December 2010 - NA-Discuss - lists.icann.org

Milton Mueller: Networks and States: The Global Politics of Internet Governance – NYU 12/14
by Joly MacFie Dec. 8, 2010

Dec. 8, 2010

The Internet Society's New York Chapter (ISOC-NY) is delighted to present Milton Mueller’s first full exposition of his new book Networks and States: The Global Politics of Internet Governance at NYU on Tuesday December 14 2010. Prof. Mueller is a co-founder of ICANN’s NonCommercial User’s Constituency and a renowned cyberlibertarian. His 2002 book Ruling the Roothas long been the definitive work on governance. We are excited to hear details of what, in his mind, has changed in the last 8 years. This event is open to the public and will be webcast live. What: Networks and States: The Global Politics of Internet Governance When: Tuesday December 14 2010 : 7-9pm Where: Rm 317, Warren Weaver Hall NYU, 251 Mercer St NYC (& W. 4 St) Who: Public welcome. No RSVP needed. Photo ID required. Webcast: http://www.livestream.com/isocny Hashtag: #isocny Facebook: http://www.facebook.com/event.php?eid=175907139093951 URL: http://www.isoc-ny.org/p2/?p=1592 Book: http://mitpress.mit.edu/catalog/item/default.asp?ttype=2&tid=12265 Milton Mueller is a professor at the School of Information Studies at Syracuse University, where he teaches courses on information and communication policy and telecommunication management.He is also XS4All Professor at Delft University of Technology, the Netherlands His research focuses on property rights, institutions and global governance in communication and information industries. Currently, he is doing research on the legal and regulatory responsibilities of Internet service providers, Internet Protocol addressing policy, the policy implications of Deep Packet Inspection technology and the security governance practices of network operators. Mueller was one of the founders of the Internet Governance Project, an alliance of scholars in action around global Internet policy issues. As co-founder of the Noncommercial Users Constituency, he has played a leading role in organizing and mobilizing public interest groups in ICANN. Mueller is on the Advisory Council of Public Interest Registry (.org). -- --------------------------------------------------------------- Joly MacFie 218 565 9365 Skype:punkcast Secretary - ISOC-NY - http://isoc-ny.org ---------------------------------------------------------------

1 0

Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows
by Garth Bruen at KnujOn Dec. 7, 2010

Dec. 7, 2010

THANK YOU! > -------- Original Message -------- > Subject: RE: [NA-Discuss] Two Years later, Dozens of Registrars Still > in the Shadows > From: ICANN At-Large Staff <staff(a)atlarge.icann.org> > Date: Tue, December 07, 2010 3:26 pm > To: <gbruen(a)knujon.com> > Cc: Carlton Samuels <carlton.samuels(a)gmail.com>, > <na-discuss(a)atlarge-lists.icann.org>, Helen <helen(a)dotalliance.com>, > ICANN At-Large Staff <staff(a)atlarge.icann.org> > > > Hi Garth, > > > > Compliance staff have sent the following information on DotAlliance: > > > > ** > > According to our records, DotAlliance is an ICANN-accredited registrar. See > below: > > > > DotAlliance Inc. > > Registrar IANA ID > > 1249 > > Registrar Corporation Type > > Canada Corporation > > RAA Version > > 2009 > > Accreditation Date > > 2009-07-01 > > Accreditation Expiration Date > > 2014-06-30 > > URL > > www.dotalliance.com > <https://connect.icann.org/,DanaInfo=www.dotalliance.com+> > > > > It appears that they only have their email addresses posted on their website > but not postal address so they are deemed non-compliant. > > > > ** > > > > Regards, > > Heidi Ullrich, Matthias Langenegger, Seth Greene, Gisella Gruber-White, > Marilyn Vernon, > > ICANN At-Large Staff > > > > From: gbruen(a)knujon.com [mailto:gbruen@knujon.com] > Sent: Tuesday, December 07, 2010 5:50 AM > To: Helen; ICANN At-Large Staff > Cc: Carlton Samuels; na-discuss(a)atlarge-lists.icann.org > Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the > Shadows > > > > Hi Helen, > > > > We're jumping from one problem to another. According to ICANN, you are a > Registrar: http://www.internic.net/registrars/registrar-1249.html > > > > I think ICANN staff needs to clarify this immediately. > > > > Which Registrar are you a reseller for if you are reseller? > > > > -Garth > > > > > > > > From: Helen <mailto:helen@dotalliance.com> > > Sent: Tuesday, December 07, 2010 4:24 AM > > To: gbruen(a)knujon.com > > Cc: Michele Neylon :: Blacknight <mailto:michele@blacknight.ie> ; Carlton > Samuels <mailto:carlton.samuels@gmail.com> > > Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the > Shadows > > > > Hi Garth! > As a reseller we've never felt the address needs to be on the front page in > flashing neon lights. > But we have had the address on our website for years.. I believe from the > start! > In addition, all resellers do need to sign the registrant agreement so they > must look at it. > http://dotalliance.com/registrationagree.html#definitions > I will ask someone to look at putting it on the contact page if this is so > distressing, however we are not nor have ever been in breach with the RAA. > > I wish I was able be in Columbia to see everyone, unfortunately an illness > in the family prevents this or even much of a peep out of me for a while. > Just remember ...someone owes me a beer in Frisco! :) > > > > Best, Helen > www.DotAlliance.com > > > On 06/12/2010 5:30 AM, gbruen(a)knujon.com wrote: > > I checked into the claims by Michele (or maybe I should address you as > "Blacknight"?) and my suspicions were confirmed. He has completely distorted > > the issues and ignored the critical problem. Active Registrar, Compana, > Directi, DOTALLIANCE, EVERYONES INTERNET, NICCO, RESELLER SERVICES, UK2 > GROUP, VOLUSION, YNOT DOMAINS, and OWN IDENTITY have not corrected the > problem as cited since June and ICANN compliance has not addressed the > issue. You've glossed over this. > > You've also glossed over the fact that OnLineNIC was allowed to sign on to > the 2009 RAA without first complying and has not been held to comply since, > even through we were informed they would be held to the RAA after signing. > > In our original report we expressed our concern the the other Registrars > would also be allowed to re-sign without meeting this requirement, and why > should they have to when it's not enforced? Why would they opt for public > disclosure when their competitors are not held by any standard? Does this > not concern you? > > The RAA has become meaningless and the Internet user DESERVERS BETTER. > > If you purport to be a leader in this community you'll expect better too. > > > > > -------------------------------------------------- > From: "Michele Neylon :: Blacknight" <mailto:michele@blacknight.ie> > <michele(a)blacknight.ie> > Sent: Sunday, December 05, 2010 8:31 PM > To: "Carlton Samuels" <mailto:carlton.samuels@gmail.com> > <carlton.samuels(a)gmail.com> > Cc: <mailto:na-discuss@atlarge-lists.icann.org> > <na-discuss(a)atlarge-lists.icann.org> > Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the > > Shadows > > > I checked into the claims by Knujon and my suspicions were confirmed. > Of the registrars supposedly in breach 50% are NOT on the 2009 RAA. They > are, therefore, NOT in breach, so I wonder how long we will have to wait > for a corrected / updated version of this report > > Regards > > Michele > > Mr. Michele Neylon > Blacknight > http://Blacknight.tel > > Via iPhone so excuse typos and brevity > > On 4 Dec 2010, at 23:14, "Carlton Samuels" > <mailto:carlton.samuels@gmail.com> <carlton.samuels(a)gmail.com> > wrote: > > > Garth: > I commend you and KnuJon for keeping at this issue. It is one thing to > be > the slacker in a contract. But the fact that ICANN fails to embrace its > duty of care to the community in ensuring that contracted parties live up > to > the terms and condition of contract remains scandalous. > > The low hanging fruit of an explanation would be ignorance of its > commitment. But reason and good judgment suggests that this would be a > stretch for explanation. Time enough for ICANN to rise to the occasion > and > do its duty. > > Carlton > [Chair, At-Large WHOIS WG] > > ============================== > Carlton A Samuels > Mobile: 876-818-1799 > Strategy, Planning, Governance, Assessment & Turnaround > ============================= > > > > > 1. Two Years Later Dozens of Registrars Still in the Shadows > (Garth Bruen at KnujOn) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Fri, 03 Dec 2010 11:49:35 -0700 > From: "Garth Bruen at KnujOn" <mailto:gbruen@knujon.com> > <gbruen(a)knujon.com> > Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in > the Shadows > To: na-discuss(a)atlarge-lists.icann.org > > Folks, > > In June of 2008 KnujOn reported that 70 Registrars did not have a > business address listed in the InterNIC Registrar Directory. Only after > reporting a month later that little had changed did ICANN perform a mass > update of the directory. On further inspection we found many of the > newly disclosed addresses were phantom locations, false addresses, and > PO boxes. This lead to a push to amend the RAA and require Registrar > location disclosure and resulted in RAA 3.16: "Registrar shall provide > on its web site its accurate contact details including a valid email and > mailing address." However, policy without policy enforcement is useless. > So far ICANN compliance has failed to enforce this rule even after being > provided with extensive evidence in June, 2010. In fact, several > Registrars cited five months ago for not posting their address have been > allowed to renew their accreditation without complying. > > The following Registrars still do not disclose their address on their > website as required in RAA 3.16 and are in continued violation: Active > Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com) > Directi Internet Solutions Pvt. (publicdomainregistry.com) DOTALLIANCE > INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) NICCO > LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 GROUP > LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS CORP > (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN > (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA > VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. > (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) ONLINENIC > INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN IDENTITY > INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES > TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) WEBAIR > INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) > NAMEHOUSE, INC. (namehouse.net) The good news is that most of the 400 > plus unique Registrars clearly provide their address in the home page > footer, a CONTACT US, or ABOUT US link and several Registrars cited in > June have since done so. Some Registrars bury the address in legal > documents, while we do not consider this compliant ICANN provides no > clear direction on where the address should be posted. > > OnLineNIC is particularly troubling since their purported public > location is an empty lot in California with their true location being in > China, but only privately disclosed to ICANN. OnLineNIC's own domain > registration has been cited multiple times by KnujOn as being false. > > Additionally, KnujOn has discovered that nine Registrars have > non-functional contact email addresses posted in the InterNIC directory: > RU-CENTER, Best Bulk Register (also has a breach notice for failure to > pay fees), Dynamic Network Services, Europe Domains, Homestead Limited, > HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo Online. > Details of the email failures along with other results will be published > in our supplemental report on Monday December 6th. > > RAA 3.16 is not the only unenforced contract obligation. In fact, most > of the RAA is unenforced with the exception being the Cardinal Sin of > failing to pay ICANN fees. KnujOn will actually detail an unprecedented > case in which a Registrar termination was reversed after back fees were > paid. > > While Registrars control the content of their websites, ICANN really is > to blame for the failure to enforce the RAA and the anti-transparent > practice of having one Registrar directory for public consumption with > bad information and another internal list for their use. > > > Full article: > > http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars_ > still_in_the_shadows/ > > -Garth > > ------------------------------------- > Garth Bruen > gbruen(a)knujon.com > http://www.knujon.com > http://www.linkedin.com/pub/4/149/724 > Linkedin Group: http://www.linkedin.com/groups?gid=1870205 > Blog: http://www.circleid.com/members/3296/ > Twitter: @Knujon > Shop: http://www.cafepress.com/knujon > Bookstore: http://astore.amazon.com/knujocom-20 > > > > > > ------ > NA-Discuss mailing list > NA-Discuss(a)atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > Visit the NARALO online at http://www.naralo.org > ------ > > ------ > NA-Discuss mailing list > NA-Discuss(a)atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > Visit the NARALO online at http://www.naralo.org > ------ > > > ------ > NA-Discuss mailing list > NA-Discuss(a)atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > Visit the NARALO online at http://www.naralo.org > ------

