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[comments-whois] Comment on 15 Day Response Requirement

I have a personal experience with the 15 day data accuracy requirement to
pass along. Shortly after ICANN initiated its new reporting and 15 day
response policy, I received a message from my registrar stating that the
whois data for my personal domain name (lextext.com) was inaccurate and that
ICANN had asked the registrar to correct the information immediately. In
order to comply with the 15-day ICANN-imposed deadline, the registrar asked
me to submit correct information within 7 days or run the risk that my
domain name would be deleted. That's a very short amount of time to get a
response, given potential vacation schedules, illness, etc. We should keep
in mind that the 15-day deadline is a deadline for the registrar to respond
to ICANN. In order to do so within that time frame, the registrar must
necessarily provide the domain name registrant an even shorter amount of

The real problem with the complaint against my domain name, however, was
that the complaint itself was fraudulent. My whois data was correct. The
complaint was submitted by some anonymous prankster, forwarded to my
registrar, and then forwarded on to me without any attempt along the way to
verify the accuracy of the complaint. It concerns me to think that my domain
name could have been deleted as a result of this fraudulent complaint had I
not responded within 7 days. In fact, that scenario ought to frighten a lot
of people. The current rule provides significant opportunity for abuse.

Here are three suggestions:

(1) ICANN should not accept anonymous complaints about whois inaccuracy. As
I understand it, ICANN currently logs the IP Address of the person who
submits a complaint, but does not require the person to submit any details
about his or her identity. That seems insufficient. The complaint form
should have mandatory fields for name, company, address, city, state,
country, telephone, and e-mail address for all complainants. Once a
complaint is submitted, an e-mail should be sent back to the complainant's
e-mail address for verification. Only when a response is received should the
complaint be lodged with ICANN. (This can be automated.) Registrants and
registrars should be provided the identity of the person filing the
complaint. A minimum level of verification and disclosure would go a long
way to curbing abuse of the system.

(2) The 15-day deadline should be extended to at least 30 days.

(3) The deletion grace period should apply to domain names deleted because
they allegedly had inaccurate whois data.

Thank you for your consideration.

Respectfully submitted,

Bret Fausett

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