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Interisle Consulting Group's WHOIS Proxy/Privacy Reveal & Relay Feasibility Survey

Comment/Reply Periods (*) Important Information Links
Comment Open: 4 June 2012
Comment Close: 25 June 2012
Close Time (UTC): 23:59 UTC Public Comment Announcement
Reply Open: 26 June 2012 To Submit Your Comments (Forum Closed)
Reply Close: 16 July 2012; Extended to 31 July 2012 Extended to 22 August 2012 View Comments Submitted
Close Time (UTC): 23:59 UTC Report of Public Comments
Brief Overview
Originating Organization: GNSO Council – Interisle Consulting's WHOIS Proxy/Privacy Reveal & Relay Feasibility Survey
Categories/Tags: Policy Processes
Purpose (Brief): This survey, conducted by the Interisle Consulting Group in Boston, MA, USA, is intended to help the Generic Names Supporting Organization (GNSO) Council determine the feasibility of conducting an extensive analytical study ("full study") into communication Relay and identity Reveal requests sent for gTLD domain names registered using Proxy and Privacy services.
Current Status: This Public Comment solicitation represents an opportunity for the community to consider the survey results detailed in this draft report, ask questions, request clarifications, and share perspectives about the feasibility of conducting a full study into WHOIS Proxy/Privacy Reveal & Relay handling for gTLD domain names. In parallel, ICANN and Interisle will conduct a Webinar to facilitate feedback by summarizing this survey's purpose, methodology, key findings, and conclusions.
Next Steps: Interisle will consider all comments submitted to this Public Comment forum during the comment period, incorporate any needed clarifications, and then publish a final version of this WHOIS Proxy/Privacy Reveal & Relay Survey report. Afterwards, the GNSO Council will use this report as a foundation to determine whether and how to launch a full study into WHOIS Proxy/Privacy Reveal & Relay handling for gTLD domain names.
Staff Contact: Liz Gasster Email:
Detailed Information
Section I: Description, Explanation, and Purpose

At the request of the GNSO Council, ICANN engaged the Interisle Consulting Group to conduct an independent third-party WHOIS Privacy and Proxy Relay/Reveal Survey to gather, analyze, and present data that might allow the ICANN community to determine the feasibility of launching a full study and inform the design and conduct of a full study (should one be undertaken).

Specifically, this survey assessed the willingness and ability of request originators, Privacy/Proxy providers, Registrars and other interested parties to participate in and provide data to a full study, identified factors that would promote or inhibit participation in a full study, and offered individuals and organizations who might be willing to participate in a full study an opportunity to identify themselves.

This final report presents the questions posed by this multi-lingual on-line survey, responses supplied by 168 survey respondents, input obtained through follow-up interviews, and the research team's analysis, conclusions, and recommendations about concerning a possible full study.

The GNSO Council sought community review and feedback on the draft report. The purpose of the Public Comment period was to ensure that survey results were communicated clearly and to solicit feedback on the goals and nature of a full study of Relay and Reveal requests (if any) that could be feasible, given the findings provided by this survey report. The final report takes into account public comment received on the draft report.

The final report is available at:

The appendices are available at:

Section II: Background

As part of a broader effort to develop a comprehensive understanding of the gTLD WHOIS system, the GNSO Council has expressed an interest in conducting an in-depth study ("full study") that would analyze Relay and Reveal requests sent for Privacy and Proxy-registered domain names. At the GNSO's request, ICANN issued an RFP in September 2010, which detailed a full study to explore and analyze a sample of Relay and Reveal requests sent for Privacy/Proxy-registered domain names to document how they are processed and identify factors that may promote or impede timely communication and resolution. The highly diverse and distributed nature of these practices has made it difficult to assess the effectiveness of related policies. The study's stated objective was therefore to help the ICANN community better understand how communication Relay and identity Reveal requests sent for Privacy/Proxy-registered domain names are actually being handled.

To some, such a study might be highly desirable, if not essential. However, RFP responses revealed concerns about how such a study could be carried out or even if it could yield meaningful results. It was not clear what data (if any) could be made available to a study team; which entities could provide that data (and on what basis); what levels of participation would be forthcoming from key groups and other members of the community; or how to design and carry out a study so that it was likely to be successful. ICANN staff therefore recommended that a survey be conducted first, to determine the feasibility of conducting a full study. The GNSO Council authorized a survey to determine whether or not a full study would be feasible, under what conditions or limitations, and how likely it would be to obtain broad participation from Relay and Reveal initiators and responders. Results of this feasibility Survey, conducted independently by Interisle, are the subject of this draft report.

Section III: Document and Resource Links
  1. WHOIS Proxy/Privacy Reveal & Relay Feasibility Survey Final Report [PDF, 1.23 MB]
  2. WHOIS Proxy/Privacy Reveal & Relay Feasibility Survey Final Report Appendices [PDF, 2.11 MB]
  3. WHOIS Proxy/Privacy Reveal & Relay Feasibility Survey Draft Report [PDF, 2.12 MB]
  4. WHOIS Proxy/Privacy Reveal & Relay Feasibility Survey Draft Report Appendices [PDF, 1.19 MB]
  5. WHOIS Privacy/Proxy Relay & Reveal Studies RFP [PDF, 81 KB]
  6. Report to the GNSO Council on WHOIS Privacy and Proxy Relay & Reveal studies [PDF, 247 KB]
  7. gTLD WHOIS Privacy and Proxy Relay and Reveal Survey Now Live
Section IV: Additional Information
Additional WHOIS studies are now being conducted at the request of the GNSO Council, as summarized by:

(*) Comments submitted after the posted Close Date/Time are not guaranteed to be considered in any final summary, analysis, reporting, or decision-making that takes place once this period lapses.

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."