1 0

Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows
by gbruen＠knujon.com Dec. 7, 2010

Dec. 7, 2010

Hi Helen, We're jumping from one problem to another. According to ICANN, you are a Registrar: http://www.internic.net/registrars/registrar-1249.html I think ICANN staff needs to clarify this immediately. Which Registrar are you a reseller for if you are reseller? -Garth From: Helen Sent: Tuesday, December 07, 2010 4:24 AM To: gbruen(a)knujon.com Cc: Michele Neylon :: Blacknight ; Carlton Samuels Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows Hi Garth! As a reseller we've never felt the address needs to be on the front page in flashing neon lights. But we have had the address on our website for years.. I believe from the start! In addition, all resellers do need to sign the registrant agreement so they must look at it. http://dotalliance.com/registrationagree.html#definitions I will ask someone to look at putting it on the contact page if this is so distressing, however we are not nor have ever been in breach with the RAA. I wish I was able be in Columbia to see everyone, unfortunately an illness in the family prevents this or even much of a peep out of me for a while. Just remember ...someone owes me a beer in Frisco! :) Best, Helen www.DotAlliance.com On 06/12/2010 5:30 AM, gbruen(a)knujon.com wrote: I checked into the claims by Michele (or maybe I should address you as "Blacknight"?) and my suspicions were confirmed. He has completely distorted the issues and ignored the critical problem. Active Registrar, Compana, Directi, DOTALLIANCE, EVERYONES INTERNET, NICCO, RESELLER SERVICES, UK2 GROUP, VOLUSION, YNOT DOMAINS, and OWN IDENTITY have not corrected the problem as cited since June and ICANN compliance has not addressed the issue. You've glossed over this. You've also glossed over the fact that OnLineNIC was allowed to sign on to the 2009 RAA without first complying and has not been held to comply since, even through we were informed they would be held to the RAA after signing. In our original report we expressed our concern the the other Registrars would also be allowed to re-sign without meeting this requirement, and why should they have to when it's not enforced? Why would they opt for public disclosure when their competitors are not held by any standard? Does this not concern you? The RAA has become meaningless and the Internet user DESERVERS BETTER. If you purport to be a leader in this community you'll expect better too. -------------------------------------------------- From: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie> Sent: Sunday, December 05, 2010 8:31 PM To: "Carlton Samuels" <carlton.samuels(a)gmail.com> Cc: <na-discuss(a)atlarge-lists.icann.org> Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows I checked into the claims by Knujon and my suspicions were confirmed. Of the registrars supposedly in breach 50% are NOT on the 2009 RAA. They are, therefore, NOT in breach, so I wonder how long we will have to wait for a corrected / updated version of this report Regards Michele Mr. Michele Neylon Blacknight http://Blacknight.tel Via iPhone so excuse typos and brevity On 4 Dec 2010, at 23:14, "Carlton Samuels" <carlton.samuels(a)gmail.com> wrote: Garth: I commend you and KnuJon for keeping at this issue. It is one thing to be the slacker in a contract. But the fact that ICANN fails to embrace its duty of care to the community in ensuring that contracted parties live up to the terms and condition of contract remains scandalous. The low hanging fruit of an explanation would be ignorance of its commitment. But reason and good judgment suggests that this would be a stretch for explanation. Time enough for ICANN to rise to the occasion and do its duty. Carlton [Chair, At-Large WHOIS WG] ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Planning, Governance, Assessment & Turnaround ============================= 1. Two Years Later Dozens of Registrars Still in the Shadows (Garth Bruen at KnujOn) ---------------------------------------------------------------------- Message: 1 Date: Fri, 03 Dec 2010 11:49:35 -0700 From: "Garth Bruen at KnujOn" <gbruen(a)knujon.com> Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in the Shadows To: na-discuss(a)atlarge-lists.icann.org Folks, In June of 2008 KnujOn reported that 70 Registrars did not have a business address listed in the InterNIC Registrar Directory. Only after reporting a month later that little had changed did ICANN perform a mass update of the directory. On further inspection we found many of the newly disclosed addresses were phantom locations, false addresses, and PO boxes. This lead to a push to amend the RAA and require Registrar location disclosure and resulted in RAA 3.16: "Registrar shall provide on its web site its accurate contact details including a valid email and mailing address." However, policy without policy enforcement is useless. So far ICANN compliance has failed to enforce this rule even after being provided with extensive evidence in June, 2010. In fact, several Registrars cited five months ago for not posting their address have been allowed to renew their accreditation without complying. The following Registrars still do not disclose their address on their website as required in RAA 3.16 and are in continued violation: Active Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com) Directi Internet Solutions Pvt. (publicdomainregistry.com) DOTALLIANCE INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) NICCO LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 GROUP LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS CORP (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) ONLINENIC INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN IDENTITY INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) WEBAIR INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) NAMEHOUSE, INC. (namehouse.net) The good news is that most of the 400 plus unique Registrars clearly provide their address in the home page footer, a CONTACT US, or ABOUT US link and several Registrars cited in June have since done so. Some Registrars bury the address in legal documents, while we do not consider this compliant ICANN provides no clear direction on where the address should be posted. OnLineNIC is particularly troubling since their purported public location is an empty lot in California with their true location being in China, but only privately disclosed to ICANN. OnLineNIC's own domain registration has been cited multiple times by KnujOn as being false. Additionally, KnujOn has discovered that nine Registrars have non-functional contact email addresses posted in the InterNIC directory: RU-CENTER, Best Bulk Register (also has a breach notice for failure to pay fees), Dynamic Network Services, Europe Domains, Homestead Limited, HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo Online. Details of the email failures along with other results will be published in our supplemental report on Monday December 6th. RAA 3.16 is not the only unenforced contract obligation. In fact, most of the RAA is unenforced with the exception being the Cardinal Sin of failing to pay ICANN fees. KnujOn will actually detail an unprecedented case in which a Registrar termination was reversed after back fees were paid. While Registrars control the content of their websites, ICANN really is to blame for the failure to enforce the RAA and the anti-transparent practice of having one Registrar directory for public consumption with bad information and another internal list for their use. Full article: http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars… -Garth ------------------------------------- Garth Bruen gbruen(a)knujon.com http://www.knujon.com http://www.linkedin.com/pub/4/149/724 Linkedin Group: http://www.linkedin.com/groups?gid=1870205 Blog: http://www.circleid.com/members/3296/ Twitter: @Knujon Shop: http://www.cafepress.com/knujon Bookstore: http://astore.amazon.com/knujocom-20 ------ NA-Discuss mailing list NA-Discuss(a)atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/na-discuss Visit the NARALO online at http://www.naralo.org ------ ------ NA-Discuss mailing list NA-Discuss(a)atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/na-discuss Visit the NARALO online at http://www.naralo.org ------ ------ NA-Discuss mailing list NA-Discuss(a)atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/na-discuss Visit the NARALO online at http://www.naralo.org ------

