[gnso-rds-pdp-wg] international law enforcement association resolution regarding domain registration data
tisrael at cippic.ca
tisrael at cippic.ca
Fri Apr 28 00:28:17 UTC 2017
On 2017-04-27 7:08 PM, John Bambenek wrote:
> Sent from my iPhone
>
> On Apr 27, 2017, at 17:54, "tisrael at cippic.ca
> <mailto:tisrael at cippic.ca>" <tisrael at cippic.ca
> <mailto:tisrael at cippic.ca>> wrote:
>
>>
>>
>> On 2017-04-27 5:58 PM, John Bambenek wrote:
>>> On 4/27/2017 4:43 PM, tisrael at cippic.ca wrote:
>>>> Hi John,
>>>>
>>>> As long as it's a true choice this might be ok. As in a cost-less
>>>> opt-in choice the registrant can make and re-make at any time.
>>>>
>>>
>>> This is exactly what I advocate. Literally check a box, uncheck a
>>> box... hell, I'll even pop for making some videos and a website
>>> explaining to consumers the pros and cons of doing both.
>> It doesn't sound like this is what you're proposing at all though.
>> You seem to be saying there should be a searchable database for at
>> least some thick WHOIS data items even if someone chooses the
>> 'private' stream.
>
> As far as I am concerned the only data besides "PRIVATE" the needs to
> be shown in that case is nameservers (the domain wouldn't work without
> making that public somehow anyway). I would like registration,
> renewal, expiration dates. Other than that, they marked their info
> private, its private.
>
>>>
>>>> But you would still need to develop a mechanism for legitimate
>>>> access to the 'privacy stream' data that should reflect broader
>>>> access norms. For example, if you are accessing for private rights
>>>> enforcement purposes, you would need to meet the civil discovery
>>>> threshold. If you're accessing for law enforcement purposes, you
>>>> would need to meet a whole other, more rigorous threshold. This
>>>> might differ by jurisdiction as well (if you're an LEA from country
>>>> A as opposed to country B).
>>>>
>>>> And even in respect to those in the fully public WHOIS stream, you
>>>> may still wish to impose some conditions. After all most data
>>>> protection regimes impose some conditions even on fully public
>>>> personal information.
>>>
>>> The question then becomes on what data fields is that true. Lots of
>>> data is stored by registrars... I don't need, for instance, credit
>>> card information (well, I do, but those requests are handled via law
>>> enforcement). In Canada, google shows a variety of things that let
>>> me search property / title records... as a rough analogy, why is
>>> what we
>> I'm not actually familiar with a google-able property search but
>> presumably the key difference would be that ownership of a property
>> doesn't in effect reveal anonymous activity of the type you would be
>> undertaking on an otherwise anonymous website.
>
> See above but I would dispute domain registrant info anyway unmasks
> any activity on an otherwise anonymous website. All it says is who
> owns a domain.
Ah my apologies, I totally misunderstood. I mean I don't have an issue
w/name servers and date of registration etc. CIRA's approach to
anonymous WHOIS is reasonable:
WHOIS search results
*Personal information about the holder of this domain name is not
available in the search results because the registration is privacy
protected.*
Interested in contacting the holder of this domain name? CIRA offers
an online Message Delivery Form
<https://services.cira.ca/agree/mdf/index.action> that allows you to
send a message to the Administrative Contact for this domain name.
------------------------------------------------------------------------
*Domain name:* XXXXXX.ca
*Domain name status:* registered
*Creation date:* 2015/01/09
*Expiry date:* 2018/01/09
*Updated date:* 2017/02/23
*DNSSEC:* Unsigned
*Registrar name:* Rebel.ca Corp.
*Registrar number:* 45
*_Name servers_*
*DNS 1 hostname:* ns1.afraid.org
*DNS 2 hostname:*
ns2.afraid.org
*DNS 3 hostname:*
ns3.afraid.org
*DNS 4 hostname:*
ns4.afraid.org
*DNS 5 hostname:*
*DNS 6 hostname:*
*DNS 7 hostname:*
*DNS 8 hostname:*
*DNS 9 hostname:*
*DNS 10 hostname:*
*DNS 11 hostname:*
*DNS 12 hostname:*
>
>>
>> Best,
>> Tamir
>>>>
>>>> Best,
>>>> Tamir
>>>>
>>>> On 2017-04-27 2:34 PM, John Bambenek via gnso-rds-pdp-wg wrote:
>>>>>
>>>>> That was why I advocate whois privacy (or equivalent). WHOIS
>>>>> would still be public be some elements need to be public
>>>>> (nameservers) or it just doesn't work... the consumer is free to
>>>>> choose which lane they want to be in, and the rest of us can use
>>>>> that data how we see fit.
>>>>>
>>>>>
>>>>> On 4/27/2017 1:17 PM, tisrael at cippic.ca wrote:
>>>>>> Hi there,
>>>>>>
>>>>>> Sorry to interject here.
>>>>>>
>>>>>> I think a governance exercise here must look beyond what the law
>>>>>> strictly allows in terms of formulating WHOIS and to how a given
>>>>>> WHOIS configuration will impact on recognized legal privacy
>>>>>> protections.
>>>>>>
>>>>>> So, in Canada, our courts have built legal protections and
>>>>>> safeguards into the civil discovery process that determine under
>>>>>> what conditions anonymous online activity can be identified.
>>>>>> Similarly, we have constitutional protections that prevent
>>>>>> private entities from voluntarily identifying anonymous online
>>>>>> actors to law enforcement if certain procedural steps aren't met.
>>>>>>
>>>>>> Making WHOIS public by default would effectively bypass all of
>>>>>> these safeguards. Surely that, then, also has to be a
>>>>>> consideration in a governance process of this sort?
>>>>>>
>>>>>> Best regards,
>>>>>> Tamir
>>>>>>
>>>>>> On 2017-04-27 2:07 PM, Paul Keating wrote:
>>>>>>> All good questions but I would like to start with the scope of
>>>>>>> the. Urrent laws as it applies to current Whois data.
>>>>>>>
>>>>>>> Sincerely,
>>>>>>> Paul Keating, Esq.
>>>>>>>
>>>>>>> On Apr 27, 2017, at 7:47 PM, allison nixon <elsakoo at gmail.com
>>>>>>> <mailto:elsakoo at gmail.com>> wrote:
>>>>>>>
>>>>>>>> I'm sure everyone's schedules are quite busy, and they will
>>>>>>>> manage.
>>>>>>>>
>>>>>>>> We need a proper legal authority here because it's potentially
>>>>>>>> falsely being presumed that the use of WHOIS data is illegal
>>>>>>>> and noncompliant in the first place. We simply do not know if
>>>>>>>> that is a factual premise. We also need to take into account
>>>>>>>> laws other than the EU privacy laws, and laws outside the EU. A
>>>>>>>> number of exemptions exist within these privacy laws and those
>>>>>>>> people throwing around the legal arguments accusing this of
>>>>>>>> being illegal don't seem to ever mention that fact. We need an
>>>>>>>> unbiased legal expert.
>>>>>>>>
>>>>>>>> What if a country is trying to enforce a law that is deemed
>>>>>>>> distasteful (violates human rights, etc), and their registrant
>>>>>>>> is located within the country? does the gatekeeper have grounds
>>>>>>>> to deny them the ability to enforce their own laws against
>>>>>>>> their own people, and if so when?
>>>>>>>>
>>>>>>>> How does WHOIS play into other areas of compliance, such as
>>>>>>>> know-your-customer, complying with sanctions, anti-money
>>>>>>>> laundering, HIPPAA, PCI, etc? Is complying to one law more
>>>>>>>> important than complying to another, if one had to choose?
