Comments

Phishing 2020: A Concentrated Dose of Badness

• Comment posted Oct 19, 2020 5:13 pm PDT — by Volker Greimann
  Thank your for this study, which made some interesting reading. Identifying abusive registrations before they can be used is certainly the ideal situation, however it is not as easy as you make it out to be. Many registrar do not…

A Failed Whois Policy

• Comment posted Sep 23, 2020 8:56 am PDT — by Volker Greimann
  I do not know, but the EPDP WG produced a final report that received mostly consensus for most of its recommendations. That does not look like failure, that looks like the process worked in producing a result that was supported…

Too Little, Too Late? Why ICANN's Proposed WHOIS Access System Isn't Worth It

• Comment posted Aug 27, 2020 12:04 pm PDT — by Volker Greimann
  It is an attempt of a compromise between the legal obligations of the parties processing the data and the needs of the parties that want access to this data. It was clear from that start that GDPR killed Whois (or…

Consistency, Urgency, and Transparency Needed for Registrant Data Requests

• Comment posted Mar 10, 2020 5:03 pm PDT — by Volker Greimann
  I do remember you had an issue that your initial requests were recognized as spam by certain third party spam protection providers and therefore did not reach us. This may or may not provide some indication on the reports you…

• Comment posted Mar 10, 2020 4:07 pm PDT — by Volker Greimann
  I appreciate your taking the time to respond. While it may be the case that you have not sent any recent requests to KS, that is ultimately irrelevant since our abuse team handles requests for many more registrar accreditations and…

• Comment posted Mar 09, 2020 7:59 pm PDT — by Volker Greimann
  the reason for APPDETEXs' low success rate could be the quality of your requests? Or the fact that APPDETEX rarely responds or follows up on our requests for further information on its requests? Or the fact that you usually send…

If ICANN Won't Stand Up to EU in WHOIS Dispute, Then the U.S. Congress Should

• Comment posted Dec 23, 2019 9:33 am PST — by Volker Greimann
  I fail to see how your responde invalidates my point. _Registrant data_ was continued to be collected even in those cases, only data that was mainly duplicate data or data of a third party the registrar had no contractual relationship…

• Comment posted Dec 20, 2019 5:08 pm PST — by Volker Greimann
  You do realize you are blatantly misrepresenting the truth when you state: "some domain registrars have started violating their contracts with ICANN by no longer collecting the required WHOIS information". Collection was never the issue, publication was. I am not…

• Comment posted Dec 20, 2019 5:06 pm PST — by Volker Greimann
  And since you quoted Facebook as a model that used whois (and keeps demanding its return), where is their public database with the real and accurate data of their users and advertisers? It sure would be helpful to see who…

• Comment posted Dec 20, 2019 5:04 pm PST — by Volker Greimann
  I am afraid I do not follow your arguments at all. How is protecting the personal, private information of our customers a bad thing? Are you saying that US congres should take a stand against basic human rights of each…

Domain Enforcement in a Post-GDPR World

• Comment posted Oct 22, 2019 9:20 am PDT — by Volker Greimann
  Can you back up that statement with data? Our abuse desk has actually seen a reduction in abuse complaints. Let's face it, there is a balance to be reached here. The rights to privacy of domain name registrants and the…

Domain Name System to Be Featured Prominently in Upcoming Review of EU Safe Harbor Rules

• Comment posted Sep 26, 2019 9:07 am PDT — by Volker Greimann
  I thought about reading that quoted article but when I looked at the price tag, I thought better. 36 EUR for 24 hour access to one article is quite rich…

The Utility Formerly Known As WHOIS

• Comment posted Sep 26, 2019 8:31 am PDT — by Volker Greimann
  This is a good outline of the status quo. We all need to work together to create a system for workable and legal disclosure that meets the requirements for legitimate requesters. To do that, we need to shed unrealistic expectations…

The End of the Road: ICANN, Whois, and Regulation

• Comment posted Sep 26, 2019 8:21 am PDT — by Volker Greimann
  You conveniently seem to ignore the progress that is being made by the EPDP that is working on just such a solution and progress would have been much faster if all sides had concentrated from the start on developing a…

New Zealand's Domain Name Commission Wins Injunction in a Lawsuit Against DomainTools

• Comment posted Sep 13, 2018 6:41 am PDT — by Volker Greimann
  "this lawsuit may cause an avalanche of litigation as a result of other registries also attempting to protect the privacy of their registrants"

ICANN's ePDP - An Insider's Perspective

• Comment posted Aug 22, 2018 8:57 am PDT — by Volker Greimann
  You are absolutely right on this: This is a do or die situation for the ICANN community. Deliver a working result or become irrelevant. Those are the options.

