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As Kabul falls, Whois could present a danger to ordinary Afghans

Kevin Murphy, August 19, 2021, Domain Policy

With Afghanistan falling to the Taliban this week, there’s potential danger to .af registrants — both in terms of losing domain services and of Whois being used for possibly deadly reprisals.

At time of writing, it’s been four days since the fall of Kabul. The uneasy truce between NATO and Taliban forces has failed to prevent scenes of chaos at the city’s main airport and the PR machine of so-called “Taliban 2.0” is in full bluster.

The new Taliban is, its spokespeople suggest, more tolerant of western liberal values and more supportive of human rights than its brutal, pre-9/11 incarnation.

Few believe this spin, and there have been multiple reports of 1990s-style oppression, including revenge killings and the suppression of women’s rights, across the country.

With all that in mind, a blog post about .af domain names may seem trivial, but it’s not my intention to trivialize.

I’m as appalled as any right-minded observer by the situation on the ground in Afghanistan and the neglect that led to it. But I believe .af could prove a learning moment in the ongoing conversation about Whois privacy.

The .af ccTLD has been managed since not long after the US-led invasion by the country’s Ministry of Communications and IT as the Afghanistan Network Information Center.

The registry had previously been managed for free from London by NetNames, with an admin contact in Kabul, according to the report of the 2003 IANA redelegation, which happened at a time when Afghanistan was still under a transitional government heavily overseen by the foreign governments behind the invasion.

Domain policy for .af was created in 2002, and it includes provisions for an open, freely available Whois database that is still in effect today.

Domains registered via overseas registrars appear to be benefiting from the impact of the EU’s General Data Protection Regulation, which redacts personal information, but this obviously does not apply in Afghanistan.

This means the names, addresses, phone numbers and email addresses of .af registrants are available for querying via various Whois interfaces, including the registry’s own, which is managed by New Zealand-based back-end CoCCA.

Using a combination of web searches and Whois queries, it is possible to find personally identifiable information of registrants, including names and addresses, at local human rights groups, as well as local news media and technology providers supportive of human rights causes.

If the reports of Taliban fighters conducting house-to-house searches for enemies of the new state are accurate, the easy availability of this personal data could be a serious problem.

To a great extent, this could be a case study in what privacy advocates within the ICANN community are always warning about — public access to Whois data gives oppressive regimes a tool to target their oppression.

And as we have seen this week, oppressive regimes can appear almost literally overnight.

While it seems unlikely there’s anyone from the old Afghan ministry still in control of the registry, I think .af back-end provider CoCCA, as well as Whois aggregators such as DomainTools, should have a long think about whether it’s a good idea to continue to provide open access to .af Whois records at this time.

Fortunately, there doesn’t appear to be a great many .af domains under management. DomainTools reckons it’s under 7,000.

At the other end of the scale of seriousness, overseas .af registrants may also see issues with their names due to the Taliban takeover.

It seems incredible today, but in 2001 a Taliban decree restricted internet access to a single computer at a government ministry. Others in government could apply to use this computer by sending a fax to the relevant minister.

While it seems impossible that such a Draconian restriction could be reintroduced today, it still seems likely that the Taliban will crack down on internet usage to an extent, including introducing morality or residency restrictions to .af regs.

.af is currently open to registrants from anywhere in the world, with no complex restrictions and .com-competitive prices.

Many multinational corporations have registered .af names for their local presence.

The string “af” has in recent years become social media shorthand for “as fuck”, and a small number overseas registrants appear to be using it as a domain hack in that context — type “corrupt.af” into your browser and see what happens.

Others seem to be using .af, where short domains are still available, as shortcuts to their social media profiles.

I don’t believe ICANN will need to get directly involved in this situation. Its Whois query tool does not support .af, and IANA presumably won’t need to get involved in terms of redelegation any more than it would following a general election or a coup d’état.

After 20 years, DomainTools takes its first VC dough

Kevin Murphy, December 3, 2020, Domain Tech

DomainTools has taken a “significant” investment from a venture capital firm, the first outside funding its received in its 20-year history.

The amount of the investment is undisclosed, but DomainTools said its investor is Battery Ventures.

Battery already owns stakes in numerous software and technology companies, but this appears to be its first foray into the domain name space.

Its principal, Jordan Welu, and partner Dave Tabors will join DomainTools’ board of directors and Andy Rothery, a Battery “executive-in-residence”, will become its executive chairman.