2 1

So public disclosure is a laughing matter
by Garth Bruen at KnujOn Dec. 7, 2010

Dec. 7, 2010

Carlton, Was it Stacy or Pam? The irony is lost on them. The point is that is makes no difference between RAA 2001 and RAA 2009, "NONE" of the Registrars are in violation because the rules are not enforced. The RAA in any version effectively does not exist. OnLineNIC was allowed to re-up without complying so there is no clearly distinction between the two, RAA amendments are just for show, disclosure to the Internet consumer is a laughing matter. Will it be the same for the law enforcement amendments? The joke will be them as we watch and see the rest signed on to the 2009 RAA without complying. -Garth > -------- Original Message -------- > Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still > in the Shadows > From: Carlton Samuels <carlton.samuels(a)gmail.com> > Date: Tue, December 07, 2010 11:42 am > To: Garth Bruen at KnujOn <gbruen(a)knujon.com> > Cc: Beau Brendler <beaubrendler(a)earthlink.net>, > na-discuss(a)atlarge-lists.icann.org > > > Garth: > FYI, I hope you were listening the the ICANN Compliance lady. Essentially, > the argument is you're only nearly half-right in certain respects since only > 12 of the outfits you fingered are in breach by virtue of signing the 2009 > RAA!!! > > [Well, blow me down with a feather!! I'm just gobsmacked that anyone yet > sentient in 2001 would've concluded a contract with entities whose business > models are Cyb-enabled and powered entirely on line and forgot to ask them > for an address record/label that embraced the pre-eminent communications > modality in the Cyb world!!] > > Of course that is not the way she said it; classic propaganda back-in - she > trumpeted the number NOT in breach that was listed according to the 2009 RAA > compliance criteria. That way she subtly invited those in the room and > following to raise the trust relationship. > > In closing, she belly-ached - prettily again! - about the 'sarcasm' flowing > her way. Slick, this one....and bears watching. > > Carlton > > ============================== > Carlton A Samuels > Mobile: 876-818-1799 > Strategy, Planning, Governance, Assessment & Turnaround > ============================= > > > On Tue, Dec 7, 2010 at 10:27 AM, Garth Bruen at KnujOn <gbruen(a)knujon.com>wrote: > > > Beau, > > > > If true that would be in line with other statements made Mr. Pritz. This > > is why David Giza was fired, right? He was actually going to follow-up > > on complaints and bring the compliance process cycle out for public > > view. Now, a clear message has been sent to ICANN staff: don't enforce > > the rules and don't talk about our procedures. At the Mexico meeting the > > compliance auditor pulled me aside and said he was concerned about > > several Registrars and might want my help. He's gone too. > > > > When I asked Mr. Pritz on an Internet Governance Forum conference call > > what happened to ICANN compliance he waved off my questions and said > > there was a vigorous search going on to fill the three vacant compliance > > positions. But where are they? It's been six months since Giza was > > removed. > > > > Yes, there are more breach notices: for failure to pay fees. > > > > Compliance is not working and I suspect this is intentional. > > > > -Garth > > > > > > > > > > > -------- Original Message -------- > > > Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still > > > in the Shadows > > > From: Beau Brendler <beaubrendler(a)earthlink.net> > > > Date: Mon, December 06, 2010 9:35 am > > > To: gbruen(a)knujon.com, "Michele Neylon :: Blacknight" > > > <michele(a)blacknight.ie>, Carlton Samuels <carlton.samuels(a)gmail.com> > > > Cc: na-discuss(a)atlarge-lists.icann.org > > > > > > > > > I found Kurt Pritz's reply to my question on compliance at yesterday's > > presentation in Cartagena rather revealing (and that's assuming I heard it > > correctly, we will need to listen to the tape). But I am fairly sure I heard > > him say, in response to my statement that a number of registrars remain out > > of compliance with the RAA and that some of us in the community don't really > > think ICANN believes it can enforce contracts, that "enforcement was an > > interesting question with several answers." (That's not an exact quote, but > > it was something similarly mysterious and vague). That sounds to me, to > > quote Carlton, that all animals are created equal but some more than others. > > Is OnlineNIC one of them? I have plenty of evidence, independent from > > Knujon, that OnlineNIC is out of compliance with the RAA, and that they were > > allowed to re-up, and continue their merry way. > > > > > > I was also concerned that Kurt seemed to characterize compliance progress > > as a factor of the number of breach notices steadily increasing. The > > meaningful statistic would be: How many of those breach notices are > > resolved? And if the system was really working, breach notices should be > > going down, not up. It's great that ICANN's strategic plan mentions security > > and contract compliance as goals, but those are going to be tough to achieve > > with no functioning compliance department. > > > > > > Repeatedly we have heard the registrar community voice its resistance to > > oversight and "regulation." But the registrar community should not be trying > > to shoot the messenger here; it should be considering how to self-police its > > ranks. If ICANN is not going to do its job, let's dismantle ICANN and take > > user and consumer concerns to the press, to international law enforcement > > bodies, and see if we can make better progress. > > > > > > -----Original Message----- > > > >From: gbruen(a)knujon.com > > > >Sent: Dec 6, 2010 8:30 AM > > > >To: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie>, Carlton > > Samuels <carlton.samuels(a)gmail.com> > > > >Cc: na-discuss(a)atlarge-lists.icann.org > > > >Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still > > in the Shadows > > > > > > > >I checked into the claims by Michele (or maybe I should address you as > > > >"Blacknight"?) and my suspicions were confirmed. He has completely > > distorted > > > >the issues and ignored the critical problem. Active Registrar, Compana, > > > >Directi, DOTALLIANCE, EVERYONES INTERNET, NICCO, RESELLER SERVICES, UK2 > > > >GROUP, VOLUSION, YNOT DOMAINS, and OWN IDENTITY have not corrected the > > > >problem as cited since June and ICANN compliance has not addressed the > > > >issue. You've glossed over this. > > > > > > > >You've also glossed over the fact that OnLineNIC was allowed to sign on > > to > > > >the 2009 RAA without first complying and has not been held to comply > > since, > > > >even through we were informed they would be held to the RAA after > > signing. > > > > > > > >In our original report we expressed our concern the the other Registrars > > > >would also be allowed to re-sign without meeting this requirement, and > > why > > > >should they have to when it's not enforced? Why would they opt for > > public > > > >disclosure when their competitors are not held by any standard? Does > > this > > > >not concern you? > > > > > > > >The RAA has become meaningless and the Internet user DESERVERS BETTER. > > > > > > > >If you purport to be a leader in this community you'll expect better > > too. > > > > > > > > > > > > > > > > > > > >-------------------------------------------------- > > > >From: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie> > > > >Sent: Sunday, December 05, 2010 8:31 PM > > > >To: "Carlton Samuels" <carlton.samuels(a)gmail.com> > > > >Cc: <na-discuss(a)atlarge-lists.icann.org> > > > >Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in > > the > > > >Shadows > > > > > > > >> I checked into the claims by Knujon and my suspicions were confirmed. > > > >> Of the registrars supposedly