Introduction

Note that Network Solutions has a long history of supporting whois abuse: see this Letter from Louis Touton to Bruce Beckwith Regarding Breach of VeriSign Registrar's Accreditation Agreement (Whois Data Accuracy).

One Example

I did a quick whois to find out what it said about forensicguard.com. Something really odd there: the administrative contact email address was xr8249n64uy@networksolutionsprivateregistration.com. I called Network Solutions Customer Service, and they verified that they started providing a private registration service about a week ago. I expressed my concern to the Network Solutions representative, who suggested that I email Network Solutions.

So, I did. Network Solutions responded that "deleting a domain name will rarely stop spaming activities." Whose side are they on?

I've had exasperating series of email exchanges with Network Solutions Customer Service, including responses from them that had nothing to do with the problem. And one response that says that they've given up on this issue. Well, I haven't, so I finally spoke with a supervisor who said that it will be escalated.

Update as of late 8 January 2004: After nearly a week, some progress: forensicguard.com is no longer a private registrant. Their (alleged) contact information is now available through whois. The domain is still valid; so, they had little to lose by spamming. Network Solutions still provides them with their domain name, DNS, and hosting service.

How Network Solutions Encourages Spammers

1. Network Solutions doesn't think that shutting down spammer's domains will stop them.

2. Spammers have nothing to lose by violating Network Solutions' Acceptable Use Policy. Network Solutions still provides services to forensicguard.com, even after that registrant spams.

3. Network Solutions recently set up a private registration facility, and provided the networksolutionsprivateregistration.com domain for their registrants to hide behind. That includes spammers, of course.
   • The Network Solutions private registration facility intentionally denies delivery of First Class mail:

       3rd Class and Bulk mail will remain unopened and will be
       destroyed upon receipt; all other mail will remain unopened
       and will be returned to sender.
     

     To respond to spammers with hard copy, I must pay for premium (USPS® Certified Mail™ or Express Mail® only) mail delivery service! Spam is virtually free to the spammers, but Network Solutions forces recipients to pay to mail them! Even more ridiculous: Network Solution scans the hard copy and emails it to the spammer, then destroys my hard copy.

   • The Network Solutions private registration facility intentionally provides a phone number that is not that of the registrant, and that serves no useful purpose:

       Phone Number - Your phone number listing displayed in
       WHOIS will be answered by an answering service that
       instructs the caller how to contact you via the e-mail
       address and/or postal address listed in WHOIS.
     

     Though the phone number that they list is not an answering service and does not instruct the caller as described. Instead, it is a voicemail system.

4. Always ask for a ticket number when speaking on the phone with Network Solutions Customer Service.

5. Network Solutions Customer Service appears to cycle through canned responses. They offered me some that had absolutely nothing to do with the issue at hand. In one conversation on the phone, the representative assured me that Network Solutions was "researching the issue", after 1) she told me that she could find no record of it, and 2) I informed her that I had received a response from Network Solutions stating that they unable to assist me further.

Is Private Registration a Good Idea?

However, as currently implemented by Network Solutions, their private registration assists spammers.

Here's how: currently, inaccurate whois information is one reliable way to shut down a spammer. The way things work now, in practice, whois information need not initially be accurate. ICANN even acknowledges this in their Registrar Advisory Concerning Whois Data Accuracy of 10 May 2002:

Although 3.7.8 envisions that ICANN may develop a policy requiring registrars to verify the contact details at the time of registration, ICANN has not yet done so.

So what good is whois? If anyone reports an inaccuracy to the registrar, it must take reasonable steps to correct, according to Section 3.7.8 of the ICANN Registrar Accreditation Agreement:

3.7.8 Registrar shall, upon notification by any person of an inaccuracy in the contact information associated with a Registered Name sponsored by Registrar, take reasonable steps to investigate that claimed inaccuracy. In the event Registrar learns of inaccurate contact information associated with a Registered Name it sponsors, it shall take reasonable steps to correct that inaccuracy.

3.7.7.2 A Registered Name Holder's willful provision of inaccurate or unreliable information, its willful failure promptly to update information provided to Registrar, or its failure to respond for over fifteen calendar days to inquiries by Registrar concerning the accuracy of contact details associated with the Registered Name Holder's registration shall constitute a material breach of the Registered Name Holder-registrar contract and be a basis for cancellation of the Registered Name registration.

How Can I Help?

(To find out if a domain belongs to a Network Solutions private registrant, perform a simple whois search. If the email address of the Administrative Contact is at networksolutionsprivateregistration.com, then they are.)

Please let ICANN and Network Solutions know how you feel about Network Solutions' implementation of private registration.

Legislative Assistance?