DomainTools said in a press release:

This investment will drive more rapid innovation in DomainTools’ platform capabilities for machine learning-based threat analytics and predictive risk scoring, along with enhanced product development around automating threat intelligence and incident response workflows.

The company is all about the “threat intelligence” nowadays, no doubt partly due to the fact that its original mission of aggregating the world’s Whois data will become decreasingly useful in light of privacy laws such as GDPR.

As a private company its financial position is unknown, but I’ll note that it did take a big chunk of change out of the US taxpayers’ pocket earlier this year under a government coronavirus-related corporate-relief program.

As it releases free download, DomainTools says 68,000 dangerous coronavirus domains have been registered

Kevin Murphy, March 26, 2020, Domain Services

More than 68,000 coronavirus-related domain names have been registered so far in 2020, according to data released by DomainTools today.

The domain intelligence services company has started publishing a list of these domains, updated daily, for free on its web site. You have to submit your email address to get it.

The download comprises a CSV file with three columns: domain, reg date, and Domain Risk Score.

This final field is based on DomainTools’ in-house algorithms that estimate how likely domains are likely to be used in nefarious activities, based on criteria including the domain’s connection to other, known-bad domains.

Only domains with a score of 70 or above out of 100 — indicating they will likely be used for activities such as phishing, malware or spam — will be included on the list, the company said.

The list will be updated daily at 0000 UTC.

You can find out more and obtain today’s list here.

Beginning of the end for DomainTools? Court orders it to scrub Whois records

Kevin Murphy, September 13, 2018, Domain Registries

DomainTools has been temporarily banned from collecting and publishing the Whois records of all .nz domains.
A Washington court yesterday handed down a preliminary injunction against the company, after New Zealand’s Domain Name Commission sued it in July for scraping and republishing its Whois in violation of its terms of service.
Notably — especially if you’re involved in the ongoing Whois reform debate — Judge Robert Lasnik’s scathing order (pdf) rubbished DomainTools’ claims that its historical Whois service provides a public interest benefit that outweighs the privacy interests of .nz registrants.
The ruling by its own admission also potentially opens the floodgates for other registries and registrars to obtain injunctions against DomainTools for the own customers.
DomainTools has been “enjoined from accessing the .nz register while DomainTools’ limited license remains revoked and/or publishing any .nz register data DomainTools had stored or compiled in its own databases”.
DNC, the policy body that oversees .nz registry InternetNZ, had alleged that DomainTools had created a “secondary or shadow register” by bulk-downloading Whois records.
Since mid-2016, each .nz Whois record has contained a notice that such behavior is prohibited, and Lasnik agreed that DomainTools must surely have been aware of this.
Lasnik further agreed with DNC that DomainTools’ service is “sabotaging” its efforts to bring more privacy protection to .nz customers; since November last year it has offered individuals the ability to opt out of having their private data published, an offer 23,000 people have taken up.
That was enough for the judge to conclude that DNC’s case had met the “irreparable harm” test required for an injunction.
He was less impressed with DomainTools’ argument that implementing the injunction would take many months and cost it up to $3.5 million.
“Defendant can presumably filter the .nz data using relatively simple database tools,” he wrote, ordering DNC to post a “nominal” $1,000 bond to cover DT’s potential losses.
Lasnik also said the public interest would be better served by permitting registrant privacy than by serving the interests of DomainTools’ cybsecurity and law enforcement customers:

defendant argues that the products it creates from its meticulously collected register data are critical cybersecurity resources and that the public interest would be harmed if the reports provided to government, financial, and law enforcement entities were incomplete because the .nz data were excised. The .nz register is comparatively small, however (approximately 710,000 domains compared with over 135,000,000 .com domains), and the defendant and its customers can access the registration information directly through plaintiff’s website if it appears that a bad actor is using an .nz domain. On the other hand, the .nz registrants’ privacy and security interests are compromised as long as defendant is publishing non-current or historical .nz information out of its database. The Court finds that the public has an interest in the issuance of an injunction.