The Fight Is on to Save Access to WHOIS: A Call to Action for Brand Owners

• Comment posted Apr 22, 2018 6:30 pm PDT — by Volker Greimann
  At least it does in civilized countries like Italy, the United Kingdom, France, the EU, and other countries that redact whois data by default. None of these TLDs are grave security threats or havens of scum and villainy. Private information…

Why Are the EU Data Protection Authorities Taking Away Our Fundamental Right to be Safe?

• Comment posted Apr 22, 2018 6:09 pm PDT — by Volker Greimann
  Btw, this is your companys product, right? https://sspblue.com/wp-content/uploads/2010/03/Privacy-Protect-One-Pager-Final-April-17-2017.pdf To quote: „Privacy Protect is SSP Blue’s exclusive service for high net worth clients to identify and remove their personally identifiable information from online sites.“ You then go on to ennumerate the…

• Comment posted Apr 22, 2018 6:04 pm PDT — by Volker Greimann
  Losing access to whois data does not make the average internet user less safe. ccTLD whois has in many countries a long history of being hidden and those TLDs are in many cases no less safe than .com. Your examples…

The Fight Is on to Save Access to WHOIS: A Call to Action for Brand Owners

• Comment posted Apr 20, 2018 8:13 am PDT — by Volker Greimann
  In categories of circumventing the GDPR or maintaining access, you are going to have a bad time. Start thinking in categories of how to make do with what you can have. Start looking at European ccTLDs like Nominet, Denic and…

GDPR and WHOIS - Winners and Losers

• Comment posted Apr 13, 2018 2:42 pm PDT — by Volker Greimann
  Matt is absolutely right in his analysis. Sadly, the response from the DPAs has been exactly as many in the community expected: "Thank you for showing us your work so far, but it is sadly not sufficient. Please come back…

ICANN IPC & BC to Host Cross-Community Call on Accreditation/Access Model for Non-Public WHOIS Data

• Comment posted Apr 03, 2018 5:04 pm PDT — by Volker Greimann
  Whois is not what I am describing as it is public. The system I describe would only permit access to those with legitimate interests that significantly outweigh the data subjects rights or those with legal rights to access this data.…

• Comment posted Apr 03, 2018 5:00 pm PDT — by Volker Greimann
  I think you need to get more engaged with all the people at ICANN claiming to represent you, the domain name registrants. ALAC, NCSC and the others. And if you are willing to invest the time, you can also get…

ICANN Cannot Expect the DPAs to Re-Design WHOIS, but Asking for a Reprieve Makes Sense

• Comment posted Apr 03, 2018 4:57 pm PDT — by Volker Greimann
  > I also have a right to prove I own something, particularly after it is stolen. Correct, but in many real world examples this is hard to do as no register exists. >The most motivated individual will always be the…

ICANN IPC & BC to Host Cross-Community Call on Accreditation/Access Model for Non-Public WHOIS Data

• Comment posted Apr 03, 2018 4:44 pm PDT — by Volker Greimann
  Concern for registrants and the safety of their private information is paramount. In fact, our registrants will always know what data would have been put in the whois, even if it is no longer public. I also consider the ability…

ICANN Cannot Expect the DPAs to Re-Design WHOIS, but Asking for a Reprieve Makes Sense

• Comment posted Apr 03, 2018 2:53 pm PDT — by Volker Greimann
  For all of those that have relied on public records of private details the warnings have been written on the wall in large capital letters for ages. This model of doing business was destined to go away as it violates…

European Commission Killing Off Thousands of EU Domains Due to Brexit

• Comment posted Apr 03, 2018 2:19 pm PDT — by Volker Greimann
  This is nothing revolutionary new, it merely clarifies the existing and long-running eligibility policies of .EU where only European citizens and certain affiliated groups were eligible to register (and thereby hold) a domain name in the TLD. Once you cease…

ICANN IPC & BC to Host Cross-Community Call on Accreditation/Access Model for Non-Public WHOIS Data

• Comment posted Apr 03, 2018 2:14 pm PDT — by Volker Greimann
  While I understand that you have a vested interest in starting this important work as soon as possible, this is an in-opportune time to do so. While IPC and BC policy people may have significant free cycles available to explore…

GDPR: Registries to Become Technical Administrators Only?