>>>>>>>>
>>>>>>>> Will the gatekeeper comply with anti-trust laws?
>>>>>>>>
>>>>>>>> How does privacy law prohibit information collection on
>>>>>>>> registrants yet collect detailed PII info on queriers and
>>>>>>>> subject them to audit? What happens if the gatekeeper is hacked
>>>>>>>> into for those audit logs? What happens if the gatekeeper
>>>>>>>> receives a national security letter?
>>>>>>>>
>>>>>>>> All of these are legal questions that need to be answered
>>>>>>>> without bias and with full understanding of the facts.
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>>
>>>>>>>> On Thu, Apr 27, 2017 at 12:42 PM, Stephanie Perrin
>>>>>>>> <stephanie.perrin at mail.utoronto.ca
>>>>>>>> <mailto:stephanie.perrin at mail.utoronto.ca>> wrote:
>>>>>>>>
>>>>>>>> And we need to have a lengthy discussion about precisely
>>>>>>>> who that legal expert might be. It appears that many of
>>>>>>>> our members are prepared to reject the views of the Data
>>>>>>>> Protection Authorities themselves, who took the time out of
>>>>>>>> their extraordinarily busy schedules to come and speak with
>>>>>>>> us in Copenhagen.
>>>>>>>>
>>>>>>>> Stephanie Perrin
>>>>>>>>
>>>>>>>>
>>>>>>>> On 2017-04-27 09:14, Gomes, Chuck via gnso-rds-pdp-wg wrote:
>>>>>>>>>
>>>>>>>>> We as a WG have not requested funds for a legal expert,
>>>>>>>>> but I don’t know what staff has built into the Draft FY18
>>>>>>>>> budget.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Marika – Did the Policy Team build any funds into the
>>>>>>>>> Draft FY18 budget for legal experts?
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Note that this is a very time sensitive issue because the
>>>>>>>>> comment period on the Draft FY18 Operating Plan and Budget
>>>>>>>>> ends tomorrow.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Lisa/Marika/Amr – Please prepare a draft comment on the
>>>>>>>>> Budget that the Leadership Team or me as Chair could send
>>>>>>>>> on Friday in this regard. If funds have not been proposed
>>>>>>>>> for such expenses, I think we should at a minimum raise
>>>>>>>>> the issue in the public comment forum even if there is not
>>>>>>>>> time to propose specific details.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Chuck
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> *From:*gnso-rds-pdp-wg-bounces at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg-bounces at icann.org>
>>>>>>>>> [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of
>>>>>>>>> *Paul Keating
>>>>>>>>> *Sent:* Thursday, April 27, 2017 7:55 AM
>>>>>>>>> *To:* Greg Shatan <gregshatanipc at gmail.com>
>>>>>>>>> <mailto:gregshatanipc at gmail.com>; Volker Greimann
>>>>>>>>> <vgreimann at key-systems.net> <mailto:vgreimann at key-systems.net>
>>>>>>>>> *Cc:* RDS PDP WG <gnso-rds-pdp-wg at icann.org>
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> *Subject:* [EXTERNAL] Re: [gnso-rds-pdp-wg] international
>>>>>>>>> law enforcement association resolution regarding domain
>>>>>>>>> registration data
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Has the WG requested funds to retain a legal expert to
>>>>>>>>> educate us on the actual laws at issue?
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> *From: *<gnso-rds-pdp-wg-bounces at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg-bounces at icann.org>> on behalf of
>>>>>>>>> Greg Shatan <gregshatanipc at gmail.com
>>>>>>>>> <mailto:gregshatanipc at gmail.com>>
>>>>>>>>> *Date: *Thursday, April 27, 2017 at 12:38 AM
>>>>>>>>> *To: *Volker Greimann <vgreimann at key-systems.net
>>>>>>>>> <mailto:vgreimann at key-systems.net>>
>>>>>>>>> *Cc: *RDS PDP WG <gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>>
>>>>>>>>> *Subject: *Re: [gnso-rds-pdp-wg] international law
>>>>>>>>> enforcement association resolution regarding domain
>>>>>>>>> registration data
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> We also need to be very clear about the limits of the
>>>>>>>>> legal requirements of applicable law, and the various
>>>>>>>>> options available for dealing with the law. There's
>>>>>>>>> no need to overcomply. Indeed it would be quite
>>>>>>>>> unreasonable to do so.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Just as paying the lowest calculable income tax is
>>>>>>>>> perfectly legitimate, so is complying with the law in
>>>>>>>>> the least disruptive way possible.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Greg
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> *Greg Shatan
>>>>>>>>> *C: 917-816-6428 <tel:%28917%29%20816-6428>
>>>>>>>>> S: gsshatan
>>>>>>>>> Phone-to-Skype: 646-845-9428 <tel:%28646%29%20845-9428>
>>>>>>>>> gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Wed, Apr 26, 2017 at 1:06 PM, Volker Greimann
>>>>>>>>> <vgreimann at key-systems.net
>>>>>>>>> <mailto:vgreimann at key-systems.net>> wrote:
>>>>>>>>>
>>>>>>>>> I wish it were so simple. "Doing harm" is not
>>>>>>>>> necessary to be in violation with applicable law.
>>>>>>>>> Just like jaywalking, speeding on an empty road or
>>>>>>>>> crossing a red light carries a fine regardless of
>>>>>>>>> whether harm was done, privacy law too does not
>>>>>>>>> care about an actual harm.
>>>>>>>>>
>>>>>>>>> We need to be very clear about the legal
>>>>>>>>> requirements when we define the limits of what can
>>>>>>>>> be done with the data we collect, and by whom.
>>>>>>>>>
>>>>>>>>> Volker
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Am 26.04.2017 um 18:43 schrieb John Horton:
>>>>>>>>>
>>>>>>>>> Greg, well said. And Tim, well said. And I'll
>>>>>>>>> strongly +1 Michael Hammer as well. I agree
>>>>>>>>> with the "do no harm" philosophy -- I'm not
>>>>>>>>> convinced that some of the proposed changes
>>>>>>>>> (e.g., those outlined in the EWG report)
>>>>>>>>> wouldn't cause more harm than the existing,
>>>>>>>>> admittedly imperfect, system. As I've said
>>>>>>>>> before, the importance of tools like Reverse
>>>>>>>>> Whois isn't only direct -- it's derivative as
>>>>>>>>> well. (If you enjoy the benefits of those of
>>>>>>>>> us who fight payment fraud, online abuse and
>>>>>>>>> other sorts of malfeasance, you have reverse
>>>>>>>>> Whois among other tools to thank.) Privacy
>>>>>>>>> laws in one part of the world are a factor we
>>>>>>>>> need to be aware of, among other factors.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Wed, Apr 26, 2017 at 9:07 AM nathalie
>>>>>>>>> coupet via gnso-rds-pdp-wg
>>>>>>>>> <gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>> wrote:
>>>>>>>>>
>>>>>>>>> +1
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Nathalie
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Wednesday, April 26, 2017 12:02 PM,
>>>>>>>>> Victoria Sheckler <vsheckler at riaa.com
>>>>>>>>> <mailto:vsheckler at riaa.com>> wrote:
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> +1
>>>>>>>>>
>>>>>>>>> Sent from my iPhone
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Apr 26, 2017, at 8:56 AM, Greg Shatan
>>>>>>>>> <gregshatanipc at gmail.com
>>>>>>>>> <mailto:gregshatanipc at gmail.com>> wrote:
>>>>>>>>>
>>>>>>>>> Thanks for weighing in, Tim. Since
>>>>>>>>> this is a multi_stakeholder_ process,
>>>>>>>>> everyone is assumed to come in with a
>>>>>>>>> point of view, so don't be shy. At
>>>>>>>>> the same time, if stakeholders cling
>>>>>>>>> dogmatically to their points of view
>>>>>>>>> the multistakeholder model doesn't work.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> As for being out on a limb:
>>>>>>>>>
>>>>>>>>> * We haven't decided what data will
>>>>>>>>> be "private" and for which
>>>>>>>>> registrants (e.g., based on
>>>>>>>>> geography or entity status)
>>>>>>>>> * We haven't decided there will be
>>>>>>>>> "gated" access and what that might
>>>>>>>>> mean, both for policy and practicality
>>>>>>>>> * The question shouldn't be whether
>>>>>>>>> we will be "allowing third parties
>>>>>>>>> access to harvest, repackage and
>>>>>>>>> republish that data," but how we
>>>>>>>>> should allow this in a way that
>>>>>>>>> balances various concerns.