in breach 50% are NOT on the 2009 RAA. > > They > > > >> are, therefore, NOT in breach, so I wonder how long we will have to > > wait > > > >> for a corrected / updated version of this report > > > >> > > > >> Regards > > > >> > > > >> Michele > > > >> > > > >> Mr. Michele Neylon > > > >> Blacknight > > > >> http://Blacknight.tel > > > >> > > > >> Via iPhone so excuse typos and brevity > > > >> > > > >> On 4 Dec 2010, at 23:14, "Carlton Samuels" <carlton.samuels(a)gmail.com > > > > > > >> wrote: > > > >> > > > >>> Garth: > > > >>> I commend you and KnuJon for keeping at this issue. It is one thing > > to > > > >>> be > > > >>> the slacker in a contract. But the fact that ICANN fails to embrace > > its > > > >>> duty of care to the community in ensuring that contracted parties > > live up > > > >>> to > > > >>> the terms and condition of contract remains scandalous. > > > >>> > > > >>> The low hanging fruit of an explanation would be ignorance of its > > > >>> commitment. But reason and good judgment suggests that this would be > > a > > > >>> stretch for explanation. Time enough for ICANN to rise to the > > occasion > > > >>> and > > > >>> do its duty. > > > >>> > > > >>> Carlton > > > >>> [Chair, At-Large WHOIS WG] > > > >>> > > > >>> ============================== > > > >>> Carlton A Samuels > > > >>> Mobile: 876-818-1799 > > > >>> Strategy, Planning, Governance, Assessment & Turnaround > > > >>> ============================= > > > >>> > > > >>> > > > >>> > > > >>>> > > > >>>> 1. Two Years Later Dozens of Registrars Still in the > > Shadows > > > >>>> (Garth Bruen at KnujOn) > > > >>>> > > > >>>> > > > >>>> > > ---------------------------------------------------------------------- > > > >>>> > > > >>>> Message: 1 > > > >>>> Date: Fri, 03 Dec 2010 11:49:35 -0700 > > > >>>> From: "Garth Bruen at KnujOn" <gbruen(a)knujon.com> > > > >>>> Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in > > > >>>> the Shadows > > > >>>> To: na-discuss(a)atlarge-lists.icann.org > > > >>>> > > > >>>> Folks, > > > >>>> > > > >>>> In June of 2008 KnujOn reported that 70 Registrars did not have a > > > >>>> business address listed in the InterNIC Registrar Directory. Only > > after > > > >>>> reporting a month later that little had changed did ICANN perform a > > mass > > > >>>> update of the directory. On further inspection we found many of the > > > >>>> newly disclosed addresses were phantom locations, false addresses, > > and > > > >>>> PO boxes. This lead to a push to amend the RAA and require Registrar > > > >>>> location disclosure and resulted in RAA 3.16: "Registrar shall > > provide > > > >>>> on its web site its accurate contact details including a valid email > > and > > > >>>> mailing address." However, policy without policy enforcement is > > useless. > > > >>>> So far ICANN compliance has failed to enforce this rule even after > > being > > > >>>> provided with extensive evidence in June, 2010. In fact, several > > > >>>> Registrars cited five months ago for not posting their address have > > been > > > >>>> allowed to renew their accreditation without complying. > > > >>>> > > > >>>> The following Registrars still do not disclose their address on > > their > > > >>>> website as required in RAA 3.16 and are in continued violation: > > Active > > > >>>> Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com > > ), > > > >>>> Directi Internet Solutions Pvt. (publicdomainregistry.com) > > DOTALLIANCE > > > >>>> INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) > > NICCO > > > >>>> LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 > > GROUP > > > >>>> LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS > > CORP > > > >>>> (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN > > > >>>> (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA > > > >>>> VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. > > > >>>> (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) > > ONLINENIC > > > >>>> INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN > > IDENTITY > > > >>>> INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES > > > >>>> TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) > > WEBAIR > > > >>>> INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) > > > >>>> NAMEHOUSE, INC. (namehouse.net) The good news is that most of the > > 400 > > > >>>> plus unique Registrars clearly provide their address in the home > > page > > > >>>> footer, a CONTACT US, or ABOUT US link and several Registrars cited > > in > > > >>>> June have since done so. Some Registrars bury the address in legal > > > >>>> documents, while we do not consider this compliant ICANN provides no > > > >>>> clear direction on where the address should be posted. > > > >>>> > > > >>>> OnLineNIC is particularly troubling since their purported public > > > >>>> location is an empty lot in California with their true location > > being in > > > >>>> China, but only privately disclosed to ICANN. OnLineNIC's own domain > > > >>>> registration has been cited multiple times by KnujOn as being false. > > > >>>> > > > >>>> Additionally, KnujOn has discovered that nine Registrars have > > > >>>> non-functional contact email addresses posted in the InterNIC > > directory: > > > >>>> RU-CENTER, Best Bulk Register (also has a breach notice for failure > > to > > > >>>> pay fees), Dynamic Network Services, Europe Domains, Homestead > > Limited, > > > >>>> HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo > > Online. > > > >>>> Details of the email failures along with other results will be > > published > > > >>>> in our supplemental report on Monday December 6th. > > > >>>> > > > >>>> RAA 3.16 is not the only unenforced contract obligation. In fact, > > most > > > >>>> of the RAA is unenforced with the exception being the Cardinal Sin > > of > > > >>>> failing to pay ICANN fees. KnujOn will actually detail an > > unprecedented > > > >>>> case in which a Registrar termination was reversed after back fees > > were > > > >>>> paid. > > > >>>> > > > >>>> While Registrars control the content of their websites, ICANN really > > is > > > >>>> to blame for the failure to enforce the RAA and the anti-transparent > > > >>>> practice of having one Registrar directory for public consumption > > with > > > >>>> bad information and another internal list for their use. > > > >>>> > > > >>>> > > > >>>> Full article: > > > >>>> > > > >>>> > > http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars… > > > >>>> > > > >>>> -Garth > > > >>>> > > > >>>> ------------------------------------- > > > >>>> Garth Bruen > > > >>>> gbruen(a)knujon.com > > > >>>> http://www.knujon.com > > > >>>> http://www.linkedin.com/pub/4/149/724 > > > >>>> Linkedin Group: http://www.linkedin.com/groups?gid=1870205 > > > >>>> Blog: http://www.circleid.com/members/3296/ > > > >>>> Twitter: @Knujon > > > >>>> Shop: http://www.cafepress.com/knujon > > > >>>> Bookstore: http://astore.amazon.com/knujocom-20 > > > >>>> > > > >>>> > > > >>>> > > > >>>> > > > >>> ------ > > > >>> NA-Discuss mailing list > > > >>> NA-Discuss(a)atlarge-lists.icann.org > > > >>> https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > > >>> > > > >>> Visit the NARALO on line at http://www.naralo.org > > > >>> ------ > > > >> > > > >> ------ > > > >> NA-Discuss mailing list > > > >> NA-Discuss(a)atlarge-lists.icann.org > > > >> https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > > >> > > > >> Visit the NARALO on line at http://www.naralo.org > > > >> ------ > > > >> > > > >------ > > > >NA-Discuss mailing list > > > >NA-Discuss(a)atlarge-lists.icann.org > > > >https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > > > > > > >Visit the NARALO on line at http://www.naralo.org > > > >------ > > > >

2 1

Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows
by Garth Bruen at KnujOn Dec. 7, 2010