• Comment posted Dec 12, 2017 5:25 pm PST — by Volker Greimann
  Hi Dirk, I am sure you are exaggerating when it comes to the utility of thick whois. In the past, there has been exactly one case where thick whois would have been useful to assist registrants in accessing their domains…

WHOIS: How Could I Have Been So Blind?

• Comment posted Dec 12, 2017 12:43 pm PST — by Volker Greimann
  ...of the GDPR, it is the law of the land and we will have to live with it. Surely you cannot be suggesting that contracted parties break the law. Sure, sometimes such laws have unintended consequences and sometimes they intentionally…

Eliminating Access to WHOIS - Bad for All Stakeholders

• Comment posted Dec 07, 2017 5:38 pm PST — by Volker Greimann
  Come May 25, open public whois in the shape it is today _will_ be a thing of the past as no contracted party will be willing to expose itself to the very clear and present legal risk of being the…

Sorry, Not Sorry: WHOIS Data Must Remain Public

• Comment posted May 03, 2017 9:01 am PDT — by Volker Greimann
  The problem comes when we start looking at the definition: Can anyone self-declare as "anti-abuse researcher"? Can Iranian or Syrian thought police? Can spammers? Can whois republishers? Should access be limited by jurisdictional borders, e.g. "researchers" in a certain jurisdiction…

• Comment posted Apr 28, 2017 9:35 am PDT — by Volker Greimann
  So you claim: "I work every working hour of the day to protect literally hundreds of millions of users from privacy violating spam, phish, malware, and support scams." Good for you, but have you ever stopped and though about where…

• Comment posted Apr 28, 2017 9:28 am PDT — by Volker Greimann
  You are basically saying that because there is some good coming from public whois, because it helps some private vigilantes to carry out their investigations more easily, it is absolutely fine to violate the privacy rights of millions of registrants…

.WEB is ICANN's First Test of Accountability

• Comment posted Nov 08, 2016 10:32 am PST — by Volker Greimann
  In all fairness, buying and selling of new gTLDs, backroom agreements and similar have been common practice throughout the program. Just look at: - the offer by Afilias to "buy any TLD" - the agreement between Donuts and Rightside that…

Heritage Holding Anti-IANA Transition Event With Cruz

• Comment posted Jul 08, 2016 12:29 pm PDT — by Volker Greimann
  OK, that clears up some of my misconception. I assumed US politicians were bribed paid rather well for speaking gigs to fund their private coffers political campaigns, but apparently this is not always the case. I am still concerned that…

• Comment posted Jul 08, 2016 9:37 am PDT — by Volker Greimann
  Did Cruz-control engage in the debate or piss off as soon as he received the cash for his speech?

ICANN Should Curb Anonymous Domain Name Abuses

• Comment posted Aug 13, 2015 2:58 pm PDT — by Volker Greimann
  As you represent a lobbyist organization, your motives are rather opaque, so you may want to clear whose interests you actually represent. Discussion with someone who is paid for his opinion by undisclosed backers is rather pointless. When you refer…

• Comment posted Aug 13, 2015 8:41 am PDT — by Volker Greimann
  Where can I find a full disclosure of who pays for your foundation? Also, I find it funny that lobbying organizations should be held to a different standard as private citizens who happen to operate a little shop on their…

A Confession About The ICANN WHOIS Data Reminder Policy

• Comment posted Jul 03, 2015 2:09 pm PDT — by Volker Greimann
  I doubt it would be slam dunk. There are enough forces at play that oppose any reduction in whois obligations that would make this effort very tough to complete.