>>>>>>>>> Eliminating reverse Whois and
>>>>>>>>> other such services is not a goal
>>>>>>>>> of this Working Group.
>>>>>>>>>
>>>>>>>>> Our job should be to provide the
>>>>>>>>> greatest possible access to the best
>>>>>>>>> possible data, consistent with
>>>>>>>>> minimizing risk under reasonable
>>>>>>>>> interpretations of applicable law. We
>>>>>>>>> need to deal with existing and
>>>>>>>>> incoming privacy laws (and with other
>>>>>>>>> laws) as well, but not in a worshipful
>>>>>>>>> manner; instead it should be in a
>>>>>>>>> solution-oriented manner. This is
>>>>>>>>> not, after all, the Privacy Working
>>>>>>>>> Group. I'll +1 Michael Hammer: Rather
>>>>>>>>> than starting from a model of
>>>>>>>>> justifying everything and anything
>>>>>>>>> from a privacy perspective, I would
>>>>>>>>> suggest that it would be much more
>>>>>>>>> appropriate, other than technical
>>>>>>>>> changes such as moving towards using
>>>>>>>>> JSON, to require justification and
>>>>>>>>> consensus for any changes from the
>>>>>>>>> existing model(s) of WHOIS.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Finally, while our purpose is not to
>>>>>>>>> maintain anyone's economic interest,
>>>>>>>>> economic interests may well be aligned
>>>>>>>>> with policy interests. Assuming that
>>>>>>>>> economic interests are at odds with
>>>>>>>>> policy interests is just as dangerous
>>>>>>>>> as assuming that policy interests are
>>>>>>>>> served by maximizing economic interests.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Greg
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> *Greg Shatan
>>>>>>>>> *C: 917-816-6428
>>>>>>>>> <tel:%28917%29%20816-6428>
>>>>>>>>> S: gsshatan
>>>>>>>>> Phone-to-Skype: 646-845-9428
>>>>>>>>> <tel:%28646%29%20845-9428>
>>>>>>>>> gregshatanipc at gmail.com
>>>>>>>>> <mailto:gregshatanipc at gmail.com>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Wed, Apr 26, 2017 at 11:28 AM,
>>>>>>>>> Dotzero <dotzero at gmail.com
>>>>>>>>> <mailto:dotzero at gmail.com>> wrote:
>>>>>>>>>
>>>>>>>>> Adding to what Tim and Allison wrote.
>>>>>>>>>
>>>>>>>>> As a starting point, I've had an
>>>>>>>>> account with DomainTools in the
>>>>>>>>> past and will likely have one in
>>>>>>>>> the future, although I don't
>>>>>>>>> currently have one.
>>>>>>>>>
>>>>>>>>> There are other organizations and
>>>>>>>>> individuals which
>>>>>>>>> consume/aggregate whois data so I
>>>>>>>>> don't think that for the purposes
>>>>>>>>> of this discussion the focus
>>>>>>>>> should be on just DomainTools. I
>>>>>>>>> know researchers and academics who
>>>>>>>>> use this data to analyze all sorts
>>>>>>>>> of things. As has been pointed
>>>>>>>>> out, there are all sorts of folks
>>>>>>>>> staking out positions because of
>>>>>>>>> their economic (and other)
>>>>>>>>> interests without necessarily
>>>>>>>>> being transparent about those
>>>>>>>>> interests.
>>>>>>>>>
>>>>>>>>> It should be remembered that the
>>>>>>>>> Internet is an agglomeration of
>>>>>>>>> many networks and resources, some
>>>>>>>>> public and some private. At the
>>>>>>>>> same time, it is simply a bunch of
>>>>>>>>> technical standards that people
>>>>>>>>> and organizations have agreed to
>>>>>>>>> use to interact with each other.
>>>>>>>>> In many cases, the ultimate
>>>>>>>>> solution to abuse is to drop
>>>>>>>>> route. To the extent that good and
>>>>>>>>> granular information is not
>>>>>>>>> readily available, regular
>>>>>>>>> (innocent) users may suffer as
>>>>>>>>> owners and administrators of
>>>>>>>>> resources act to protect those
>>>>>>>>> resources and their legitimate
>>>>>>>>> users from abuse and
>>>>>>>>> maliciousness. The reality is that
>>>>>>>>> most users of the internet utilize
>>>>>>>>> a relatively small subset of all
>>>>>>>>> the resources out there. For some,
>>>>>>>>> a service like Facebook IS the
>>>>>>>>> Internet.
>>>>>>>>>
>>>>>>>>> It may also incite a tendency
>>>>>>>>> towards returning to a model of
>>>>>>>>> walled gardens. At various points
>>>>>>>>> I have heard discussions about the
>>>>>>>>> balkanization of the internet,
>>>>>>>>> with things like separate roots,
>>>>>>>>> etc. People should think very
>>>>>>>>> carefully about what they are
>>>>>>>>> asking for because they may not be
>>>>>>>>> happy with it if they actually get it.
>>>>>>>>>
>>>>>>>>> Rather than starting from a model
>>>>>>>>> of justifying everything and
>>>>>>>>> anything from a privacy
>>>>>>>>> perspective, I would suggest that
>>>>>>>>> it would be much more appropriate,
>>>>>>>>> other than technical changes such
>>>>>>>>> as moving towards using JSON, to
>>>>>>>>> require justification and
>>>>>>>>> consensus for any changes from the
>>>>>>>>> existing model(s) of WHOIS.
>>>>>>>>>
>>>>>>>>> Michael Hammer
>>>>>>>>>
>>>>>>>>> On Wed, Apr 26, 2017 at 10:27 AM,
>>>>>>>>> allison nixon <elsakoo at gmail.com
>>>>>>>>> <mailto:elsakoo at gmail.com>> wrote:
>>>>>>>>>
>>>>>>>>> Thank you for your email Tim.
>>>>>>>>>
>>>>>>>>> Full disclosure(because I
>>>>>>>>> believe in being transparent
>>>>>>>>> about this sort of thing), we
>>>>>>>>> do business with Domaintools
>>>>>>>>> and use their tools to consume
>>>>>>>>> whois data.
>>>>>>>>>
>>>>>>>>> "i'll close by saying I think
>>>>>>>>> Allison's point about economic
>>>>>>>>> value has merit. yes, the
>>>>>>>>> point of the WG is not to
>>>>>>>>> protect anyone's economic
>>>>>>>>> interest. I agree 100% with
>>>>>>>>> that statement and will
>>>>>>>>> disagree with anyone who
>>>>>>>>> thinks the future of
>>>>>>>>> DomainTools or other
>>>>>>>>> commercial service should have
>>>>>>>>> one iota of impact on this
>>>>>>>>> discussion."