While arguably limited to historical Whois records, it’s a rare example of judicial commentary on the privacy rights of registrants and may well play into the ongoing debate about Whois in the post-GDPR world.
Even if it turns out not to have wider policy implications, the legal implications for DomainTools are potentially devastating.
While .nz has only about 710,000 domains under management, and is but one of over 1,500 TLDs, DomainTools, DNC and Judge Lasnik all seem to agree that the floodgates for further litigation may have now opened. Lasnik wrote:

defendant argues that a preliminary injunction in this case could start an avalanche of litigation as other registers attempt to protect the privacy of their registrants. If defendant built a business by downloading, storing, and using data from other registers in violation of the terms that governed its access to that data, defendant may be correct — other registers may be encouraged to pursue a breach of contract claim if plaintiff is successful here. It would be ironic, however, if a plaintiff who has shown a likelihood of success and irreparable injury were deprived of preliminary relief simply because defendant may have acted wrongfully toward others as well

DNC said in a statement: “Managers of other countries domain name systems across the world will want to pay attention to the judgment. This may raise confidence to fight their own cases should DomainTools be breaching their terms of use.”
The case has yet to go to court, but the fact that DNC won the injunction indicates that the judge believes it has a likelihood of winning.

Empty Whois a threat to the US elections?

Kevin Murphy, September 5, 2018, Domain Policy

Could a lack of Whois records thwart the fight against attempts to interfere in this year’s US elections?
That’s the threat raised by DomainTools CEO Tim Chen in a blog post, and others, this week.
Chen points to recent research by Facebook, based on an investigation by security company FireEye, that linked a large network of bogus news sites and social media accounts to the Iranian state media.
FireEye’s investigation used “historical Whois records”, presumably provided by DomainTools, to connect the dots between various domains and registrants associated with “Liberty Front Press”, a purportedly independent media organization and prolific social media user.
Facebook subsequently found that 652 accounts, pages and groups associated with the network, and removed them from its platform.
The accounts and sites in question were several years old but had been focusing primarily on politics in the UK and US since last year, Facebook said.
Based on screenshots shared by Facebook, the accounts had been used to spread political messages bashing US president Donald Trump and supporting the UK’s staunchly pro-Palestinian opposition leader Jeremy Corbyn.
Google’s research, also inspired by FireEye’s findings and Whois data, linked the network to the state-run Islamic Republic of Iran Broadcasting.
The actions by Google and Facebook come as part of their crackdown on fake news ahead of the US mid-term Congressional elections, this November, which are are largely being seen as a referendum on the Trump presidency.
Because the domains in question predate the General Data Protection Regulation and ICANN’s response to it, DomainTools was able to capture Whois records before they went dark in May.
While the records often use bogus data, registrant email addresses common to multiple domains could be used to establish common ownership.
Historical Whois data for domains registered after May 2018 is not available, which will likely degrade the utility of DomainTools’ service over time.
Chen concluded his blog post, which appeared to be written partly in response to data suggesting that GDPR has not led to a growth in spam, with this:

Domain name Whois data isn’t going to solve the world’s cyberattack problems all on its own, but these investigations, centering on an issue of global importance that threatens our very democracy, likely get severely impaired without it. And this is just the tip of the iceberg, a few uniquely important investigations among the hundreds of thousands of cyberattacks going on all day every day all over the globe by people and organizations that can now hide behind the anonymity inherent in today’s internet. It’s reasonable that domain names used for certain commercial or functional purposes should require transparent registration information. Whois is not a crime.

DomainTools is one of the founders of the new Coalition for a Secure and Transparent Internet, a lobby group devoted to encouraging legislatures to keep Whois open.
Representatives of Facebook and Iran’s government are among the members of the Expedited Policy Development Process on Whois, an emergency ICANN working group that is currently trying to write a permanent GDPR-compliant Whois policy for ICANN.

DomainTools tracks its one billionth domain

Kevin Murphy, August 10, 2018, Domain Services

DomainTools now has records of over a billion domain names in its database, according to the company.
The billionth name was added last month, according to a blog post.
The company notes that there are only about 350 million domains in existence today, meaning that twice as many domains have been deleted and never re-registered as are currently online.
For .com, DomainTools knows of 434 million domains that no longer exist, compared to the over 130 million registered today.
Even DomainTools, which has been collecting data for 17 years, knows its records are incomplete, but it reckons its number is probably within 10% of the total number of domains ever registered.
For new gTLDs, the one with the most deleted names is .realty (97% deleted) and the best is .boston (0.3% deleted), the company said.
More data here.

