Hello All, Listed below is a complaint that I submitted to ICANN Compliance this weekend consistent with the concerns I raised on the CPWG call this past Wednesday. I will keep the community informed of any developments. <Complaint Submitted to ICANN Compliance> ICM Registry during its application to become the registry operator of the .XXX TLD made several material representations to ICANN (Org/Board/Community) as well as the broader Internet community in connection with how it would operate the .XXX TLD. Two such representations involved registry safeguards (services) designed to minimize abuse and child sexual abusive material. The first involved enhanced registrant verification to ensure that ICM knew every registrant and that they had met the registration criteria. The second involved the use of a Membership Contact ROID that was associated with each domain name registration. This feature allowed ICM Registry to quickly remove from the zone file all domain names associated with a problematic registrant upon becoming aware of a problem. As ICANN compliance is keenly aware Registry Operators are required to file a Registry Services Evaluation Process (RSEP) in connection with any new, modified, or deprecated registry service. ICANN Org has taken a very expansive definition of when a Registry Operator is required to submit an RSEP. Case in point, ICANN required fTLD to file an RSEP in connection with minor changes in how .Bank and .Insurance registrants are verified, see https://www.icann.org/en/system/files/files/rsep-2017039-bank-et-al-request-... Upon information and belief ICM Registry has changed the process by which registrants are verified and they have removed the Membership Contact ROID without submitting an RSEP which is a violation of their Registry Agreement. Additionally, any attempt by ICM Registry to deprecate these services would constitute a material deviation from the representations made by ICM Registry when securing their right to operate the .XXX TLD.