>>>>>>>>>
>>>>>>>>> I will however disagree
>>>>>>>>> vehemently with you on this
>>>>>>>>> point. It is obvious that many
>>>>>>>>> of the arguments to cut off
>>>>>>>>> anonymous querying to WHOIS
>>>>>>>>> data are economically
>>>>>>>>> motivated. Financial concerns
>>>>>>>>> are cited numerous times in
>>>>>>>>> approved documents. I also
>>>>>>>>> believe the "vetting" process
>>>>>>>>> is likely to become a new
>>>>>>>>> revenue stream for someone as
>>>>>>>>> well. A revenue stream with
>>>>>>>>> HIGHLY questionable privacy
>>>>>>>>> value-add.
>>>>>>>>>
>>>>>>>>> Every dollar of income for the
>>>>>>>>> Domaintools company and others
>>>>>>>>> like it come from their
>>>>>>>>> clients, who see a multiplier
>>>>>>>>> of value from it. That means
>>>>>>>>> for every dollar spent on the
>>>>>>>>> entire whois aggregator
>>>>>>>>> industry means that a much
>>>>>>>>> larger amount of money is
>>>>>>>>> saved through prevented harms
>>>>>>>>> like fraud, abuse, and even
>>>>>>>>> fake medications which kill
>>>>>>>>> people.
>>>>>>>>>
>>>>>>>>> I think it is extremely
>>>>>>>>> important to identify what
>>>>>>>>> critical systems rely on whois
>>>>>>>>> (either directly or
>>>>>>>>> downstream), and determine if
>>>>>>>>> we are ready to give up the
>>>>>>>>> utility of these systems.
>>>>>>>>>
>>>>>>>>> We also need to identify the
>>>>>>>>> value of the ability to
>>>>>>>>> anonymously query whois and
>>>>>>>>> what that loss of privacy will
>>>>>>>>> mean as well. While I
>>>>>>>>> obviously do not make many
>>>>>>>>> queries anonymously(although
>>>>>>>>> our vendor has their own
>>>>>>>>> privacy policy), I understand
>>>>>>>>> this is important especially
>>>>>>>>> to those researching more
>>>>>>>>> dangerous actors. Why would
>>>>>>>>> $_COUNTRY dissidents want to
>>>>>>>>> query domains when their
>>>>>>>>> opponents would surely be
>>>>>>>>> hacking into the audit logs
>>>>>>>>> for this?
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Apr 25, 2017 11:41 PM,
>>>>>>>>> "Chen, Tim"
>>>>>>>>> <tim at domaintools.com
>>>>>>>>> <mailto:tim at domaintools.com>>
>>>>>>>>> wrote:
>>>>>>>>>
>>>>>>>>> "And I hope more
>>>>>>>>> stakeholders in this
>>>>>>>>> multi-stakeholder process
>>>>>>>>> will come forward with
>>>>>>>>> their own perspectives, as
>>>>>>>>> they will differ from mine."
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> happy to do so.
>>>>>>>>> DomainTools is clearly a
>>>>>>>>> stakeholder in this
>>>>>>>>> debate. and we have a
>>>>>>>>> fair amount of experience
>>>>>>>>> around the challenges,
>>>>>>>>> benefits and risks of
>>>>>>>>> whois data aggregation at
>>>>>>>>> scale.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> from the beginning of this
>>>>>>>>> EWG/RDS idea we've stood
>>>>>>>>> down bc i didn't believe
>>>>>>>>> our opinion would be seen
>>>>>>>>> as objective-enough given
>>>>>>>>> our line of business. but
>>>>>>>>> it is apparent to me
>>>>>>>>> having followed this
>>>>>>>>> debate for many weeks now,
>>>>>>>>> that this is a working
>>>>>>>>> group of individuals who
>>>>>>>>> all bring their own biases
>>>>>>>>> into the debate. whether
>>>>>>>>> they care to admit that to
>>>>>>>>> themselves or not. so we
>>>>>>>>> might as well wade in too.
>>>>>>>>> bc I think our experience
>>>>>>>>> is very relevant to the
>>>>>>>>> discussion.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> i'll do my best to be as
>>>>>>>>> objective as I can, as a
>>>>>>>>> domain registrant myself
>>>>>>>>> and as an informed
>>>>>>>>> industry participant.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> since our experience is
>>>>>>>>> working with security
>>>>>>>>> minded organizations, that
>>>>>>>>> is the context with which
>>>>>>>>> I will comment.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> since this is an ICANN
>>>>>>>>> working group, I start
>>>>>>>>> with the ICANN mission
>>>>>>>>> statement around the
>>>>>>>>> security and stability of
>>>>>>>>> the DNS. I find myself
>>>>>>>>> wanting to fit this debate
>>>>>>>>> to that as the north star.
>>>>>>>>> i do not see the RDS as
>>>>>>>>> purpose driven to fit the
>>>>>>>>> GDPR or any
>>>>>>>>> region-specific legal
>>>>>>>>> resolution. but I do see
>>>>>>>>> those as important inputs
>>>>>>>>> to our discussion.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> from a security
>>>>>>>>> perspective, my experience
>>>>>>>>> is that the benefits of
>>>>>>>>> the current Whois model,
>>>>>>>>> taken with this lens, far
>>>>>>>>> outweigh the costs.
>>>>>>>>> again, I can only speak
>>>>>>>>> from my experience here at
>>>>>>>>> DomainTools, and obviously
>>>>>>>>> under the current Whois
>>>>>>>>> regime. This is not to
>>>>>>>>> say it cannot be
>>>>>>>>> improved. From a data
>>>>>>>>> accuracy perspective alone
>>>>>>>>> there is enormous room for
>>>>>>>>> improvement as I think we
>>>>>>>>> can all agree. every day
>>>>>>>>> I see the tangible
>>>>>>>>> benefits to security
>>>>>>>>> interests, which for the
>>>>>>>>> most part are "doing
>>>>>>>>> good", from the work that
>>>>>>>>> we do. when I compare
>>>>>>>>> that to the complaints
>>>>>>>>> that we get bc "my PII is
>>>>>>>>> visible in your data",
>>>>>>>>> it's not even close by my
>>>>>>>>> value barometer (which my
>>>>>>>>> differ from others').
>>>>>>>>> this is relevant bc any
>>>>>>>>> future solution will be
>>>>>>>>> imperfect as I have
>>>>>>>>> mentioned before. as
>>>>>>>>> Allison and others point
>>>>>>>>> out we need to measure the
>>>>>>>>> harm done by any new
>>>>>>>>> system that may seek to
>>>>>>>>> solve one problem
>>>>>>>>> (privacy?) and
>>>>>>>>> inadvertently create many
>>>>>>>>> more. since this group is
>>>>>>>>> fond of analogies I'll
>>>>>>>>> contribute one from the
>>>>>>>>> medical oath (not sure if
>>>>>>>>> this is just U.S.) "first,
>>>>>>>>> do no harm".
