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CANN has once again acceded to the wants of contracted parties and is at risk of abdicating its duty to act in the global public interest when it comes to WHOIS policy. Its inability or unwillingness to date to reign in bad WHOIS policy, driven by contracted party interests, flies in the face of its previously-expressed policy goal “to ensure the continued availability of WHOIS to the greatest extent possible while maintaining the security and stability of the Internet’s system of unique identifiers.” The latest WHOIS policy outcomes should be rejected because they fail to achieve this goal, to the detriment of public safety.

This failure is evident from the latest recommendations from the “Expedited” Policy Development Process (EPDP) on WHOIS—which contain no changes to the ineffectual status quo, and do not require registries and registrars to do anything. Instead, they merely propose the development of a new WHOIS data field to flag whether a domain registrant is a natural or legal person. The flag, even if developed, would be completely voluntary to implement by registries and registrars—and they have no incentive to do so.

Unfortunately, there is no recommendation mandating a distinction between natural and legal person data in the processing of domain registration data ...

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