Dec. 7, 2010

Beau, If true that would be in line with other statements made Mr. Pritz. This is why David Giza was fired, right? He was actually going to follow-up on complaints and bring the compliance process cycle out for public view. Now, a clear message has been sent to ICANN staff: don't enforce the rules and don't talk about our procedures. At the Mexico meeting the compliance auditor pulled me aside and said he was concerned about several Registrars and might want my help. He's gone too. When I asked Mr. Pritz on an Internet Governance Forum conference call what happened to ICANN compliance he waved off my questions and said there was a vigorous search going on to fill the three vacant compliance positions. But where are they? It's been six months since Giza was removed. Yes, there are more breach notices: for failure to pay fees. Compliance is not working and I suspect this is intentional. -Garth > -------- Original Message -------- > Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still > in the Shadows > From: Beau Brendler <beaubrendler(a)earthlink.net> > Date: Mon, December 06, 2010 9:35 am > To: gbruen(a)knujon.com, "Michele Neylon :: Blacknight" > <michele(a)blacknight.ie>, Carlton Samuels <carlton.samuels(a)gmail.com> > Cc: na-discuss(a)atlarge-lists.icann.org > > > I found Kurt Pritz's reply to my question on compliance at yesterday's presentation in Cartagena rather revealing (and that's assuming I heard it correctly, we will need to listen to the tape). But I am fairly sure I heard him say, in response to my statement that a number of registrars remain out of compliance with the RAA and that some of us in the community don't really think ICANN believes it can enforce contracts, that "enforcement was an interesting question with several answers." (That's not an exact quote, but it was something similarly mysterious and vague). That sounds to me, to quote Carlton, that all animals are created equal but some more than others. Is OnlineNIC one of them? I have plenty of evidence, independent from Knujon, that OnlineNIC is out of compliance with the RAA, and that they were allowed to re-up, and continue their merry way. > > I was also concerned that Kurt seemed to characterize compliance progress as a factor of the number of breach notices steadily increasing. The meaningful statistic would be: How many of those breach notices are resolved? And if the system was really working, breach notices should be going down, not up. It's great that ICANN's strategic plan mentions security and contract compliance as goals, but those are going to be tough to achieve with no functioning compliance department. > > Repeatedly we have heard the registrar community voice its resistance to oversight and "regulation." But the registrar community should not be trying to shoot the messenger here; it should be considering how to self-police its ranks. If ICANN is not going to do its job, let's dismantle ICANN and take user and consumer concerns to the press, to international law enforcement bodies, and see if we can make better progress. > > -----Original Message----- > >From: gbruen(a)knujon.com > >Sent: Dec 6, 2010 8:30 AM > >To: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie>, Carlton Samuels <carlton.samuels(a)gmail.com> > >Cc: na-discuss(a)atlarge-lists.icann.org > >Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows > > > >I checked into the claims by Michele (or maybe I should address you as > >"Blacknight"?) and my suspicions were confirmed. He has completely distorted > >the issues and ignored the critical problem. Active Registrar, Compana, > >Directi, DOTALLIANCE, EVERYONES INTERNET, NICCO, RESELLER SERVICES, UK2 > >GROUP, VOLUSION, YNOT DOMAINS, and OWN IDENTITY have not corrected the > >problem as cited since June and ICANN compliance has not addressed the > >issue. You've glossed over this. > > > >You've also glossed over the fact that OnLineNIC was allowed to sign on to > >the 2009 RAA without first complying and has not been held to comply since, > >even through we were informed they would be held to the RAA after signing. > > > >In our original report we expressed our concern the the other Registrars > >would also be allowed to re-sign without meeting this requirement, and why > >should they have to when it's not enforced? Why would they opt for public > >disclosure when their competitors are not held by any standard? Does this > >not concern you? > > > >The RAA has become meaningless and the Internet user DESERVERS BETTER. > > > >If you purport to be a leader in this community you'll expect better too. > > > > > > > > > >-------------------------------------------------- > >From: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie> > >Sent: Sunday, December 05, 2010 8:31 PM > >To: "Carlton Samuels" <carlton.samuels(a)gmail.com> > >Cc: <na-discuss(a)atlarge-lists.icann.org> > >Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the > >Shadows > > > >> I checked into the claims by Knujon and my suspicions were confirmed. > >> Of the registrars supposedly in breach 50% are NOT on the 2009 RAA. They > >> are, therefore, NOT in breach, so I wonder how long we will have to wait > >> for a corrected / updated version of this report > >> > >> Regards > >> > >> Michele > >> > >> Mr. Michele Neylon > >> Blacknight > >> http://Blacknight.tel > >> > >> Via iPhone so excuse typos and brevity > >> > >> On 4 Dec 2010, at 23:14, "Carlton Samuels" <carlton.samuels(a)gmail.com> > >> wrote: > >> > >>> Garth: > >>> I commend you and KnuJon for keeping at this issue. It is one thing to > >>> be > >>> the slacker in a contract. But the fact that ICANN fails to embrace its > >>> duty of care to the community in ensuring that contracted parties live up > >>> to > >>> the terms and condition of contract remains scandalous. > >>> > >>> The low hanging fruit of an explanation would be ignorance of its > >>> commitment. But reason and good judgment suggests that this would be a > >>> stretch for explanation. Time enough for ICANN to rise to the occasion > >>> and > >>> do its duty. > >>> > >>> Carlton > >>> [Chair, At-Large WHOIS WG] > >>> > >>> ============================== > >>> Carlton A Samuels > >>> Mobile: 876-818-1799 > >>> Strategy, Planning, Governance, Assessment & Turnaround > >>> ============================= > >>> > >>> > >>> > >>>> > >>>> 1. Two Years Later Dozens of Registrars Still in the Shadows > >>>> (Garth Bruen at KnujOn) > >>>> > >>>> > >>>> ---------------------------------------------------------------------- > >>>> > >>>> Message: 1 > >>>> Date: Fri, 03 Dec 2010 11:49:35 -0700 > >>>> From: "Garth Bruen at KnujOn" <gbruen(a)knujon.com> > >>>> Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in > >>>> the Shadows > >>>> To: na-discuss(a)atlarge-lists.icann.org > >>>> > >>>> Folks, > >>>> > >>>> In June of 2008 KnujOn reported that 70 Registrars did not have a > >>>> business address listed in the InterNIC Registrar Directory. Only after > >>>> reporting a month later that little had changed did ICANN perform a mass > >>>> update of the directory. On further inspection we found many of the > >>>> newly disclosed addresses were phantom locations, false addresses, and > >>>> PO boxes. This lead to a push to amend the RAA and require Registrar > >>>> location disclosure and resulted in RAA 3.16: "Registrar shall provide > >>>> on its web site its accurate contact details including a valid email and > >>>> mailing address." However, policy without policy enforcement is useless. > >>>> So far ICANN compliance has failed to enforce this rule even after being > >>>> provided with extensive evidence in June, 2010. In fact, several > >>>> Registrars cited five months ago for not posting their address have been > >>>> allowed to renew their accreditation without complying. > >>>> > >>>> The following Registrars still do not disclose their address on their > >>>> website as required in RAA 3.16 and are in continued violation: Active > >>>> Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com) > >>>> Directi Internet Solutions Pvt. (publicdomainregistry.com) DOTALLIANCE > >>>> INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) NICCO > >>>> LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 GROUP > >>>> LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS CORP > >>>> (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN > >>>> (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA > >>>> VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. > >>>> (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) ONLINENIC > >>>> INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN IDENTITY > >>>> INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES > >>>> TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) WEBAIR > >>>> INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) > >>>> NAMEHOUSE, INC. (namehouse.net) The good news is that most of the 400 > >>>> plus unique Registrars clearly provide their address in the home page > >>>> footer, a CONTACT US, or ABOUT US link and several Registrars cited in > >>>> June have since done so. Some Registrars bury the address in legal > >>>> documents, while we do not consider this compliant ICANN provides no > >>>> clear direction on where the address should be posted. > >>>> > >>>> OnLineNIC is particularly troubling since their purported public > >>>> location is an empty lot in California with their true location being in > >>>> China, but only privately disclosed to ICANN. OnLineNIC's own domain > >>>> registration has been cited multiple times by KnujOn as being false. > >>>> > >>>> Additionally, KnujOn has discovered that nine Registrars have > >>>> non-functional contact email addresses posted in the InterNIC directory: > >>>> RU-CENTER, Best Bulk Register (also has a breach notice for failure to > >>>> pay fees), Dynamic Network Services, Europe Domains, Homestead Limited, > >>>> HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo Online. > >>>> Details of the email failures along with other results will be published > >>>> in our supplemental report on Monday December 6th. > >>>> > >>>> RAA 3.16 is not the only unenforced contract obligation. In fact, most > >>>> of the RAA is unenforced with the exception being the Cardinal Sin of > >>>> failing to pay ICANN fees. KnujOn will actually detail an unprecedented > >>>> case in which a Registrar termination was reversed after back fees were > >>>> paid. > >>>> > >>>> While Registrars control the content of their websites, ICANN really is > >>>> to blame for the failure to enforce the RAA and the anti-transparent > >>>> practice of having one Registrar directory for public consumption with > >>>> bad information and another internal list for their use. > >>>> > >>>> > >>>> Full article: > >>>> > >>>> http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars… > >>>> > >>>> -Garth > >>>> > >>>> ------------------------------------- > >>>> Garth Bruen > >>>> gbruen(a)knujon.com > >>>> http://www.knujon.com > >>>> http://www.linkedin.com/pub/4/149/724 > >>>> Linkedin Group: http://www.linkedin.com/groups?gid=1870205 > >>>> Blog: http://www.circleid.com/members/3296/ > >>>> Twitter: @Knujon > >>>> Shop: http://www.cafepress.com/knujon > >>>> Bookstore: http://astore.amazon.com/knujocom-20 > >>>> > >>>> > >>>> > >>>> > >>> ------ > >>> NA-Discuss mailing list > >>> NA-Discuss(a)atlarge-lists.icann.org > >>> https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > >>> > >>> Visit the NARALO online at http://www.naralo.org > >>> ------ > >> > >> ------ > >> NA-Discuss mailing list > >> NA-Discuss(a)atlarge-lists.icann.org > >> https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > >> > >> Visit the NARALO online at http://www.naralo.org > >> ------ > >> > >------ > >NA-Discuss mailing list > >NA-Discuss(a)atlarge-lists.icann.org > >https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > > > >Visit the NARALO online at http://www.naralo.org > >------