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> i'll close by saying I
>>>>>>>>> think Allison's point
>>>>>>>>> about economic value has
>>>>>>>>> merit. yes, the point of
>>>>>>>>> the WG is not to protect
>>>>>>>>> anyone's economic
>>>>>>>>> interest. I agree 100%
>>>>>>>>> with that statement and
>>>>>>>>> will disagree with anyone
>>>>>>>>> who thinks the future of
>>>>>>>>> DomainTools or other
>>>>>>>>> commercial service should
>>>>>>>>> have one iota of impact on
>>>>>>>>> this discussion. but I
>>>>>>>>> also think "it's too
>>>>>>>>> expensive" or "it's too
>>>>>>>>> hard" are weak and
>>>>>>>>> dangerous excuses when
>>>>>>>>> dealing with an issue like
>>>>>>>>> this which has enormous
>>>>>>>>> and far reaching
>>>>>>>>> consequences for the very
>>>>>>>>> mission of ICANN around
>>>>>>>>> the security and stability
>>>>>>>>> of our internet.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Tim
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Mon, Apr 24, 2017 at
>>>>>>>>> 3:50 PM, allison nixon
>>>>>>>>> <elsakoo at gmail.com
>>>>>>>>> <mailto:elsakoo at gmail.com>>
>>>>>>>>> wrote:
>>>>>>>>>
>>>>>>>>> Thanks for the
>>>>>>>>> documentation in your
>>>>>>>>> earlier email. While I
>>>>>>>>> understand that's how
>>>>>>>>> things are supposed to
>>>>>>>>> work in theory, it's
>>>>>>>>> not implemented very
>>>>>>>>> widely, and unless
>>>>>>>>> there is enforcement,
>>>>>>>>> then it's unlikely to
>>>>>>>>> be useful at all.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> "as a given, we put
>>>>>>>>> ourselves in a certain
>>>>>>>>> position in terms of
>>>>>>>>> the actions we can and
>>>>>>>>> cannot recommend. We
>>>>>>>>> can make similar
>>>>>>>>> statements focused on
>>>>>>>>> registry operators,
>>>>>>>>> registrars, or any
>>>>>>>>> other stakeholder in
>>>>>>>>> this space. If we all
>>>>>>>>> approach this WG's
>>>>>>>>> task with the goal of
>>>>>>>>> not changing anything,
>>>>>>>>> we're all just wasting
>>>>>>>>> our time."
>>>>>>>>>
>>>>>>>>> There are things that
>>>>>>>>> people would be
>>>>>>>>> willing to change
>>>>>>>>> about WHOIS. Changes
>>>>>>>>> purely relating to the
>>>>>>>>> data format would not
>>>>>>>>> be as controversial.
>>>>>>>>> Changing to that RDAP
>>>>>>>>> json format would
>>>>>>>>> probably be an
>>>>>>>>> agreeable point to
>>>>>>>>> most here.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> There are two
>>>>>>>>> different major points
>>>>>>>>> of contention here.
>>>>>>>>> The first is the data
>>>>>>>>> format, second is the
>>>>>>>>> creation of a new
>>>>>>>>> monopoly and ceding
>>>>>>>>> power to it. By
>>>>>>>>> monopoly I mean- who
>>>>>>>>> are the gatekeepers of
>>>>>>>>> "gated" access? Will
>>>>>>>>> it avoid all of the
>>>>>>>>> problems that
>>>>>>>>> monopolies are
>>>>>>>>> historically prone to?
>>>>>>>>> Who will pay them? It
>>>>>>>>> seems like a massive
>>>>>>>>> leap of faith to
>>>>>>>>> commit to this without
>>>>>>>>> knowing who we are
>>>>>>>>> making the commitment to.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> "I do not believe it
>>>>>>>>> is this WG's
>>>>>>>>> responsibility to
>>>>>>>>> protect anyone's
>>>>>>>>>
>>>>>>>>> commercial services if
>>>>>>>>> those things are
>>>>>>>>> basically in response to
>>>>>>>>> deficiencies in the
>>>>>>>>> existing Whois protocol. "
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> From my understanding
>>>>>>>>> of past ICANN working
>>>>>>>>> groups, registrars
>>>>>>>>> have fought against
>>>>>>>>> issues that would have
>>>>>>>>> increased their costs.
>>>>>>>>> And the destruction of
>>>>>>>>> useful WHOIS
>>>>>>>>> results(or becoming
>>>>>>>>> beholden to some new
>>>>>>>>> monopoly) stand to
>>>>>>>>> incur far more costs
>>>>>>>>> for far larger
>>>>>>>>> industries. So this
>>>>>>>>> shouldn't surprise
>>>>>>>>> you. If those economic
>>>>>>>>> concerns are not valid
>>>>>>>>> then I question why
>>>>>>>>> the economic concerns
>>>>>>>>> of registrars are valid.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> If entire industries
>>>>>>>>> are built around a
>>>>>>>>> feature you would
>>>>>>>>> consider a
>>>>>>>>> "deficiency", then
>>>>>>>>> your opinion may
>>>>>>>>> solely be your own.
>>>>>>>>> And I hope more
>>>>>>>>> stakeholders in this
>>>>>>>>> multi-stakeholder
>>>>>>>>> process will come
>>>>>>>>> forward with their own
>>>>>>>>> perspectives, as they
>>>>>>>>> will differ from mine.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> "Not trying to
>>>>>>>>> hamstring the WG.
>>>>>>>>> Just asking if this is
>>>>>>>>> not something that has
>>>>>>>>> already been solved.."
>>>>>>>>>
>>>>>>>>> Hi Paul,
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> It's an interesting
>>>>>>>>> thought. This document
>>>>>>>>> was recommended to me
>>>>>>>>> as one that was
>>>>>>>>> approved in the past
>>>>>>>>> by the working group
>>>>>>>>> that outlined what the
>>>>>>>>> resulting system might
>>>>>>>>> look like. I'm still
>>>>>>>>> learning and reading
>>>>>>>>> about these working
>>>>>>>>> groups and what they
>>>>>>>>> do, and this document
>>>>>>>>> is massive.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> https://www.icann.org/en/syste
>>>>>>>>> m/files/files/final-report-06j
>>>>>>>>> un14-en.pdf
>>>>>>>>> <https://www.icann.org/en/system/files/files/final-report-06jun14-en.pdf>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> In the document, it
>>>>>>>>> says: /"Central to the
>>>>>>>>> remit of the EWG is
>>>>>>>>> the question of how to
>>>>>>>>> design a system that
>>>>>>>>> increases the accuracy
>>>>>>>>> of the data collected
>>>>>>>>> while also offering
>>>>>>>>> protections for those
>>>>>>>>> Registrants seeking to
>>>>>>>>> guard and maintain
>>>>>>>>> their privacy."/
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> One of the things I
>>>>>>>>> notice is that any
>>>>>>>>> talk about actually
>>>>>>>>> increasing accuracy of
>>>>>>>>> whois info- via
>>>>>>>>> enforcement- is
>>>>>>>>> vigorously opposed in
>>>>>>>>> this group, and it's
>>>>>>>>> merely assumed that
>>>>>>>>> people will supply
>>>>>>>>> better quality data
>>>>>>>>> under the new system.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Throughout the
>>>>>>>>> document it talks
>>>>>>>>> about use-cases and
>>>>>>>>> features (whois
>>>>>>>>> history, reverse
>>>>>>>>> query, etc), which are
>>>>>>>>> indeed identical to
>>>>>>>>> the features of the
>>>>>>>>> whois aggregators of
>>>>>>>>> current day. Such a
>>>>>>>>> system would replace
>>>>>>>>> them. Will the service
>>>>>>>>> quality be as good?
