Input to Expert Working Group on gTLD Directory Services Thoughts on EWG Next Gen

[Danny Pryor]

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.

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.

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.

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.

There is also a need for extreme transparency on an issue of this
magnitude, and it seems *every single domain owner on the planet should
have received a notice of the EWG's work*, 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
http://mm.icann.org/pipermail/input-to-ewg/2013/000021.html.

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.

Respectfully submitted,

Danny Pryor, President

*Rodan Media Group*
www.rodanmedia.com
dtp at rodanmedia.net

PO Box 30136
Fort Lauderdale, FL
33303

T | 954-561-0600
F | 954-333-6345
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