[gnso-rds-pdp-wg] [EXT] Re: international law enforcement association resolution regarding domain registration data

Mon Apr 24 15:31:29 UTC 2017

Scott,

I understand the context.  However, I am not sure how the RDS gets you any
further unless it is coupled with a requirement that all registrations be
verified so that the gated access will result in meaningful information.

Also, I am not sure to what extent it would aid in the accuracy of the
underlying WHOIS data.  People who want to keep their information
confidential or who would otherwise provide fake data will certainly find a
way of avoiding having to provide the data you are seeking.  Nominet
recently (3 years ago :-( ) went through this with the .UK requirement of
confirmed WHOIS.  They wanted to make sure that registrants were ³connected²
to the UK and that the WHOIS data was correct.  However, it is a simple
process to avoid, including the use of agents and/or dropbox locations and
the like.  Corporate registrant data remains virtually untraceable (just as
real estate holdings do) in terms of the Beneficial Owners.  So, while I
sympathize with the desire to have accurate WHOIS data I remain at a loss as
to how this can be achieved.  Asking Registrars to employ complex and costly
investigative or confirmation systems would seem to conflict with the
economic  model in which registrars receive very little gross margin (let
alone profit) from domain registrations.

And, while I understand the argument about privacy when it comes to
registration data I do not share the opinion that it should all be private.
Those desiring to restrict their personal data can easily do so through use
of agents and privacy services.  That they chose not to do so is not an
issue that IMHO the rest of the public really needs to bear the burden for.

Disclosure:  I am a lawyer in the domain space, a director of DomainTools
and an active domain investor.  I use WHOIS in my daily practice.

Paul Keating

From:  "Hollenbeck, Scott" <shollenbeck at verisign.com>
Date:  Monday, April 24, 2017 at 4:54 PM
To:  "'cdoman at alienvault.com'" <cdoman at alienvault.com>, Paul Keating
<paul at law.es>, "'gnso-rds-pdp-wg at icann.org'" <gnso-rds-pdp-wg at icann.org>
Subject:  RE: [EXT] Re: [gnso-rds-pdp-wg] international law enforcement
association resolution regarding domain registration data