2 1

Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows
by Carlton Samuels Dec. 6, 2010

Dec. 6, 2010

Garth: I commend you and KnuJon for keeping at this issue. It is one thing to be the slacker in a contract. But the fact that ICANN fails to embrace its duty of care to the community in ensuring that contracted parties live up to the terms and condition of contract remains scandalous. The low hanging fruit of an explanation would be ignorance of its commitment. But reason and good judgment suggests that this would be a stretch for explanation. Time enough for ICANN to rise to the occasion and do its duty. Carlton [Chair, At-Large WHOIS WG] ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Planning, Governance, Assessment & Turnaround ============================= > > 1. Two Years Later Dozens of Registrars Still in the Shadows > (Garth Bruen at KnujOn) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Fri, 03 Dec 2010 11:49:35 -0700 > From: "Garth Bruen at KnujOn" <gbruen(a)knujon.com> > Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in > the Shadows > To: na-discuss(a)atlarge-lists.icann.org > > Folks, > > In June of 2008 KnujOn reported that 70 Registrars did not have a > business address listed in the InterNIC Registrar Directory. Only after > reporting a month later that little had changed did ICANN perform a mass > update of the directory. On further inspection we found many of the > newly disclosed addresses were phantom locations, false addresses, and > PO boxes. This lead to a push to amend the RAA and require Registrar > location disclosure and resulted in RAA 3.16: "Registrar shall provide > on its web site its accurate contact details including a valid email and > mailing address." However, policy without policy enforcement is useless. > So far ICANN compliance has failed to enforce this rule even after being > provided with extensive evidence in June, 2010. In fact, several > Registrars cited five months ago for not posting their address have been > allowed to renew their accreditation without complying. > > The following Registrars still do not disclose their address on their > website as required in RAA 3.16 and are in continued violation: Active > Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com) > Directi Internet Solutions Pvt. (publicdomainregistry.com) DOTALLIANCE > INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) NICCO > LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 GROUP > LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS CORP > (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN > (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA > VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. > (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) ONLINENIC > INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN IDENTITY > INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES > TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) WEBAIR > INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) > NAMEHOUSE, INC. (namehouse.net) The good news is that most of the 400 > plus unique Registrars clearly provide their address in the home page > footer, a CONTACT US, or ABOUT US link and several Registrars cited in > June have since done so. Some Registrars bury the address in legal > documents, while we do not consider this compliant ICANN provides no > clear direction on where the address should be posted. > > OnLineNIC is particularly troubling since their purported public > location is an empty lot in California with their true location being in > China, but only privately disclosed to ICANN. OnLineNIC's own domain > registration has been cited multiple times by KnujOn as being false. > > Additionally, KnujOn has discovered that nine Registrars have > non-functional contact email addresses posted in the InterNIC directory: > RU-CENTER, Best Bulk Register (also has a breach notice for failure to > pay fees), Dynamic Network Services, Europe Domains, Homestead Limited, > HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo Online. > Details of the email failures along with other results will be published > in our supplemental report on Monday December 6th. > > RAA 3.16 is not the only unenforced contract obligation. In fact, most > of the RAA is unenforced with the exception being the Cardinal Sin of > failing to pay ICANN fees. KnujOn will actually detail an unprecedented > case in which a Registrar termination was reversed after back fees were > paid. > > While Registrars control the content of their websites, ICANN really is > to blame for the failure to enforce the RAA and the anti-transparent > practice of having one Registrar directory for public consumption with > bad information and another internal list for their use. > > > Full article: > > http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars… > > -Garth > > ------------------------------------- > Garth Bruen > gbruen(a)knujon.com > http://www.knujon.com > http://www.linkedin.com/pub/4/149/724 > Linkedin Group: http://www.linkedin.com/groups?gid=1870205 > Blog: http://www.circleid.com/members/3296/ > Twitter: @Knujon > Shop: http://www.cafepress.com/knujon > Bookstore: http://astore.amazon.com/knujocom-20 > > > >

3 4

Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows
by Beau Brendler Dec. 6, 2010

