The idea of requiring authentication for access to the global Whois
information has some merit. However, this change should not be made
independently by each RIR but should be coordinated across the entire
Internet Registry ecosystem.

If each RIR implements such a change independently, individuals and
organizations must create an account relationship with the five RIRs to
access each RIR's portion of the total global Whois information. This seems
onerous for those with a legitimate need for access to the information and
for the RIRs, each of whom has to maintain accounts for everyone who needs
to access the totality of the global Whois information.

A less onerous solution would be for the RIRs to create an access
federation that allows access to the totality of the global Whois
information to organizations or individuals with accounts from the other
RIRs. Furthermore, this federation could be extended to NIRs, international
law enforcement agencies, or other organizations with legitimate interests
in accessing global Whois information.

The primary goal of such a change should not be to limit who has essential
access to global Whois information. But to ensure a minimal level of
accountability for those who have access to global Whois information. The
current system, with anonymous access to the global Whois information, has
a complete lack of accountability for those with access.

Thanks.

-- 
===============================================
David Farmer               Email:[email protected]
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
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