At-Large Preliminary Issue Report on ‘Thick’ Whois Workspace

Click here to download the ALAC Statement on the Thick Whois Preliminary Report in PDF format.

ALAC Statement on the Thick Whois Preliminary Report

23 December 2011

The ALAC generally supports all gTLD registries using the thick Whois model, but regardless of outcome, the ALAC strongly encourages the GNSO to initiate such a PDP.

We believe that the Preliminary Issue Report reasonably reflect the issues and specifications for a PDP, with one exception. Specifically the following is problematic:

Are there other models that could / should be considered? For example, in the context of registrar deliberations on this issue, it was suggested that ‘depositing the [W]hois at a common third party across all ICANN-contracted TLDs’ could be considered.

We find this problematic for three reasons:

1. Looking at the specific example, having a common third party for all gTLDs is, to some extent, counter to the intent of having registries spread around the world. It centralizes where the long-term intent is to decentralize. Even if a less centralized approach is taken where there are multiple Whois providers, presumably certified or accredited by ICANN, we end up with ICANN taking on a new responsibility without any real substantive benefits. Moreover, it takes a level of control out of the hands of the Registry. This level of control has been important when one looks at the tiered access that some Registries provide to meet local/regional privacy concerns.
2. In the more general case, opening up this PDP to an overall review of Whois models (and perhaps ultimately the Whois concept itself) will take what appears to be a relatively straight-forward issue and transform it into the global Whois debate, That debate is being addressed in a number of other ways at the moment, and the GNSO should take care to ensure that this limited PDP does not morph into the larger and far more contentious issue.
3. Lastly, consideration of alternate Whois models does not make sense in relation to just a few gTLDs, all the more so when there are other activities in ICANN that are at this time considering the more general Whois question, potentially including alternative models.

The ALAC does note that some in At-Large are particularly concerned with issues related to privacy, and feel that any policy development be done with the full consideration of privacy issues and in particular should not take actions that would lessen the availability of legitimate and legal access to privacy. Moreover, there have also been concerns raised that a thick Whois requires the storage of personal information outside of the country of origin and such issues might also be included in any PDP.

In summary, with the one exception noted above, the ALAC supports the Preliminary Issue Report, and supports the initiation of a PDP on the narrow issue of requiring that all Registries move to or continue to use the thick Whois model. Moreover we encourage the completion of all such deliberations within a time-frame comparable to the expected go-live launch of the new gTLDs.

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(Draft version and comments follow)

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Draft ALAC Statement on the Thick Whois Preliminary Report

Author: Alan Greenberg with support of Carlton Samuels

The ALAC generally supports all gTLD registries using the thick Whois model, but regardless of outcome, the ALAC strongly encourages the GNSO to initiate such a PDP.

We believe that the Preliminary Issue Report reasonably reflect the issues and specifications for a PDP, with one exception. Specifically the following is problematic:

Are there other models that could / should be considered?

For example, in the context of registrar deliberations on this issue, it was suggested that ‘depositing the [W]hois at a common third party across all ICANN-contracted TLDs’ could be considered.

We find this problematic for two reasons:

1. Looking at the specific example, having a common third party for all gTLDs to some extent is counter to the intent of having registries spread around the world. It centralizes where the long-term intent is to decentralize. If a less centralized approach is taken, where there are multiple Whois providers, perhaps certified by ICANN, we end up with ICANN taking on a new responsibility without any real substantive benefits. Moreover, it takes a level of control out of the hands of the Registry. This level of control has been important when one looks at the tiered access that some Registries provide to meet local/regional privacy concerns.
2. In the more general case, opening up this PDP to an overall review of Whois models (and perhaps ultimately the Whois concept itself) will take what appears to be a relatively straight-forward issue and transform it into the global Whois debate, That debate is being addressed in a number of other ways at the moment, and the GNSO should take care to ensure that this limited PDP does not morph into the larger and far more contentious issue.

The ALAC does note that some in At-Large are particularly concerned with issues related to privacy, and feel that any policy development be done with the full consideration of privacy issues and in particular should not take actions that would lessen the availability of legitimate and legal access to privacy. Moreover, there have also been concerns raised that a thick Whois requires the storage of personal information outside of the country of origin and such issues might also be included in any PDP.

In summary, with the one exception noted above, the ALAC supports the Preliminary Issue Report, and supports the initiation of a PDP on the narrow issue of requiring that all Registries move to or continue to use the thick Whois model. Moreover we encourage the completion of all such deliberations within a time-frame comparable to the expected go-live launch of the new gTLDs.