Hi Steven,

Even when this assertion is relevant, it may not be persuasive, for a number of reasons.  For example, the Whois data reminder obligation applies to the registrant of record.  In the case of a proxy service, the registrant or record is the service, not its customer.  If a Whois data reminder is sent to a non-proxy registrant and bounces back, then the RAA requires the registrar to re-verify.  But a data reminder sent to a proxy service will almost never bounce back, and therefore there may be no RAA obligation to re-verify.   This is so even if the customer data provided to the service is inaccurate or outdated.   In this circumstance it is up to the p/p service accreditation standards to specify the conditions under which customer data must be re-verified.


This depends on how the service is set up. One could suggest that if such required messages from the registrar do not reach the registrant, it could become the providers' obligation to perform the information requirements on its own. The registrar could then rely on the provider to perform its duties under the accreditation agreement with ICANN just at it performs its own obligations under the RAA.

Please also remember that the registrars obligation only extends to the registrant of record, not to anyone who may use the domain name with permission of that registrant.

V.