Should Barclays Lose the .Barclays Top-Level Domain?

• Comment posted Jun 08, 2015 9:13 am PDT — by Volker Greimann
  If I read it correctly, the RA reads that it must be an officer or board member that is convicted. There is no provision for the conviction of the organization itself. So that may be the "out" used in this…

The .DOCTOR Quarantine

• Comment posted Mar 16, 2015 4:05 pm PDT — by Volker Greimann
  You are looking at this in a very US-centric view, I assume. When I mean a medical doctor, I say "Arzt", not doctor. When I say doctor, I could mean all kinds of things, depending on the circumstances. You are…

• Comment posted Mar 16, 2015 3:48 pm PDT — by Volker Greimann
  John, that may be the case where you are, but over here, holders of Doctorates are usually fiercely proud of their titles. They are even officially considered to be part of your name, regardless of the kind of doctorate you…

• Comment posted Mar 16, 2015 10:23 am PDT — by Volker Greimann
  And to answer your rethoric question: Yes, all of those are real, legally qualified doctors. Just not of the particular field that ICANN felt needed to be singled out for "protection".

• Comment posted Mar 16, 2015 10:21 am PDT — by Volker Greimann
  Constantine, yes I am, at least when the definition is as limited as in this case. Not all doctors are of the medical persuasion, in fact those make up only a fraction of people holding a doctorate. To quote Wikipedia:…

• Comment posted Mar 14, 2015 9:13 am PDT — by Volker Greimann
  The question is not so much if certain TLDs may need more regulation than others, the question is why this one, and why restrict it so that other legitimate doctors are excluded from its use? You may hold any position…

• Comment posted Mar 13, 2015 4:55 pm PDT — by Volker Greimann
  I fully agree with the author that this decision sets a very bad example and is unnecessarily restrictive. This decision should be scrapped as soon as possible.

Section 3.18 of the 2013 RAA: Reasonable Investigations, Appropriate Responses

• Comment posted Dec 10, 2014 2:29 pm PST — by Volker Greimann
  Having worked with John and his organization, I feel it is safe to say that they are the senders of the most organized and most useful complaints, always ready to supply additional evidence and discuss with us how to improve…

Is the ICANN New gTLD Program a Draft for a V2 of the Internet?

• Comment posted Dec 02, 2014 3:22 pm PST — by Volker Greimann
  Do not quote Mummy (Mrs. Merkels nom de guerre) on anything related to the net. She has absolutely no clue whatsoever. The internet is newland, i.e. an undiscovered country, to her. Her speech is what you get when politicians dabble…

• Comment posted Dec 02, 2014 9:33 am PST — by Volker Greimann
  If you want censorship and fragmentation of the internet, by all means try to split up the root. If you prefer a unified and free'ish internet for all, with information flowing uninterrupted around the globe, you need a unified root.…

• Comment posted Dec 01, 2014 11:11 am PST — by Volker Greimann
  While there may be many roots already, there is only one official root and a few minor roots almost no-one uses. Segmentation is the first step to blocking and many regimes have already expressed their interest in this precisely because…

• Comment posted Dec 01, 2014 10:45 am PST — by Volker Greimann
  government-controlled DNS is one of the worst ideas of recent years. It will only lead to segmentation or fracturing of the internet on national or political borders and destroy the one common internet for all. By proposing it, you are…

Big Brands Trying to Corner Generic Domain Namespaces?

• Comment posted Jun 15, 2012 9:35 am PDT — by Volker Greimann
  That is my reading as well. You can also leave a comment that may be igno..., err, taken into account by the evaluators: https://gtldcomment.icann.org/comments-feedback/applicationcomment/login

• Comment posted Jun 15, 2012 8:27 am PDT — by Volker Greimann
  Indeed it is worrying that big brands are trying to corner the market for generic terms for their exclusive use. Most people in favor of the new program envisioned a new DNS of choice and a multitude of namespaces open…

2100 New gTLD Applications. What Does It Mean?

• Comment posted May 08, 2012 8:40 am PDT — by Volker Greimann
  I interpret the language the same way, however I do believe there will be no difference in fact from the result Anthony is suggesting. Contending strings will be preferred and more likely to end up in the first batch, as…

Who is Keeping TAS Down?

