Dear TPR WG members, Thank you for your patience while ICANN’s Contractual Compliance team reviewed your follow-up inquiry and prepared their response. The attached report is in response to the WG’s request for context behind Compliance’s complaint volumes, specifically, the numbers pertaining to unauthorized inter-registrar transfers, unauthorized COR complaints, and the volume of complaints determined by Compliance to be valid and subsequently addressed with registrars. Holida Yanik has provided the attached report as well as the below explanation, and she will be available for questions during our next TPR WG call (30 January at 16 UTC). Please review this email and attached report prior to our upcoming call on Tuesday. Thank you. Kind regards, Christian, Caitlin, Berry and Julie On 29 August 2020, ICANN Contractual Compliance migrated to a new case processing platform, the Naming Services portal for Compliance (NSp Compliance). NSp Compliance includes “smart forms” tailored for individual complaint types, which capture additional reporting criteria for each complaint type, including subject matter category (e.g. Unauthorized Transfer and/or Unauthorized COR). Categories of complaints in NSp are selected by complainants while submitting the complaint. This means that these numbers are taking into account what the complainants reported to us while submitting the complaints. Page 1: 1. During the period covering Sept 2020-Oct 2023 period (since transition to NSp), ICANN compliance received in total 13.630 of Transfer complaints. The number of transfer complaints received during Sept 2020-July 2021 period was severely impacted by an influx of complaints concerning failing registrar with more than 100k domains under registration, which has since been terminated (you can view Notice of Termination here<https://www.icann.org/uploads/compliance_notice/attachment/1155/hedlund-to-b...> and find ICANN’s announcement regarding the invocation of De-Accredited Registrar Transition Procedure (DARTP) here<https://www.icann.org/en/announcements/details/net-4-india-registrants-next-...>). 2. During this period, ICANN Compliance closed 12.497 complaints as invalid (without initiating a case with the contracted party) and addressed 1.353 complaints with Contracted Parties (CP). Note: The number of complaints received may not align with the number of closed complaints within the same time periods. Discrepancy may arise because complaints may undergo processing and closure in subsequent periods. Page 2: From Sept 2020 through Oct 2023, ICANN Compliance: 1. received 988 complaints for which complainants selected the categories “Unauthorized Inter-Registrar Transfer” and “Unauthorized COR”. 2. closed 679 Unauthorized Inter-Registrar Transfer complaints as invalid and addressed with CPs 88 complaints. 3. closed 169 Unauthorized COR complaints as invalid and addressed with 42 complaints. Page 3: Out of 81 closed complaints under complaint categories related to improperly allowed transfers despite of 60-Day COR Lock, URS, UDRP, TDRP, Court Order, 80 complaints were closed as invalid and 1 complaint was addressed with CP. Page 4: Out of 2435 closed complaints with complaint categories related to denied COR (Other, COR Not Authorized, Domain Expired, Court Order, and UDRP, URS or TDRP Proceedings),2316 complaints were closed as invalid and 119 complaints were addressed with CPs. Page 5: Out of 10,670 closed complaints with complaint categories related to denied Inter-registrar Transfer (Other, 60-day COR Lock, 60-day Lock After Creation or Transfer, Evidence of Fraud, Registrant Identity Dispute, Transfer Contact Objection, Nonpayment of Registration Period, Court Order, and UDRP, URS or TDRP Proceedings), 9649 complaints were closed as invalid, while 1021 complaints were sent to CPs. Page 6: Out of 157 closed complaints where complainants selected the TEAC category, 151 complaints were closed as invalid, while 6 complaints were validated and sent to CPs. Page 7: ICANN Contractual closed 12.497 transfer complaints as invalid (without initiating a case with the contracted party). The table shows the number of complaints closed as invalid by closure codes. Page 8: ICANN Compliance closed 1.572 Contracted Party cases. The table shows the number of closed CP cases by closure codes.