> Chris, in the note below I shared an actual example of an existing contact
> identifier/handle, ³C270-LRMS². It¹s an identifier that¹s assigned by the
> registry when the contact is created, and it¹s guaranteed to be unique within
> the registry namespace. It can be generated in many different ways (hash
> values are certainly one possible way) as long as the final value conforms to
> the syntax described in the EPP specifications.
>  
> One thing that makes these identifiers interesting is that they, too, can be
> searched for in an RDDS. In theory, we could have a system that returned
> nothing but these abstract identifiers in responses to domain name queries.
> One would then have to issue additional queries to see the details behind the
> handle, and if the system were designed in such a way it would be possible to
> restrict access to this information based on whatever policies exist for
> access to personally identifiable information.
>  
> 
> Scott
>  
> 
> From: Chris Doman [mailto:cdoman at alienvault.com]
> Sent: Monday, April 24, 2017 9:38 AM
> To: Paul Keating <Paul at law.es>; Hollenbeck, Scott <shollenbeck at verisign.com>;
> 'gnso-rds-pdp-wg at icann.org' <gnso-rds-pdp-wg at icann.org>
> Subject: [EXTERNAL] Re: [EXT] Re: [gnso-rds-pdp-wg] international law
> enforcement association resolution regarding domain registration data
>  
> 
> Can you provide an example of a handle please for my understanding?
> 
>  
> 
> Do you mean for example a hashed user id from a registrar, or an email
> address?
> 
> 
> From:gnso-rds-pdp-wg-bounces at icann.org <gnso-rds-pdp-wg-bounces at icann.org> on
> behalf of Paul Keating <Paul at law.es>
> Sent: 24 April 2017 14:31:21
> To: Hollenbeck, Scott; 'gnso-rds-pdp-wg at icann.org'
> Subject: [EXT] Re: [gnso-rds-pdp-wg] international law enforcement association
> resolution regarding domain registration data
> 
>  
> 
> I would like to understand this further and forgive my ignorance.  Could
> you please explain what you mean by the following:
> 
> We already have "anonymized unique identifiers" in the form of contact
> identifiers, sometimes also known as "handles" (but not to be confused
> with handle system (RFC 3650) identifiers). For example, a WHOIS query for
> a particular domain to one particular thick RDDS registry service will
> return a registrant identifier of "C270-LRMS" in addition to the more
> identifiable information that we're all familiar with. RDAP also supports
> these identifiers, so they are available for purposes as we see fit to
> recommend.
> 
> 
> 
> Also, although WHOIS information itself is not always helpful, WHOIS
> combined with other data (including DNS and historical data) can be
> extremely helpful.  So, I am not at all certain as to what is intended by
> the message or what the solution proposed is or how it works.
> 
> Thank you,
> 
> Paul Keating
> 
> On 4/24/17, 2:47 PM, "Hollenbeck, Scott via gnso-rds-pdp-wg"
> <gnso-rds-pdp-wg-bounces at icann.org on behalf of gnso-rds-pdp-wg at icann.org
> <mailto:gnso-rds-pdp-wg-bounces at icann.org%20on%20behalf%20of%20gnso-rds-pdp-wg
> @icann.org> >
> wrote:
> 
>> >I must have missed this note when it was original sent back in March.
>> >Chuck asked me to address one of the questions posed below.
>> >
>> >Scott
>> >
>>> >> -----Original Message-----
>>> >> From: Gomes, Chuck
>>> >> Sent: Monday, April 24, 2017 7:48 AM
>>> >> To: Hollenbeck, Scott <shollenbeck at verisign.com>
>>> >> Subject: FW: [EXTERNAL] Re: [gnso-rds-pdp-wg] international law
>>> >> enforcement association resolution regarding domain registration data
>>> >>
>>> >> FYI Scott.
>>> >>
>>> >> Chuck
>>> >>
>>> >> -----Original Message-----
>>> >> From: theo geurts [mailto:gtheo at xs4all.nl]
>>> >> Sent: Thursday, March 02, 2017 4:21 PM
>>> >> To: Gomes, Chuck <cgomes at verisign.com>; Greg Aaron <gca at icginc.com>
>>> >> Cc: gnso-rds-pdp-wg at icann.org
>>> >> Subject: [EXTERNAL] Re: [gnso-rds-pdp-wg] international law enforcement
>>> >> association resolution regarding domain registration data
>>> >>
>>> >>
>>> >> Thanks, Chuck.
>>> >>
>>> >> I think it is important that we as a WG understand that gated access
>>> >>could
>>> >> be a recommendation. But it does not single out any other
>>> >> solutions/recommendations,  but to get to that point, we should keep
>>> >> exploring.
>>> >>
>>> >> To give this some more color. In 2016 we assisted paloaltonetworks.com
>>> >>and
>>> >> shadow server taking down the Prince of Persia malware that went
>>> >> undetected and roamed the internet for ten years (that's a long time
>>> >> folks) http://researchcenter.paloaltonetworks.com/2016/06/unit42-prince-
>>> >> of-persia-game-over/
>>> >>
>>> >> So the actual WHOIS data was useless in a sense we were dealing with
>>> >> stolen identities.
>>> >> But we were able to map out the botnet controller network through the
>>> >> WHOIS and coordinated with more Registrars to sinkhole the entire lot.
>>> >>
>>> >> Again the WHOIS data was useless in this case as it was fake, could have
>>> >> passed every syntax or WHOIS cross-validation check.
>>> >>
>>> >> So instead of gated access, why not aim for an RDS that used anonymized
>>> >> unique identifiers that are available for everyone?
>> >
>> >We already have "anonymized unique identifiers" in the form of contact
>> >identifiers, sometimes also known as "handles" (but not to be confused
>> >with handle system (RFC 3650) identifiers). For example, a WHOIS query
>> >for a particular domain to one particular thick RDDS registry service
>> >will return a registrant identifier of "C270-LRMS" in addition to the
>> >more identifiable information that we're all familiar with. RDAP also
>> >supports these identifiers, so they are available for purposes as we see
>> >fit to recommend.
>> >
>> >Scott
>> >_______________________________________________
>> >gnso-rds-pdp-wg mailing list
>> >gnso-rds-pdp-wg at icann.org
>> >https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
> 
> 
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