• Comment posted Apr 30, 2012 12:31 pm PDT — by Volker Greimann
  Well, it does not look like the window will reopen anytime soon: http://domainincite.com/beckstrom-breaks-tas-bug-silence-says-big-reveal-could-be-as-late-as-prague/ That is a possible reveal at least two months behind schedule, and they are not even willing to commit to that.

Fake Bank Site, Fake Registrar

• Comment posted Mar 29, 2012 5:01 pm PDT — by Volker Greimann
  Where can I sign a petition for that? ;-) This has been a request of many registrars for a long time.

• Comment posted Mar 28, 2012 4:19 pm PDT — by Volker Greimann
  ... is ICANN's problem. But seriously: While I agree that it is not helpful that ICANN omits half the WHOIS data, that data is not required for the complainant to check if his complaint is correct as his complaint is…

Port 43 Failures Continue to Haunt

• Comment posted Mar 20, 2012 5:13 pm PDT — by Volker Greimann
  Not sure if I follow you here. You are saying a stalking victim can either no longer own a domain name, or should be prepared to meet their stalker fearlessly? You are saying a dissident should fearlessly face the shooting…

• Comment posted Mar 20, 2012 2:27 pm PDT — by Volker Greimann
  I disagree with your arguments on whois privacy. Privacy functions serve a useful and beneficial purpose for registrants with a variety of legitimate interest of not having their private and personal information publicly available to any nutjob. Just as any…

• Comment posted Mar 09, 2012 10:17 am PST — by Volker Greimann
  All of this could also be solved by moving the last thin registry to a thick whois model. Once there are no longer any thin whois registries, the need for registrars to provide a secondary whois service beside that of…

Most Abusive Domain Registrations are Preventable

• Comment posted Mar 07, 2012 9:10 am PST — by Volker Greimann
  Usually not. CC payments are handled through a payment service provider, we do not have access to the data and resellers get paid directly by their customers so we do not see the individual payments or customer data either. I…

• Comment posted Feb 20, 2012 3:33 pm PST — by Volker Greimann
  Not all barriers that can be implemented actually make sense, especially if they overly inconvenience "normal" registrants. Not everything that _can_ be done _should_ be done. Additionally, any change to registration procedures needs to have a substantial effect. Cosmetic changes…

• Comment posted Feb 20, 2012 1:09 pm PST — by Volker Greimann
  The point remains however that in all likelyhood and checking of the whois data will not reduce the amount of crime on the internet. True, additional verification will increase the accuracy of the data of the legitimate registrants, but criminals…

• Comment posted Feb 17, 2012 2:20 pm PST — by Volker Greimann
  While I cannot divulge any details at this time to avoid derailing the current talks by breaking the confidentiality agreed with ICANN, I can disclose that email confirmation is one part of the proposal the registrars made. I read you…

• Comment posted Feb 17, 2012 9:30 am PST — by Volker Greimann
  Email verification is pretty much a done deal already. The ongoing negotiations between ICANN staff and registrars are pointing in the direction of required email verification on a registrant-level in the upcoming new version of the RAA.

Beyond Words: Diverse Voices at ICANN and Miscommunications

• Comment posted Dec 08, 2011 11:57 am PST — by Volker Greimann
  To update this topic to the current state of affairs: After Dakar, ICANN and the Registrar Stakeholder Group have opened a round of negotiations to amend the RAA to incorporate the majority of the recommendations into the next version of…

ANA Moves Campaign Against New gTLDs to YouTube, Accuses ICANN of Lying

• Comment posted Dec 01, 2011 5:03 pm PST — by Volker Greimann
  Armchair quarterbacking, thats all this is. They were too cheap or too lazy to engage with the ICANN community during the long, long, long process during which this program was developed, and now, once everything is finally done and a…

Bringing Order to The World's Cybrary: New TLDs Make Sense to Organize the Chaos of the Internet

• Comment posted Oct 14, 2011 9:47 am PDT — by Volker Greimann
  Very true. In a way, the internet is going to become more chaotic again, like in the beginning of the web. But is that a bad thing? Some TLDs will thrive, some will crash and burn. And that is a…