Tech giants gunning for AlpNames over new gTLD “abuse”

A small group of large technology companies including Microsoft and Facebook have demanded that ICANN Compliance take a closer look at AlpNames, the budget registrar regularly singled out as a spammers’ favorite.
The ad hoc coalition, calling itself the Independent Compliance Working Party, wrote to ICANN last week to ask why the organization is not making better use of statistical data to bring compliance actions against the small number of companies that see the most abuse.
AlpNames, the Gibraltar-based registrar under common ownership with new gTLD portfolio registry Famous Four Media, is specifically singled out in the group’s letter.
The letter, sourcing the August 2017 Statistical Analysis of DNS Abuse in gTLDs (pdf), says there “is a clear problem with one particular contracted party”.
AlpNames was the registrar behind over half of the new gTLD domains blacklisted by SpamHaus over the study period, for example, the letter states.
The tiny territory of Gibraltar also frequently ranks unusually highly on abuse lists due to AlpNames presence there, the letter and report say.
The ICWP letter also says that the four gTLDs .win, .loan, .top, and .link were used by over three quarters of abusive domains over the SADAG study period.
The letter calls the abuse rates “troublesome” and says:

We are alarmed at the levels of DNS abuse among a few contracted parties, and would appreciate further information about how ICANN Compliance is using available data to proactively address the abusive activity amongst this subset of contracted parties in order to improve the situation before it further deteriorates.

It goes on to wonder whether high levels of unaddressed abuse could amount to violations of new gTLD Registry Agreements and Registrar Accreditation Agreements, and to ask whether there any barriers to ICANN Compliance pursuing breach claims against such potential violations.
The ICWP comprises Adobe, DomainTools, eBay, Facebook, Microsoft and Time Warner. It’s represented by Fabricio Vayra of Perkins Coie.
Other than the letter (pdf), the Independent Compliance Working Party does not appear to have any web presence, and a spokesperson has not yet responded to DI’s request for more information.
The SADAG report also singled out Chinese registrar Nanjing Imperiosus Technology Co, aka DomainersChoice.com, as having particularly egregious levels of abuse, but noted that this abuse disappeared after ICANN terminated its RAA last year.
AlpNames has not to date had any public breach notices issued against it, but this is certainly not the first time it’s been singled out for public censure.
In November last year, ICANN’s Competition, Consumer Trust, and Consumer Choice Review Team (CCT) named it in a report that claimed: “Certain registries and registrars appear to either positively encourage or at the very least willfully ignore DNS abuse.”
AlpNames seems to have been used often by abusers due to its bargain-basement, often sub-$1 prices — making disposable domains more cost effective — and its tool that allowed up to 2,000 domains to be registered simultaneously.
If not actively soliciting abusive behavior, these factors certainly don’t make abuse any more difficult.
But will ICANN Compliance take action in response to the criticism leveled by CCT and now ICWP?
The main problem with the ICWP letter, and the SADAG report it is based upon, is that the data it uses is now rather old.
The SADAG report sourced abuse databases only up to January 2017, a time when AlpNames’ total gTLD domains under management was at its peak of around three million names.
Since then, the company has been hemorrhaging DUM, losing hundreds of thousands of domains every month. At the end of November 2017, the most recent data compiled by DI shows that it was down to around 838,000 domains.
It’s quite possible that AlpNames’ customer base is no longer the den of abuse it once was, whether due to natural attrition or a proactive purge of bad actors.
A month ago, in a press release connected with a $5.4 million buy-out of an co-founder, AlpNames chairman Iain Roache said he has a “10-year strategic plan” to turn AlpNames into a “Tier-1” registrar and “bring the competition to the incumbents”.

DomainTools scraps apps and APIs in war on spam

Kevin Murphy, January 22, 2018, Domain Services

DomainTools is to scrap at least five of its services as it tries to crack down spam.
It’s getting rids of its mobile apps, its APIs, and is to stop showing registrants’ personal information to unauthenticated users.
CEO Tim Chen told us in an email at the weekend:

The Android app is no longer supported.
The iOS app will no longer be supported after February 20th.
The Developer API is no longer supported.
On February 20th, the Bulk Parsed Whois tool available to Personal Members will no longer be supported.
On February 20th, our production Whois API will no longer be available to individual membership levels, an Enterprise relationships will be required.

