The last time I checked there are some big loop holes that allows anyone
to legally mine WHOIS.  ICANN says you can only restrict bulk e-mailing to
WHOIS contacts.  Tele-marketing and postal mail *are* actually
allowed.  And, if you don't use automated processes to request the WHOIS
data you are in compliance there as well.

> I guess I have to ask then...do you really think they don't use the zone
> files to mine whois?

> Zone files won't help you with the particulars. You would still need to get
> the whois information. Doing it on your own for commercial purposes would be
> whois mining and could open you up to legal ramifications. Of course, IANAL.

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