Input to Expert Working Group on gTLD Directory Services ICANN working group proposal regarding WHOIS

Di Giorgio Domenico D.DiGiorgio at
Thu Sep 5 15:04:27 UTC 2013

Dear Sirs,

I am writing you as Director of the Anti-Counterfeiting Unit of the Italian Medicines Agency, a regulatory governmental body who strongly cooperates with the U.S. firm LegitScript in counteracting the illegal distribution of counterfeit medicines through the Internet.

We believe that the WG proposal is very problematic and could have extremely negative implications for agencies like AIFA, and firms like LegitScript, that rely on open access to WHOIS records in order to determine who operates rogue e-pharmacies.

Overall, we feel like this is a dangerous proposed policy that gives one organization a monopoly over a very important set of data (WHOIS records) and allows them to determine who has access, and at what level.

For instance, if ARDS came to be, it is possible that they would tell AIFA that you can no longer access WHOIS records at all, or can only view a limited portion of the records.

It will create serious problems in our activities, aimed at tackling a serious threat to public health, the distribution of counterfeit medicines through the Internet.

Internet was born free and open since it was an instrument to share knowledge.

Today, Internet is still a carrier of information but the sharing part is somewhat misused (or so believed by some organizations and governments) and hence all the attempts, more or less effective, to control information sharing across the Internet.

The Domain Name System (DNS) is a key infrastructure of the Internet.

In the past, attempts were made to control the access to and the administration of this essential service.

Today we have a system which is not perfect but is fit: a shared service, with public data.

It's very important to the inner working of the Internet that these data are public because any host connected to the Internet use them.

Some of these data, those regarding the people behind an Internet host, have a special value.

They are shared through the WHOIS protocol, the white pages of the Internet.

Reducing their accessibility could create an obstacle to our activities in protecting public health.

The most valued argument by companies advocating a controlled access to WHOIS data is privacy.

The "privacy option" is already offered as a premium service to domain name registrants.

Share the knowledge.

If everybody has access to the same knowledge, everybody has the same power.

Nobody needs to control this power.

We are lucky, that's exactly what we have today: everybody has access to WHOIS data.

Privacy isn't an argument since the Internet has today a way to hide personal data for who concerns.

We cannot risk that privacy becomes a tool for the ones threatening public health.

Thank you for your attention

Domenico Di Giorgio


Domenico Di Giorgio, Ph. D.
Director of Counterfeit Prevention Unit
AIFA - Italian Medicines Agency

Via del Tritone, 181 - 00187 Roma
Tel. +39.(0)6.5978.4356 - Fax +39.(0)6.5978.4496

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