Dec. 6, 2010

I found Kurt Pritz's reply to my question on compliance at yesterday's presentation in Cartagena rather revealing (and that's assuming I heard it correctly, we will need to listen to the tape). But I am fairly sure I heard him say, in response to my statement that a number of registrars remain out of compliance with the RAA and that some of us in the community don't really think ICANN believes it can enforce contracts, that "enforcement was an interesting question with several answers." (That's not an exact quote, but it was something similarly mysterious and vague). That sounds to me, to quote Carlton, that all animals are created equal but some more than others. Is OnlineNIC one of them? I have plenty of evidence, independent from Knujon, that OnlineNIC is out of compliance with the RAA, and that they were allowed to re-up, and continue their merry way. I was also concerned that Kurt seemed to characterize compliance progress as a factor of the number of breach notices steadily increasing. The meaningful statistic would be: How many of those breach notices are resolved? And if the system was really working, breach notices should be going down, not up. It's great that ICANN's strategic plan mentions security and contract compliance as goals, but those are going to be tough to achieve with no functioning compliance department. Repeatedly we have heard the registrar community voice its resistance to oversight and "regulation." But the registrar community should not be trying to shoot the messenger here; it should be considering how to self-police its ranks. If ICANN is not going to do its job, let's dismantle ICANN and take user and consumer concerns to the press, to international law enforcement bodies, and see if we can make better progress. -----Original Message----- >From: gbruen(a)knujon.com >Sent: Dec 6, 2010 8:30 AM >To: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie>, Carlton Samuels <carlton.samuels(a)gmail.com> >Cc: na-discuss(a)atlarge-lists.icann.org >Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows > >I checked into the claims by Michele (or maybe I should address you as >"Blacknight"?) and my suspicions were confirmed. He has completely distorted >the issues and ignored the critical problem. Active Registrar, Compana, >Directi, DOTALLIANCE, EVERYONES INTERNET, NICCO, RESELLER SERVICES, UK2 >GROUP, VOLUSION, YNOT DOMAINS, and OWN IDENTITY have not corrected the >problem as cited since June and ICANN compliance has not addressed the >issue. You've glossed over this. > >You've also glossed over the fact that OnLineNIC was allowed to sign on to >the 2009 RAA without first complying and has not been held to comply since, >even through we were informed they would be held to the RAA after signing. > >In our original report we expressed our concern the the other Registrars >would also be allowed to re-sign without meeting this requirement, and why >should they have to when it's not enforced? Why would they opt for public >disclosure when their competitors are not held by any standard? Does this >not concern you? > >The RAA has become meaningless and the Internet user DESERVERS BETTER. > >If you purport to be a leader in this community you'll expect better too. > > > > >-------------------------------------------------- >From: "Michele Neylon :: Blacknight" <michele(a)blacknight.ie> >Sent: Sunday, December 05, 2010 8:31 PM >To: "Carlton Samuels" <carlton.samuels(a)gmail.com> >Cc: <na-discuss(a)atlarge-lists.icann.org> >Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the >Shadows > >> I checked into the claims by Knujon and my suspicions were confirmed. >> Of the registrars supposedly in breach 50% are NOT on the 2009 RAA. They >> are, therefore, NOT in breach, so I wonder how long we will have to wait >> for a corrected / updated version of this report >> >> Regards >> >> Michele >> >> Mr. Michele Neylon >> Blacknight >> http://Blacknight.tel >> >> Via iPhone so excuse typos and brevity >> >> On 4 Dec 2010, at 23:14, "Carlton Samuels" <carlton.samuels(a)gmail.com> >> wrote: >> >>> Garth: >>> I commend you and KnuJon for keeping at this issue. It is one thing to >>> be >>> the slacker in a contract. But the fact that ICANN fails to embrace its >>> duty of care to the community in ensuring that contracted parties live up >>> to >>> the terms and condition of contract remains scandalous. >>> >>> The low hanging fruit of an explanation would be ignorance of its >>> commitment. But reason and good judgment suggests that this would be a >>> stretch for explanation. Time enough for ICANN to rise to the occasion >>> and >>> do its duty. >>> >>> Carlton >>> [Chair, At-Large WHOIS WG] >>> >>> ============================== >>> Carlton A Samuels >>> Mobile: 876-818-1799 >>> Strategy, Planning, Governance, Assessment & Turnaround >>> ============================= >>> >>> >>> >>>> >>>> 1. Two Years Later Dozens of Registrars Still in the Shadows >>>> (Garth Bruen at KnujOn) >>>> >>>> >>>> ---------------------------------------------------------------------- >>>> >>>> Message: 1 >>>> Date: Fri, 03 Dec 2010 11:49:35 -0700 >>>> From: "Garth Bruen at KnujOn" <gbruen(a)knujon.com> >>>> Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in >>>> the Shadows >>>> To: na-discuss(a)atlarge-lists.icann.org >>>> >>>> Folks, >>>> >>>> In June of 2008 KnujOn reported that 70 Registrars did not have a >>>> business address listed in the InterNIC Registrar Directory. Only after >>>> reporting a month later that little had changed did ICANN perform a mass >>>> update of the directory. On further inspection we found many of the >>>> newly disclosed addresses were phantom locations, false addresses, and >>>> PO boxes. This lead to a push to amend the RAA and require Registrar >>>> location disclosure and resulted in RAA 3.16: "Registrar shall provide >>>> on its web site its accurate contact details including a valid email and >>>> mailing address." However, policy without policy enforcement is useless. >>>> So far ICANN compliance has failed to enforce this rule even after being >>>> provided with extensive evidence in June, 2010. In fact, several >>>> Registrars cited five months ago for not posting their address have been >>>> allowed to renew their accreditation without complying. >>>> >>>> The following Registrars still do not disclose their address on their >>>> website as required in RAA 3.16 and are in continued violation: Active >>>> Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com) >>>> Directi Internet Solutions Pvt. (publicdomainregistry.com) DOTALLIANCE >>>> INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) NICCO >>>> LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 GROUP >>>> LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS CORP >>>> (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN >>>> (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA >>>> VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. >>>> (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) ONLINENIC >>>> INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN IDENTITY >>>> INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES >>>> TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) WEBAIR >>>> INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) >>>> NAMEHOUSE, INC. (namehouse.net) The good news is that most of the 400 >>>> plus unique Registrars clearly provide their address in the home page >>>> footer, a CONTACT US, or ABOUT US link and several Registrars cited in >>>> June have since done so. Some Registrars bury the address in legal >>>> documents, while we do not consider this compliant ICANN provides no >>>> clear direction on where the address should be posted. >>>> >>>> OnLineNIC is particularly troubling since their purported public >>>> location is an empty lot in California with their true location being in >>>> China, but only privately disclosed to ICANN. OnLineNIC's own domain >>>> registration has been cited multiple times by KnujOn as being false. >>>> >>>> Additionally, KnujOn has discovered that nine Registrars have >>>> non-functional contact email addresses posted in the InterNIC directory: >>>> RU-CENTER, Best Bulk Register (also has a breach notice for failure to >>>> pay fees), Dynamic Network Services, Europe Domains, Homestead Limited, >>>> HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo Online. >>>> Details of the email failures along with other results will be published >>>> in our supplemental report on Monday December 6th. >>>> >>>> RAA 3.16 is not the only unenforced contract obligation. In fact, most >>>> of the RAA is unenforced with the exception being the Cardinal Sin of >>>> failing to pay ICANN fees. KnujOn will actually detail an unprecedented >>>> case in which a Registrar termination was reversed after back fees were >>>> paid. >>>> >>>> While Registrars control the content of their websites, ICANN really is >>>> to blame for the failure to enforce the RAA and the anti-transparent >>>> practice of having one Registrar directory for public consumption with >>>> bad information and another internal list for their use. >>>> >>>> >>>> Full article: >>>> >>>> http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars… >>>> >>>> -Garth >>>> >>>> ------------------------------------- >>>> Garth Bruen >>>> gbruen(a)knujon.com >>>> http://www.knujon.com >>>> http://www.linkedin.com/pub/4/149/724 >>>> Linkedin Group: http://www.linkedin.com/groups?gid=1870205 >>>> Blog: http://www.circleid.com/members/3296/ >>>> Twitter: @Knujon >>>> Shop: http://www.cafepress.com/knujon >>>> Bookstore: http://astore.amazon.com/knujocom-20 >>>> >>>> >>>> >>>> >>> ------ >>> NA-Discuss mailing list >>> NA-Discuss(a)atlarge-lists.icann.org >>> https://atlarge-lists.icann.org/mailman/listinfo/na-discuss >>> >>> Visit the NARALO online at http://www.naralo.org >>> ------ >> >> ------ >> NA-Discuss mailing list >> NA-Discuss(a)atlarge-lists.icann.org >> https://atlarge-lists.icann.org/mailman/listinfo/na-discuss >> >> Visit the NARALO online at http://www.naralo.org >> ------ >> >------ >NA-Discuss mailing list >NA-Discuss(a)atlarge-lists.icann.org >https://atlarge-lists.icann.org/mailman/listinfo/na-discuss > >Visit the NARALO online at http://www.naralo.org >------

1 0

Two Years Later Dozens of Registrars Still in the Shadows
by Garth Bruen at KnujOn Dec. 3, 2010

