[NA-Discuss] Comments on the IRTP-B

[ebw at abenaki.wabanaki.net]

Alan,

In your comments on the recent IRTP-B draft you wrote:

> How does standardizing and clarifying WHOIS status messages relate to
> bulk transfers?

Here is the relation I derived. The utility for standard output from WHOIS,
a subject I've been involved in in one form or another since Dave Crocker
and I proposed a WHOIS-FIX BoF at IETF-53, is negligible to any consumer
of WHOIS output who is not attempting to automatically parse the output.

For a consumer of WHOIS data who does rely upon automated processing of
WHOIS data, standardizing and clarifying WHOIS status messages is critical
to the consumer's business model, in so far as that business model has a
critical dependence upon correct process of WHOIS data.

The universe of such actors who have a persistent, not occasional or
intermittant consumption of WHOIS data, for critical business processes,
is limited.

It starts with WHOIS data scrappers who harvest contact information, and
continues throught the universe of slightly unsavory characters to the
registrars, and resellers of registrars, which attempt to trigger domain
transfer in numbers sufficient to sustain their operations. The Domain
Registry of America is one such market actor with a critical reliance on
WHOIS data, including status messages. 

Had you experience as a registrar over the past decade, you would have
known that registrars have engaged in a number of techniques intended
to impede data scrapers -- rate limiting hold down timers, rate triggered
address blocking, with and without hold down timers, ... and non-standard
data formats.

Now IF there were a useful consumer protection organization, and IF that
consumer protection organization identified inter-registrar transfer as
a consumer protection interest, and IF the means of monitoring registrar
WHOIS data by the consumer protection organization were not also available
to data scraping registrar-and consumer abusing organizations, then the
policy recommendation could have benefits that outweigh costs.

Similarly, If there were a useful law enforcement organization, and IF
that law enforcement organization identified inter-registrar transfer as
a law enforcement interest, and IF the means of monitoring registrar
WHOIS data by the law enforcement organization were not also available to
data scraping registrar-and consumer abusing organizations, then the
policy recommendation could have benefits that outweigh costs. 

However, neither of these two premises appears to be true, so their
conclusions are unsupported.

Which leaves bulk transfer -- the business model based upon sustained
consumption of WHOIS data -- as the primary beneficiary of standardizing
and clarifying WHOIS status messages.

I hope this clarifies the fog you mentioned.

Eric