• Comment posted Oct 14, 2011 9:26 am PDT — by Volker Greimann
  There are hundreds of applicants willing to bet hundreds of thousands of dollars on the success of their proposed strings. Would they do so if they shared your view? Probably not. Be aware that success does not mean surpassing .com…

• Comment posted Oct 13, 2011 11:33 am PDT — by Volker Greimann
  The introduction of previous TLDs was too slow and too limited. They serve a small niche, but due to their restrictive models, they failed to gain a wider appeal or visibility. Other TLDs like .cat and .info have filled their…

• Comment posted Oct 12, 2011 3:50 pm PDT — by Volker Greimann
  The new gTLD program is nothing less than a revolution of the way the internet is going to be used in the future. As flawed or as imperfect as the process may be perceived, it was the result of almost…

War of Words - the gTLD Weaponry

• Comment posted Aug 22, 2011 4:47 pm PDT — by Volker Greimann
  One further factor may also very well be the fear of many brands to be left behind in the new program and therefore seeking to derail the program in its entirety. This may especially be true for brands that have…

Some Considerations for New TLD Operators from a Registrar Perspective

• Comment posted Jun 14, 2011 11:38 am PDT — by Volker Greimann
  First of all, thank you Michele for an excellent post. You raise a number of very valid points that all aspiring registry operators should take to heart. Let me chime in from another registrars view: The success of many new…

The Facts about Vertical Integration?

• Comment posted Nov 08, 2010 5:19 pm PST — by Volker Greimann
  But the board already has changed policy: In the Nairobi board decision that became the basis for the VI language included in DAG4 the ICANN board boldy went and changed current policy. This can and should be removed from the…

A Case for Limited New TLD Flavors

• Comment posted Sep 23, 2010 4:43 pm PDT — by Volker Greimann
  Anyone should have the choice to try a new business model that he has confidence in. Of course most new TLDs will not perform like dotCOM, many will be comparable more to dotPRO, dotCAT or dotMUSEUM. So what? We are…

New TLD Vertical Integration, Market Forces and the Path of Least Compliance

• Comment posted Sep 22, 2010 2:10 pm PDT — by Volker Greimann
  Ron, I remember our talks from Brussels very well, and if I remember correctly, the main reason for you to favor vertical separation in the new gTLD market was your perception of ICANN being unable to monitor and enforce compliance…

Precrime Regulation of Internet Innovation

• Comment posted Sep 21, 2010 9:16 am PDT — by Volker Greimann
  This also applies to other areas of current discussion on the future of the internet, such as the debate on the topic of the Vertical Integration of Registries and Registrars in the field of new gTLDs. While many favor a…

Putting String Similarity into Context: Bulgaria's IDN (.бг) vs. Brazil's ccTLD (.br)

• Comment posted Aug 17, 2010 12:25 pm PDT — by Volker Greimann
  The author is correct in assuming ICANN should review the terms "confusingly similar" based on the way it will be used, to be more precise, in the way it may be abused. Having a new IDN TLD look similar to…

Who Is Blocking WHOIS? Part 2

• Comment posted Jul 02, 2010 5:23 pm PDT — by Volker Greimann
  Garth, we have been working with them already, however we understand they are a private lobbyist organization not sponsored or duly authorized by any official government agency. Maybe thats a European worldview, but we view such unsponsored lobbyist organizations with…

• Comment posted Jul 02, 2010 5:08 pm PDT — by Volker Greimann
  Dear Garth, please realize one thing. We register thousands of domain names on a daily basis. These domains are registered by criminals, through different resellers all the time. The majority of registered domain names are legitimate and it is impossible…

• Comment posted Jul 02, 2010 4:50 pm PDT — by Volker Greimann
  Garth, we are aware of the problem with the illicit pharmacy domain names and are shutting these domain names down by the dozens every week, usually on the very same day we receive a substantiated complaint. However, you are "trying…

• Comment posted Jul 02, 2010 2:45 pm PDT — by Volker Greimann
  We have read your recent report with interest and appreciate your efforts to strengthen Internet security in general and contractual compliance of registrars specifically. We were however amazed to find our own name among those registrars listed as being in…