It’s all part of an effort to make sure DomainTools services are not being abused by spammers, which has lead to a dispute with GoDaddy over bulk access to its registrants’ Whois data.
The longstanding problem of new registrants getting spammed with calls and emails offering web hosting and such has escalated over the last few years. Domain Name Wire detailed the scale of the abuse registrants can experience in a post last week.
While to my knowledge nobody has directly accused DomainTools of facilitating such abuse, the scrapped services are the ones that would be most useful to these spammers.
The company is also going to scale back what guest users can see when they do a Whois lookup, and is to make automated scraping of Whois records more difficult for paying members.
In a blog post, Chen wrote last week:

As of today, unauthenticated users of the DomainTools Whois Lookup tool will not see personally identifiable information for the registrant parsed out in the results, and will be required to submit a CAPTCHA to see the full raw domain name Whois record. Phone numbers in the parsed results have been replaced with image files, much the same way emails have always been rendered

As well as hoping to ease relations with GoDaddy — the source of a very heavy chunk of DomainTools’ data — the moves are also part of the company’s strategy for dealing with the incoming General Data Protection Regulation.
This is the EU law that gives registrants more control over the privacy of their personal data.
Chen told us earlier this month that DomainTools is keen to ensure its enterprise-level suite of security products, which he said are vital for security and intellectual property investigations, continue to operatie under the new regime.
About 80% of DomainTools’ revenue comes from its enterprise-level customers, over 500 companies.

GoDaddy and DomainTools scrap over Whois access

Kevin Murphy, January 12, 2018, Domain Registrars

GoDaddy has seriously limited DomainTools’ access to its customers’ Whois records, pissing off DomainTools.
DomainTools CEO Tim Chen this week complained to DI that its access to Whois has been throttled back significantly in recent months, making it very difficult to keep its massive database of domain information up to date.
Chen said that DomainTools is currently only able to access GoDaddy’s Whois over port 43 at about 2% of the rate it had previously.
He said that this has been going on for about six months and that the market-leading registrar has been unresponsive to its requests to have previous levels restored.
“By throttling access to the data by 98% they’re defeating the ability of security practitioners to get data on GoDaddy domains,” Chen said. “It’s particularly troublesome because they [GoDaddy] are such a big part of DNS.”
“We have customers who say the quality of GoDaddy data is just degrading across the board, either through direct look-ups or in some of the DomainTools products themselves,” he said.
DomainTools customers include security professionals trying to hunt down the source of attacks and intellectual property interests trying to locate pirates and cybersquatters.
GoDaddy today confirmed to DI that it has been throttling DomainTools’ Whois access, and said that it’s part of ongoing anti-spam measures.
In recent years there’s been an increase in the amount of spam — usually related to web design, hosting, and SEO — sent to recent domain registrants using email addresses harvested from new Whois records.
GoDaddy, as the market-share leader in retail domain sales, takes a tonne of flak from customers who, unaware of standard Whois practice, think the company is selling their personal information to spammers.
This kind of Twitter exchange is fairly common on GoDaddy’s feed:


While GoDaddy is not saying that DomainTools is directly responsible for this kind of activity, throttling its port 43 traffic is one way the company is trying to counter the problem, VP of policy James Bladel told DI tonight.
“Companies like [DomainTools] present a challenge,” he said. “While we may know these folks, we don’t know who their customers are.”
But that’s just a part of the issue. GoDaddy was also concerned about the amount of resources DomainTools was consuming, and its own future legal responsibilities under the European Union’s forthcoming General Data Protection Regulation.
“When [Chen] says they’re down to a fraction or a percentage of what they had previously, well what they had previously was they were updating and archiving Whois almost in real time,” Bladel said. “And that’s not going to fly.”
“That is not only, we feel, not congruent with our responsibilities to our customers’ data, but it’s also, later on down the road, exactly the kind of thing that GDPR and other regulations are designed to stop,” he said.
GDPR is the EU law that, when it fully kicks in in May, gives European citizens much more rights over the sharing and processing of their private data.
Bladel added that DomainTools is still getting more Whois access than other parties using port 43.
“They have a level of access that is much, much higher than what they would normally have as a registrar,” he said, “but much lower than I think they want, because they want to effectively download and keep current the entirety of the Whois database.”
I’m not getting a sense from GoDaddy that it’s likely to backtrack on its changes.
Indeed, the company also today announced that it from January 25 it will start to “mask” key elements of Whois records when queried over port 43.
GoDaddy told high-value customers such as domainers today that port 43 queries will no longer return the registrant’s first name, last name, email address or phone number.
Bulk Whois users such as registrars (and, I assume, DomainTools) that have been white-listed via the “GoDaddy Port43 Process” will continue to receive full records.
Its web-based Whois, which includes a CAPTCHA gateway to prevent scraping, will continue to function as normal.
Bladel said that these changes are NOT related to GDPR, nor to the fact that ICANN said a couple months back that it would not enforce compliance with Whois provisions of the Registrar Accreditation Agreement, subject to certain conditions.

