<div dir="ltr"><div style>At this time, I agree there is a need to open some aspects of WHOIS search to greater transparency, such as the ability to perform better historical WHOIS searches, and there is a need to put authoritative records under a central authority, as proposed with the ARDS. However, I am concerned about the cost of this undertaking and the specific reasons that instigated the need to consider such a vast proposal.</div>
<div style><br></div><div style>It would be imperative that the basic WHOIS search remain completely free of any charge, and that only nominal fees be imposed for more extensive searches, which could be achieved if a single authoritative repository were maintained. However, I would propose each registry operator also maintain an authoritative internal WHOIS database, which they may charge non-clients for use. <br>
</div><div style><br></div><div style>The proposed solutions, themselves, may have intellectual merit, but what processes will the implementation of these proposals seek to correct, improve, assuage or eliminate? It is unclear why there is a need to perform such a comprehensive overhaul. In fact, while many specific solutions are proposed, in great detail, the issues these solutions address are hardly identified well. </div>
<div style><br></div><div style>Further, while I completely support the notion of doing what can be done to thwart the activities of "black hat" users, which are identified in the report as "miscreants", this report does little to identify precisely what problems these rogue individuals are causing that supports the proposed fixes. </div>
<div style><br></div><div style>There is also a need for extreme transparency on an issue of this magnitude, and it seems <i>every single domain owner on the planet should have received a notice of the EWG's work</i>, and that a proper time to request comments would have been a time of year when people are not vacationing in greater numbers. I am forced to agree with the comments of Mr. George Kirikos, who wrote about his transparency concerns in the comments found at <a href="http://mm.icann.org/pipermail/input-to-ewg/2013/000021.html">http://mm.icann.org/pipermail/input-to-ewg/2013/000021.html</a>.</div>
<div style><br></div><div style>I do praise the decision to extend the comment period beyond the original date of August 12; however, I have grave concerns that individual domain owners and registrants were never notified of this process, neither by the registry operators nor by ICANN, itself.</div>
<div style><br></div><div style>Respectfully submitted,</div><br clear="all"><div><div dir="ltr">Danny Pryor, President<div><font size="1"><br></font></div><div><font><b>Rodan Media Group</b></font></div><div><font><a href="http://www.rodanmedia.com" target="_blank">www.rodanmedia.com</a></font></div>
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