Dec. 3, 2010

Folks, In June of 2008 KnujOn reported that 70 Registrars did not have a business address listed in the InterNIC Registrar Directory. Only after reporting a month later that little had changed did ICANN perform a mass update of the directory. On further inspection we found many of the newly disclosed addresses were phantom locations, false addresses, and PO boxes. This lead to a push to amend the RAA and require Registrar location disclosure and resulted in RAA 3.16: "Registrar shall provide on its web site its accurate contact details including a valid email and mailing address." However, policy without policy enforcement is useless. So far ICANN compliance has failed to enforce this rule even after being provided with extensive evidence in June, 2010. In fact, several Registrars cited five months ago for not posting their address have been allowed to renew their accreditation without complying. The following Registrars still do not disclose their address on their website as required in RAA 3.16 and are in continued violation: Active Registrar, Inc. (activeregistrar.com) COMPANA LLC (budgetnames.com) Directi Internet Solutions Pvt. (publicdomainregistry.com) DOTALLIANCE INC (dotalliance.com) EVERYONES INTERNET LTD. (resellone.net) NICCO LTD. (nicco.com) RESELLER SERVICES INC. (ResellServ.com) UK2 GROUP LTD. (uk2group.com) VOLUSION, INC. (volusion.com) YNOT DOMAINS CORP (myorderbox.com) PREMIUM REGISTRATIONS SWEDEN (premiumregistrations.com) AB CONNECT (hosteur.com) FUNPEAS MEDIA VENTURES, LLC DBA DOMAINPROCESSOR.COM, DomainContext, Inc. (isregistrar.com) NEW GREAT DOMAINS (newgreatdomains.com) ONLINENIC INC. (onlinenic.com) OPEN SYSTEM LTD. (turbosite.com.br), OWN IDENTITY INC (ownidentity.com) PACNAMES LTD (pacnames.com) QUANTUMPAGES TECHNOLOGIES (ownregistrar.com) ULTRARPM INC. (metapredict.com) WEBAIR INTERNET DEVELOPMENT (webair.com) ZOG MEDIA, INC. (zognames.com) NAMEHOUSE, INC. (namehouse.net) The good news is that most of the 400 plus unique Registrars clearly provide their address in the home page footer, a CONTACT US, or ABOUT US link and several Registrars cited in June have since done so. Some Registrars bury the address in legal documents, while we do not consider this compliant ICANN provides no clear direction on where the address should be posted. OnLineNIC is particularly troubling since their purported public location is an empty lot in California with their true location being in China, but only privately disclosed to ICANN. OnLineNIC's own domain registration has been cited multiple times by KnujOn as being false. Additionally, KnujOn has discovered that nine Registrars have non-functional contact email addresses posted in the InterNIC directory: RU-CENTER, Best Bulk Register (also has a breach notice for failure to pay fees), Dynamic Network Services, Europe Domains, Homestead Limited, HTTP.NET, Namescout, Hostmaster.ca, Nameshare Inc, and Universo Online. Details of the email failures along with other results will be published in our supplemental report on Monday December 6th. RAA 3.16 is not the only unenforced contract obligation. In fact, most of the RAA is unenforced with the exception being the Cardinal Sin of failing to pay ICANN fees. KnujOn will actually detail an unprecedented case in which a Registrar termination was reversed after back fees were paid. While Registrars control the content of their websites, ICANN really is to blame for the failure to enforce the RAA and the anti-transparent practice of having one Registrar directory for public consumption with bad information and another internal list for their use. Full article: http://www.circleid.com/posts/20101203_two_years_later_dozens_of_registrars… -Garth ------------------------------------- Garth Bruen gbruen(a)knujon.com http://www.knujon.com http://www.linkedin.com/pub/4/149/724 Linkedin Group: http://www.linkedin.com/groups?gid=1870205 Blog: http://www.circleid.com/members/3296/ Twitter: @Knujon Shop: http://www.cafepress.com/knujon Bookstore: http://astore.amazon.com/knujocom-20

1 0

On the exchange of notes between Peter and Heather -- city names
by Eric Brunner-Williams Dec. 1, 2010

Dec. 1, 2010

Dear North American Regional At Large Colleagues, I'm preparing a personal comment, reflecting my thoughts on the issue of city names, to submit before my term as the Unaffiliated NARALO Member Representative begins at the close of the 2010 ICANN AGM in Cartagena. Broadly, I think each of the rationals Peter offers for declining to explore changes from the DAGv4 (now DAGv5) protections is flawed, and I think limiting the GAC's interest in distinguishing urban public administrations from private parties to delegation agreements to mere string protection is also flawed. Naturally, given the complexity of the issues, and my own prolixity, it will take me several pages to present my thoughts to Peter and Heather. I am aware of gTLD projects in the North American Region concerned with Boston, Chicago, Dallas, New York, Miami, Portland (Oregon), Seattle, San Francisco, Las Vegas, and smaller numbers of gTLD projects similarly concerned with urban areas in Europe, Asia, South America, and Asia - Pacific. The public comments period for the current version of the DAG closes on December 10th, at 7am Eastern, 4am Pacific, just before the Friday Board meeting that week, and the beginning of my term as the Unaffiliated NARALO Member Representative at the close of that Board meeting. Eric Brunner-Williams Ithaca, New York

1 1

Re: [NA-Discuss] Request to have a Fast Track PDP initiated
by Danny Younger Dec. 1, 2010

Dec. 1, 2010

If you'll bear with me, I'd like to continue this discussion just a bit more before I reply individually to the comments and questions that have been put forth so far on this topic. I was fortunate enough to have been a participant in the Washington DC GNSO session that first gave rise to the principles governing the new gTLD process, and as high-level principles should be guiding all of our actions in this matter allow me to call your attention to the very first principle that was articulated by the GNSO: "New generic top-level domains (gTLDs) must be introduced in an orderly, timely and predictable way." An orderly introduction is vital because admittedly ICANN has had serious problems in the past with earlier gTLD rollouts... and if major problems emerged in what amounted to a very limited rollout, then just imagine what could well happen in a rollout of 200 to 500 TLDs. A brief bit of history: As Miriam Sapiro of Summit Strategies noted in her report on the earlier proof-of-concept-TLDs, "the lack of any screening or verification in the .info Sunrise period led to serious abuses, including an unusually high number (43%) of registrations that had to be cancelled or transferred." In that earlier episode a total of 15,172 cases needed to be acted upon by WIPO between December 26, 2001 and August 26, 2002 -- this due to the fact that insufficient scrutiny allowed for an ICANN-Afilias Registry Agreement to be drafted that did not require Afilias to examine the validity of Sunrise registrations. Insufficient scrutiny, the failure to examine all possible loopholes that might be amenable to gaming, is that which allows disaster to happen. If an opportunity can be exploited, we have learned that it most assuredly will be exploited. So, now we need to ask ourselves if the first policy principle articulated by the GNSO is sufficient to deal with the potential host of problems that might emerge... or if that first principle needs to be bolstered with additional policy constructs (so that ICANN staff can have a better set of tools with which to implement/actualize the principle). Can we, in fact, have an orderly and predictable rollout in an environment where no policy on domain name speculation by registrars exists and wherein new cross-ownership circumstances might indeed occasion misbehaviors? Perhaps... If Staff (in its role as the organization's policy-implementor) pays heed to the recent Board call for "additional enforcement mechanisms", and actually produces mechanisms designed to stave off the type of abuses that we have recently seen, then maybe the GNSO's first principle will be sufficient without the need for additional policy guidance. Unfortunately, however, no such additional mechanisms nor graduated sanctions (also called for by the Board) have appeared in the latest version of the DAG -- so we can't be certain that we can actually trust the ICANN Staff to do the right thing for the community. The at-large might want to have further conversations with ICANN Staff on this point in Cartagena (as policy implementation is supposed to be their baliwick). What we do know for a certainty is the current philosophy of the ICANN Board on this topic. In their latest resolution they stated: "ICANN will have the ability to address possible abuses that may arise out of registry-registrar cross-ownership through the consensus policy process." ... and therein lies our best solution. Rather than crafting a policy on the topic of registrar domain name speculation in the form of an "amendment" to the RAA or as part of a "revised" RAA (which might not be adopted by many registrars until their next renewal cycle some four-to-five years hence), we need to think in terms of drafting the policy as a "consensus policy" initiative which upon adoption by the Board necessarily goes into immediate effect. I understand that some might wonder if it's even possible to arrive at a consensus policy formulation in the face of probable opposition by the registrar community. By way of reminder, consensus is not the same as unanimity. If the remainder of the community agrees that a policy is warranted, then such a policy may indeed go into effect over the objections of a self-interested party. With that said, we are facing a future in which ICANN has publicly committed through its Affirmation "that as it contemplates expanding the top-level domain space, the various issues that are involved will be adequately addressed prior to implementation". We have together recognized an issue that has impacted a ccTLD launch and which could equally impact future gTLD launches, and now we have a duty as members of the ICANN community to see to it that it is "adequately addressed". While several options may be put forth ranging from enhanced Staff implementation efforts to participation in the GNSO's RAA amendment/revision process, we are likely best served by utilizing the tools at our disposal that allow us to place an "issue" in the hands of the GNSO: "An Advisory Committee may raise an issue for policy development by action of such committee to commence the PDP, and transmission of that request to the GNSO Council." If we can narrowly frame the issue and provide short and succinct policy guidance in our request, then I believe that the Policy Development Process can move forward on an expedited or fast-track basis. I look forward to seeing the ALAC once again standing up to defend the user interest, and I look forward to just a bit more discussion to better scope the way forward.

1 0