[comments-whois] WhoIs Task force comments

["Tews, Shane" <stews@verisign.com>]

These comments are being submitted on behalf of the Network Solutions
registrar:
Network Solutions recognizes that a significant amount of effort has been
invested in reaching this interim draft document; however, the draft report
does not yet reflect a throrough vetting of all the issues related to the
future of WhoIs, nor a community consensus on it conclusions.

Bulk WhoIs is one of the causes of the current Spam problem that has several
State legislatures and the Congress looking at ways to curb the abuse of
e-mail addresses for unsolicited marketing appeals.  Bulk WhoIs is a cause
of concern for privacy advocates as well.  Choosing to use the domain name
system for either personal or professional use should not be a cause for the
abuse your name, address, phone number, fax number and e-mail.  For example,
a single woman who has been the subject of harassment has a legitimate basis
for concern that her personally identifiable information is publicly
available.  Network Solutions believe this and other legal/societal
circumstances are legitimate grounds for establishing limits on the
availability of contact information.  

Such consumer privacy concerns have not yet been addressed by in this
report.  Until these concerns are addressed, by recognizing the variety of
cause of the inaccurate information, progress on improvements on WhoIs
accuracy will be difficult.  

Network Solutions stands ready to contribute to an on-going discussion
addressing this topic.