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On page 63 it gets
>>>>>>>>> into thoughts on who
>>>>>>>>> would be "accredited"
>>>>>>>>> to access the gated
>>>>>>>>> whois data. Every
>>>>>>>>> proposed scenario
>>>>>>>>> seems to recognize the
>>>>>>>>> resulting system will
>>>>>>>>> need to handle a large
>>>>>>>>> query volume from a
>>>>>>>>> large number of
>>>>>>>>> people, and one
>>>>>>>>> proposes accrediting
>>>>>>>>> bodies which may
>>>>>>>>> accredit organizations
>>>>>>>>> which may accredit
>>>>>>>>> individuals. It even
>>>>>>>>> proposes an abuse
>>>>>>>>> handling system which
>>>>>>>>> is also reminiscent in
>>>>>>>>> structure to how abuse
>>>>>>>>> is handled currently
>>>>>>>>> in our domain name
>>>>>>>>> system. Many of these
>>>>>>>>> proposed schemes
>>>>>>>>> appear to mimic the
>>>>>>>>> ways that the hosting
>>>>>>>>> industry and registrar
>>>>>>>>> industry operate, so
>>>>>>>>> we can expect that the
>>>>>>>>> patterns of abuse will
>>>>>>>>> be equally frequent,
>>>>>>>>> especially if higher
>>>>>>>>> quality data is supplied.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> The proposed scenarios
>>>>>>>>> all paint a picture of
>>>>>>>>> "gated" access with
>>>>>>>>> very wide gates, while
>>>>>>>>> simultaneously
>>>>>>>>> representing to domain
>>>>>>>>> purchasers that their
>>>>>>>>> data is safe and
>>>>>>>>> privacy protected. And
>>>>>>>>> this is supposed to
>>>>>>>>> *reduce* the total
>>>>>>>>> number of privacy
>>>>>>>>> violations? This
>>>>>>>>> doesn't even appeal to
>>>>>>>>> me as a consumer of
>>>>>>>>> this data.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Whoever sets up this
>>>>>>>>> system also stands to
>>>>>>>>> inherit a lot of money
>>>>>>>>> from the
>>>>>>>>> soon-to-be-defunct
>>>>>>>>> whois aggregation
>>>>>>>>> industry. They would
>>>>>>>>> certainly win our
>>>>>>>>> contract, because we
>>>>>>>>> would have no choice.
>>>>>>>>> All domain reputation
>>>>>>>>> services, anti-spam,
>>>>>>>>> security research,
>>>>>>>>> etc, efforts will all
>>>>>>>>> need to pay up.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> After being supplied
>>>>>>>>> with the above
>>>>>>>>> document, I also saw a
>>>>>>>>> copy of a rebuttal
>>>>>>>>> written by a company
>>>>>>>>> that monitors abusive
>>>>>>>>> domains. I strongly
>>>>>>>>> agree with the
>>>>>>>>> sentiments in this
>>>>>>>>> document and I do not
>>>>>>>>> see evidence that
>>>>>>>>> those concerns have
>>>>>>>>> received fair
>>>>>>>>> consideration. While I
>>>>>>>>> do not see this new
>>>>>>>>> gatekeeper as an
>>>>>>>>> existential threat, I
>>>>>>>>> do see it as a likely
>>>>>>>>> degradation in the
>>>>>>>>> utility i do see from
>>>>>>>>> whois. To be clear, we
>>>>>>>>> do not do any business
>>>>>>>>> with this company.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> http://mm.icann.org/pipermail/
>>>>>>>>> input-to-ewg/attachments/20130
>>>>>>>>> 823/410038bb/LegitScriptCommen
>>>>>>>>> tsonICANNEWGWhoisReplacementSt
>>>>>>>>> ructure-0001.pdf
>>>>>>>>> <http://mm.icann.org/pipermail/input-to-ewg/attachments/20130823/410038bb/LegitScriptCommentsonICANNEWGWhoisReplacementStructure-0001.pdf>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> I also found John
>>>>>>>>> Bambenek's point in a
>>>>>>>>> later thread to be
>>>>>>>>> interesting-
>>>>>>>>> concentrating WHOIS
>>>>>>>>> knowledge solely to
>>>>>>>>> one organization
>>>>>>>>> allows the country it
>>>>>>>>> resides in to use it
>>>>>>>>> to support its
>>>>>>>>> intelligence
>>>>>>>>> apparatus, for example
>>>>>>>>> monitoring when its
>>>>>>>>> espionage domains are
>>>>>>>>> queried for, and
>>>>>>>>> targeting researchers
>>>>>>>>> that query them (since
>>>>>>>>> anonymous querying
>>>>>>>>> will be revoked).
>>>>>>>>> Nation states already
>>>>>>>>> use domains in
>>>>>>>>> operations so this
>>>>>>>>> monopoly is a perfect
>>>>>>>>> strategic data
>>>>>>>>> reserve. The fact that
>>>>>>>>> this system is pushed
>>>>>>>>> by privacy advocates
>>>>>>>>> is indeed ironic.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> None of those concerns
>>>>>>>>> appear to have been
>>>>>>>>> addressed by this
>>>>>>>>> group in any serious
>>>>>>>>> capacity. Before the
>>>>>>>>> addition of new
>>>>>>>>> members, I don't think
>>>>>>>>> many people had the
>>>>>>>>> backgrounds or
>>>>>>>>> skillsets to even
>>>>>>>>> understand why they
>>>>>>>>> are a concern. But I
>>>>>>>>> think this is a
>>>>>>>>> discussion worth
>>>>>>>>> having at this point
>>>>>>>>> in time for this group.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> On Mon, Apr 24, 2017
>>>>>>>>> at 1:50 PM, Andrew
>>>>>>>>> Sullivan
>>>>>>>>> <ajs at anvilwalrusden.com
>>>>>>>>> <mailto:ajs at anvilwalrusden.com>>
>>>>>>>>> wrote:
>>>>>>>>>
>>>>>>>>> Hi,
>>>>>>>>>
>>>>>>>>> On Mon, Apr 24,
>>>>>>>>> 2017 at 07:25:47PM
>>>>>>>>> +0200, Paul
>>>>>>>>> Keating wrote:
>>>>>>>>> > Andrew,
>>>>>>>>> >
>>>>>>>>> > Thank you. That
>>>>>>>>> was helpful.
>>>>>>>>> >
>>>>>>>>> > ""Given this
>>>>>>>>> registrant, what other
>>>>>>>>> > domains are
>>>>>>>>> registered?" is a
>>>>>>>>> solved problem,
>>>>>>>>> and has been since the
>>>>>>>>> > early 2000s.²
>>>>>>>>> >
>>>>>>>>> > This is also
>>>>>>>>> traceable via
>>>>>>>>> alternative means
>>>>>>>>> such as
>>>>>>>>> consistencies in
>>>>>>>>> > various WHOIS
>>>>>>>>> fields such as
>>>>>>>>> email, address,
>>>>>>>>> name, etc.
>>>>>>>>>
>>>>>>>>> Well, sort of.
>>>>>>>>> The email,
>>>>>>>>> address, and name
>>>>>>>>> fields are _user_
>>>>>>>>> supplied. So they
>>>>>>>>> come from the
>>>>>>>>> other party to the
>>>>>>>>> transaction. The
>>>>>>>>> ROID is assigned
>>>>>>>>> by the registry
>>>>>>>>> itself. So once
>>>>>>>>> you have a match,
>>>>>>>>> you know that you
>>>>>>>>> are looking at the
>>>>>>>>> same object, only
>>>>>>>>> the same
>>>>>>>>> object, and all
>>>>>>>>> the same object(s).
>>>>>>>>>
>>>>>>>>> Email addresses in
>>>>>>>>> particular are
>>>>>>>>> guaranteed unique
>>>>>>>>> in the world at
>>>>>>>>> any given time
>>>>>>>>> (though not
>>>>>>>>> guaranteed as
>>>>>>>>> unique identifiers
>>>>>>>>> over
>>>>>>>>> time), so they may
>>>>>>>>> be useful for
>>>>>>>>> these purposes.