Big changes at DomainTools as privacy law looms

Kevin Murphy, January 11, 2018, Domain Services

Regular users of DomainTools should expect significant changes to their service, possibly unwelcome, as the impact of incoming European Union privacy law begins to be felt.
Professional users such as domain investors are most likely to be impacted by the changes.
The company hopes to announce how its services will be rejiggered to comply with the General Data Protection Regulation in the next few weeks, probably in February, but CEO Tim Chen spoke to DI yesterday in general terms about the law’s possible impact.
“There will be changes to the levels of service we offer currently, especially to any users of DomainTools that are not enterprises,” Chen said.
GDPR governs how personal data on EU citizens is captured, shared and processed. It deals with issues such as customer consent, the length of time such data may be stored, and the purposes for which it may be processed.
Given that DomainTools’ entire business model is based on capturing domain registrants’ contact information without their explicit consent, then storing, processing and sharing that data indefinitely, it doesn’t take a genius to work out that the new law represents a possibly existential threat.
But while Chen says he’s “very concerned” about GDPR, he expects the use cases of his enterprise customers to be protected.
DomainTools no longer considers itself a Whois company, Chen said, it’s a security services company now. Only about 20% of its revenue now comes from the $99-a-month customers who pay to access services such as reverse Whois and historical Whois queries.
The rest comes from the 500-odd enterprise customers it has, which use the company’s data for purposes such as tracking down network abuse and intellectual property theft.
DomainTools is very much aligned here with the governments and IP lawyers that are pressing ICANN and European data protection authorities to come up with a way Whois data can still be made available for these “legitimate purposes”.
“We’re very focused on our most-important goal of making sure the cyber security and network security use cases for Whois data are represented in the final discussions on how this legislation is really going to land,” he said.
“There needs to be some level of access that is retained for uses that are very consistent with protecting the very constituents that this legislation is trying to protect from a privacy perspective,” he said.
The two big issues pressing on Chen’s mind from a GDPR perspective are the ability of the company to continue to aggregate Whois records from hundreds of TLDs and thousands of registrars, and its ability to continue to provide historical, archived Whois records — the company’s most-popular product after vanilla Whois..
These are both critical for customers responding to security issues or trying to hunt down serial cybersquatters and copyright infringers, Chen said.
“[Customers are] very concerned, because their ability to use this data as part of their incident response is critical, and the removal of the data from that process really does injure their ability to do their jobs,” he said.
How far these use cases will be protected under GDPR is still an open question, one largely to be determined by European DPAs, and DomainTools, like ICANN the rest of the domain industry, is still largely in discussion mode.
“Part of what we need to help DPAs understand is: how long is long enough?” Chen said. “Answering how long this data can be archived is very important.”
ICANN was recently advised by its lawyers to take its case for maintaining Whois in as recognizable form as possible to the DPAs and other European privacy bodies.
And governments, via the Governmental Advisory Committee, recently urged ICANN to continue to permit Whois access for “legitimate purposes”.
DomainTools is in a different position to most of the rest of the industry. In terms of its core service, it’s not a contracted party with ICANN, so perhaps will have to rely on hoping whatever the registries and registrars work out will also apply to its own offerings.
It’s also different in that it has no direct customer relationship with the registrants whose data it processes, nor does it have a contractual relationship with the companies that do have these customer relationships.
This could make the issue of consent — the right of registrant to have a say in how their data is processed and when it is deleted — tricky.
“We’re not in a position to get consent from domain owners to do what we do,” Chen said. “I think where we need to be more thoughtful is whether DomainTools needs to have a process where people can opt out of having their data processed.”
“When I think about consent, it’s not on the way in, because we just don’t have a way to do that, it’s allowing a way out… a mechanism where people can object to their data being processed,” he said.
How DomainTools’ non-enterprise customers and users will be affected should become clear when the company outlines its plans in the coming weeks.
But Chen suggested that most casual users should not see too much impact.
“The ability of anyone who has an interest in using Whois data, who needs it every now and then, for looking up a Whois record of a domain because they want to buy it as a domain investor for example, that should still be very possible after GDPR,” he said.
“I don’t think GDPR is aimed at individual, one-at-a-time use cases for data, I think it’s aimed at scalable abuse of the data for bad purposes,” he said.
“If you’re running a business in domain names and you need to get Whois at significant scale, and you need to evaluate that many domains for some reason, that’s where the impact may be,” he said.
Disclosure: I share a complimentary DomainTools account with several other domain industry bloggers.