[dow3tf] =?windows-874?q?Task=20Force=203=20=97=20Statement=20of=20Impass?==?windows-874?q?e?=

["Brian Darville" <BDARVILLE@xxxxxxxxx>]

Here is an alternative statement of the impasse between the parties:

Statement of Impasse

Whois Task Force 3 was initially tasked with exploring "mechanisms to
improve the quality of contact data that must be collected at the time
of registration."

In addition to researching possible means of introducing data
verification into the registration process, the Task Force was also
asked to "determine what verification mechanisms can be used cost
effectively to combat the deliberate provision of false information, and
determine whether additional mechanisms are necessary to provide
traceability of registrants, or provide for more timely responses for
misuse of domain names associated with deliberately false information."
It is this last milestone that has taken most of the attention of the
Task Force, and where the greatest degree of separation between parities
exists.

The key issues here have been articulated as concerning two points:

1) Verification at the Time of Registration and Verification Following a
Complaint

The basic disagreement in the Task Force has to do with
verification at the time of registration and verification following a
complaint about data accuracy. The Registrar's Constituency has made it
clear that they will not support the cost of new requirements or
services that will require adding resources if there is no relative
benefit to them. Benefit can be defined in a number of ways, but in this
case the Registrars hold that the Whois data reminder policy, and the
WDPRS are sufficient services for identifying and managing patently or
potentially false registrations, and that adding additional verification
requirements doesn't improve their service as Registrars, and doesn't
benefit their business.  The IPC disagrees, believing that the WDPRS
cannot be the sole venue for making Whois complaints, primarily because
it is not well publicized.  Were the WDPRS better known to users, such
as by providing links to it in Whois output, the IPC would be more
comfortable discussing it as the only means of making Whois complaints.
Otherwise, Registrars would have a free pass to ignore evidence of false
contact data arriving via other means such as by phone or email.

The IPC, BC, and ISP Constituencies see benefit in being able to
readily verify the ownership of a domain, or to verify that the
information is inaccurate, and therefore have the domain put on hold.
Both actions of verification (proof of ownership or proof of falsity)
benefit these users by enabling them to effectively deal with "bad
actors" who may be hurting their business.  As such the IPC advocates
verification at the time of registration.  The Registrars do not.  In
addition, the IPC would like at least two data elements verified
following a complaint, the Registrars would only like one data element
verified.  
	

2) The ALAC Representative framed the disagreement as one revolving
around the purpose of increasing accuracy of the Whois database.  

If the key purpose, as discussed in the Description of Work, is
to allow for greater tracking of "bad actors" associated with providing
false or inaccurate  data, then this would indicate a relatively small
number of investigations (compared to the extensive number of domain
registrations), and the concentration of resources in a manner that
would support expedited research of problem reports, and more rapid,
conclusive penalties for providing false data.

If the concern is to have the overall database be as accurate as
possible, this would indicate a more flexible, registrant-oriented
approach that allows ample time for verifying data, such as the annual
Whois data reminder policy. Keeping the Whois database as up to date as
possible overall also means allowing for the inevitable inaccuracies
that occur in any registration database, such as when people move or
change phone numbers or email addresses, and take their time in updating
non-urgent accounts.

The IPC does not believe examining the purposes for which the
Whois database is used is within the scope of Task Force 3's work.
However, if forced to choose, the IPC would choose going after bad
actors.  We believe the proposals made here in that context are a good
starting point, such as the recommendation for conclusive penalties for
providing false data.

Brian Darville