>>>>>>>>> Take it from someone
>>>>>>>>> named "Andrew
>>>>>>>>> Sullivan",
>>>>>>>>> however, that
>>>>>>>>> names are pretty
>>>>>>>>> useless as
>>>>>>>>> context-free
>>>>>>>>> identifiers :)
>>>>>>>>>
>>>>>>>>> > In reality
>>>>>>>>> finding out
>>>>>>>>> answers to
>>>>>>>>> questions such as
>>>>>>>>> > yours (above)
>>>>>>>>> requires
>>>>>>>>> investigation
>>>>>>>>> using a plethora
>>>>>>>>> of data.
>>>>>>>>>
>>>>>>>>> To be clear,
>>>>>>>>> finding out the
>>>>>>>>> answer to what I
>>>>>>>>> (meant to) pose(d)
>>>>>>>>> requires no
>>>>>>>>> plethora of data:
>>>>>>>>> it requires a
>>>>>>>>> single query and
>>>>>>>>> access to
>>>>>>>>> the right
>>>>>>>>> repository (the
>>>>>>>>> registry). In
>>>>>>>>> some theoretical
>>>>>>>>> system, the
>>>>>>>>> correct underlying
>>>>>>>>> database query
>>>>>>>>> would be something
>>>>>>>>> like this:
>>>>>>>>>
>>>>>>>>> SELECT
>>>>>>>>> domain_roid,
>>>>>>>>> domain_name FROM
>>>>>>>>> domains WHERE
>>>>>>>>> registrant_roid = ?;
>>>>>>>>>
>>>>>>>>> and you put the
>>>>>>>>> correct ROID in
>>>>>>>>> where the question
>>>>>>>>> mark is, and off
>>>>>>>>> you go. That will
>>>>>>>>> give you the list
>>>>>>>>> of all the domain
>>>>>>>>> names, and
>>>>>>>>> their relevant
>>>>>>>>> ROIDs, registered
>>>>>>>>> by a given
>>>>>>>>> registrant
>>>>>>>>> contact. At
>>>>>>>>> least one registry
>>>>>>>>> with which I am
>>>>>>>>> familiar once had
>>>>>>>>> a WHOIS feature
>>>>>>>>> that allowed
>>>>>>>>> something close to
>>>>>>>>> the above, only it
>>>>>>>>> would stop after
>>>>>>>>> some number of
>>>>>>>>> domains so as not
>>>>>>>>> to return too much
>>>>>>>>> data. I think the
>>>>>>>>> default was
>>>>>>>>> therefore LIMIT
>>>>>>>>> 50, but I also
>>>>>>>>> think the feature was
>>>>>>>>> eventually
>>>>>>>>> eliminated about
>>>>>>>>> the time that the
>>>>>>>>> ICANN community
>>>>>>>>> rejected
>>>>>>>>> IRIS as an answer
>>>>>>>>> to "the whois
>>>>>>>>> problem".
>>>>>>>>>
>>>>>>>>> What the above
>>>>>>>>> will of course not
>>>>>>>>> do is help you in
>>>>>>>>> the event Bob The
>>>>>>>>> Scammer has
>>>>>>>>> created dozens of
>>>>>>>>> different contacts
>>>>>>>>> for himself by (say)
>>>>>>>>> registering names
>>>>>>>>> through many
>>>>>>>>> different
>>>>>>>>> registrars. I do
>>>>>>>>> not believe
>>>>>>>>> that any registry
>>>>>>>>> is going to
>>>>>>>>> support such a use
>>>>>>>>> at least without
>>>>>>>>> access controls,
>>>>>>>>> because it can be
>>>>>>>>> expensive to
>>>>>>>>> answer such things.
>>>>>>>>> So, what you
>>>>>>>>> understood me to
>>>>>>>>> be asking, I
>>>>>>>>> think, is the
>>>>>>>>> question I
>>>>>>>>> did _not_ ask:
>>>>>>>>> given this human
>>>>>>>>> being or
>>>>>>>>> organization, what
>>>>>>>>> other
>>>>>>>>> domains are
>>>>>>>>> registered?" That
>>>>>>>>> does require a lot
>>>>>>>>> of different data,
>>>>>>>>> and it requires
>>>>>>>>> cross-organizational
>>>>>>>>> searches, and it
>>>>>>>>> requires sussing
>>>>>>>>> out when someone
>>>>>>>>> has lied also.
>>>>>>>>> Such research is,
>>>>>>>>> I agree, completely
>>>>>>>>> outside the scope
>>>>>>>>> of what any
>>>>>>>>> technical system
>>>>>>>>> will ever be able to
>>>>>>>>> offer reliably.
>>>>>>>>>
>>>>>>>>> > An entire
>>>>>>>>> > industry exists
>>>>>>>>> for this purpose
>>>>>>>>> and I don¹t think
>>>>>>>>> we should be
>>>>>>>>> > considering
>>>>>>>>> replacing what has
>>>>>>>>> already been
>>>>>>>>> existing in the
>>>>>>>>> cyber security
>>>>>>>>> > marketplace.
>>>>>>>>>
>>>>>>>>> I do not believe
>>>>>>>>> it is this WG's
>>>>>>>>> responsibility to
>>>>>>>>> protect anyone's
>>>>>>>>> commercial
>>>>>>>>> services if those
>>>>>>>>> things are
>>>>>>>>> basically in
>>>>>>>>> response to
>>>>>>>>> deficiencies in
>>>>>>>>> the existing Whois
>>>>>>>>> protocol. In this
>>>>>>>>> case, however,
>>>>>>>>> that's not the
>>>>>>>>> problem. Linking
>>>>>>>>> data in multiple
>>>>>>>>> databases to a given
>>>>>>>>> real-world human
>>>>>>>>> being is hard even
>>>>>>>>> in systems without
>>>>>>>>> competition and
>>>>>>>>> multiple points of
>>>>>>>>> access. It's
>>>>>>>>> always going to
>>>>>>>>> require researchers
>>>>>>>>> for the domain
>>>>>>>>> name system.
>>>>>>>>>
>>>>>>>>> Best regards.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> A
>>>>>>>>>
>>>>>>>>> --
>>>>>>>>> Andrew Sullivan
>>>>>>>>> ajs at anvilwalrusden.com
>>>>>>>>> <mailto:ajs at anvilwalrusden.com>
>>>>>>>>> ______________________________
>>>>>>>>> _________________
>>>>>>>>> gnso-rds-pdp-wg
>>>>>>>>> mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/l
>>>>>>>>> istinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> --
>>>>>>>>>
>>>>>>>>> ______________________________
>>>>>>>>> ___
>>>>>>>>> Note to self: Pillage
>>>>>>>>> BEFORE burning.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> ______________________________
>>>>>>>>> _________________
>>>>>>>>> gnso-rds-pdp-wg
>>>>>>>>> mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/l
>>>>>>>>> istinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> ______________________________
>>>>>>>>> _________________
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/l
>>>>>>>>> istinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> ______________________________
>>>>>>>>> _________________
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/
>>>>>>>>> listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>>
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>>
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>> --
>>>>>>>>>
>>>>>>>>> Bei weiteren Fragen stehen wir Ihnen gerne zur
>>>>>>>>> Verfügung.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Mit freundlichen Grüßen,
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Volker A. Greimann
>>>>>>>>>
>>>>>>>>> - Rechtsabteilung -
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Key-Systems GmbH
>>>>>>>>>
>>>>>>>>> Im Oberen Werk 1
>>>>>>>>>
>>>>>>>>> 66386 St. Ingbert
>>>>>>>>>
>>>>>>>>> Tel.: +49 (0) 6894 - 9396 901
>>>>>>>>> <tel:+49%206894%209396901>
>>>>>>>>>
>>>>>>>>> Fax.: +49 (0) 6894 - 9396 851
>>>>>>>>> <tel:+49%206894%209396851>
>>>>>>>>>
>>>>>>>>> Email: vgreimann at key-systems.net
>>>>>>>>> <mailto:vgreimann at key-systems.net>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Web: www.key-systems.net
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>>>>>>>>>
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>>>>>>>>>
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>>>>>>>>>
>>>>>>>>> Geschäftsführer: Alexander Siffrin
>>>>>>>>>
>>>>>>>>> Handelsregister Nr.: HR B 18835 - Saarbruecken
>>>>>>>>>
>>>>>>>>> Umsatzsteuer ID.: DE211006534
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Member of the KEYDRIVE GROUP
>>>>>>>>>
>>>>>>>>> www.keydrive.lu <http://www.keydrive.lu>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Der Inhalt dieser Nachricht ist vertraulich und
>>>>>>>>> nur für den angegebenen Empfänger bestimmt. Jede
>>>>>>>>> Form der Kenntnisgabe, Veröffentlichung oder
>>>>>>>>> Weitergabe an Dritte durch den Empfänger ist
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>>>>>>>>>
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>>>>>>>>>
>>>>>>>>> --------------------------------------------
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Should you have any further questions, please do
>>>>>>>>> not hesitate to contact us.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Best regards,
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Volker A. Greimann
>>>>>>>>>
>>>>>>>>> - legal department -
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Key-Systems GmbH
>>>>>>>>>
>>>>>>>>> Im Oberen Werk 1
>>>>>>>>>
>>>>>>>>> 66386 St. Ingbert
>>>>>>>>>
>>>>>>>>> Tel.: +49 (0) 6894 - 9396 901
>>>>>>>>> <tel:+49%206894%209396901>
>>>>>>>>>
>>>>>>>>> Fax.: +49 (0) 6894 - 9396 851
>>>>>>>>> <tel:+49%206894%209396851>
>>>>>>>>>
>>>>>>>>> Email: vgreimann at key-systems.net
>>>>>>>>> <mailto:vgreimann at key-systems.net>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Web: www.key-systems.net
>>>>>>>>> <http://www.key-systems.net> / www.RRPproxy.net
>>>>>>>>> <http://www.RRPproxy.net>www.domaindiscount24.com
>>>>>>>>> <http://www.domaindiscount24.com> /
>>>>>>>>> www.BrandShelter.com <http://www.BrandShelter.com>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Follow us on Twitter or join our fan community on
>>>>>>>>> Facebook and stay updated:
>>>>>>>>>
>>>>>>>>> www.facebook.com/KeySystems
>>>>>>>>> <http://www.facebook.com/KeySystems>www.twitter.com/key_systems
>>>>>>>>> <http://www.twitter.com/key_systems>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> CEO: Alexander Siffrin
>>>>>>>>>
>>>>>>>>> Registration No.: HR B 18835 - Saarbruecken
>>>>>>>>>
>>>>>>>>> V.A.T. ID.: DE211006534
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> Member of the KEYDRIVE GROUP
>>>>>>>>>
>>>>>>>>> www.keydrive.lu <http://www.keydrive.lu>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> This e-mail and its attachments is intended only
>>>>>>>>> for the person to whom it is addressed.
>>>>>>>>> Furthermore it is not permitted to publish any
>>>>>>>>> content of this email. You must not use, disclose,
>>>>>>>>> copy, print or rely on this e-mail. If an
>>>>>>>>> addressing or transmission error has misdirected
>>>>>>>>> this e-mail, kindly notify the author by replying
>>>>>>>>> to this e-mail or contacting us by telephone.
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>> gnso-rds-pdp-wg mailing list gnso-rds-pdp-wg at icann.org
>>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>>
>>>>>>>>> _______________________________________________
>>>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>>>> gnso-rds-pdp-wg at icann.org <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>> _______________________________________________
>>>>>>>> gnso-rds-pdp-wg mailing list gnso-rds-pdp-wg at icann.org
>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>>>
>>>>>>>> --
>>>>>>>> _________________________________ Note to self: Pillage BEFORE
>>>>>>>> burning.
>>>>>>>> _______________________________________________ gnso-rds-pdp-wg
>>>>>>>> mailing list gnso-rds-pdp-wg at icann.org
>>>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>>
>>>>>>> _______________________________________________
>>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> --
>>>>>> Tamir Israel Staff Lawyer Samuelson-Glushko Canadian Internet
>>>>>> Policy & Public Interest Clinic (CIPPIC) University of Ottawa |
>>>>>> Faculty of Law | CML Section 57 Louis Pasteur Street Ottawa | ON
>>>>>> | K1N 6N5 ☎: (613) 562-5800 ext. 2914 Fax: (613) 562-5417 PGP
>>>>>> Key: 0x7F01E2C7
>>>>>> <https://cippic.ca/documents/keys/tisrael@cippic.ca-pub.txt> PGP
>>>>>> Fingerprint: 871C 31EC B6CC 3029 A1A1 14C4 D119 76EC 7F01 E2C7 *♺
>>>>>> Do you really need to print this email? / Est-ce nécessaire
>>>>>> d’imprimer ce courriel?*
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>
>>>>> _______________________________________________
>>>>> gnso-rds-pdp-wg mailing list
>>>>> gnso-rds-pdp-wg at icann.org
>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>> --
>>>> Tamir Israel Staff Lawyer Samuelson-Glushko Canadian Internet
>>>> Policy & Public Interest Clinic (CIPPIC) University of Ottawa |
>>>> Faculty of Law | CML Section 57 Louis Pasteur Street Ottawa | ON |
>>>> K1N 6N5 ☎: (613) 562-5800 ext. 2914 Fax: (613) 562-5417 PGP Key:
>>>> 0x7F01E2C7
>>>> <https://cippic.ca/documents/keys/tisrael@cippic.ca-pub.txt> PGP
>>>> Fingerprint: 871C 31EC B6CC 3029 A1A1 14C4 D119 76EC 7F01 E2C7 *♺
>>>> Do you really need to print this email? / Est-ce nécessaire
>>>> d’imprimer ce courriel?*
>> --
>> Tamir Israel Staff Lawyer Samuelson-Glushko Canadian Internet Policy
>> & Public Interest Clinic (CIPPIC) University of Ottawa | Faculty of
>> Law | CML Section 57 Louis Pasteur Street Ottawa | ON | K1N 6N5 ☎:
>> (613) 562-5800 ext. 2914 Fax: (613) 562-5417 PGP Key: 0x7F01E2C7
>> <https://cippic.ca/documents/keys/tisrael@cippic.ca-pub.txt> PGP
>> Fingerprint: 871C 31EC B6CC 3029 A1A1 14C4 D119 76EC 7F01 E2C7 *♺ Do
>> you really need to print this email? / Est-ce nécessaire d’imprimer
>> ce courriel?*
--
Tamir Israel Staff Lawyer Samuelson-Glushko Canadian Internet Policy &
Public Interest Clinic (CIPPIC) University of Ottawa | Faculty of Law |
CML Section 57 Louis Pasteur Street Ottawa | ON | K1N 6N5 ☎: (613)
562-5800 ext. 2914 Fax: (613) 562-5417 PGP Key: 0x7F01E2C7
<https://cippic.ca/documents/keys/tisrael@cippic.ca-pub.txt> PGP
Fingerprint: 871C 31EC B6CC 3029 A1A1 14C4 D119 76EC 7F01 E2C7 *♺ Do you
really need to print this email? / Est-ce nécessaire d’imprimer ce
courriel?*
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