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

Re: [NA-Discuss] Fwd: [WHOIS-WG] Fwd: Roundup of WHOIS Issues
by Volker Greimann July 23, 2010

July 23, 2010

Dear Garth, dear Evan, thank you Michele, who brought this to my attention. I would like to take the opportunity to set the record straight on some issues as Garth tends to twist and misinterpret words intentionally looking for a breach where there is none. > > -Unresponsive Registrars > > > > As noted above, there are many Registrars who would not disclose their > > Port 43 address. Some have supplied it after we published our report, > > but others remain silent. One Registrar is grumbling that he may sue us > > to get us to stop asking: > > http://forum.icann.org/lists/gnso-vi-feb10/msg02490.html A wonderful example of the word-twisting and reading a statement out of context, Garth. Key-Systems has never hidden its port 43 whois address. In fact, it is listed in _every_ whois query of any one of our domains: Domain Name: KEY-SYSTEMS.NET Registrar: KEY-SYSTEMS GMBH Whois Server: whois.rrpproxy.net Yet Key-Systems is listed as registrar who may be in breach do to possible failure to provide access to a port 43 whois server. We called you on that and showed you that we do provide this service and also make no effort to hide that service. Instead of admitting your error and removing the false listing of Key-Systems from your report when I pointed this out and requested you update your "report", you insisted the report was still correct in all of its claims, even though you were proven wrong. We take any accusation of breach of contract seriously, as such accusations may amount to libellous interference. That is why we considered sueing Knujon, and not to get you to stop asking. Asking questions, based on good research is good and we support that, but publicly making erroneous claims of contractual breach based on the failure to do proper research and failure to correct them upon notification of the error is libel. KnuJon is trying to paint all registrars with the same brush, instead of singling out the actual bad actors, not realizing that this weakens the report as a whole. > In the chat referenced, there's an insinuation claiming you use "sloppy > research methods". I'd like to get that allegation investigated. Is there > anything constructive this guy Volker can offer? Or does he think that > "sloppy" means anything that produces results he doesn't like? I will always accept constructive criticism based on facts. In this case however, the listing of Key-Systems in that section of the KnuJon "report" was based on three things: a) Failure to find a whois service at whois.key-systems.net b) Our failure to answer an email request for that address. c) Failure of Knujon to make even one webbased whois check of any one of our domain names, which would have immediately revealed the address KnuJon was unable to find: whois.rrpproxy.net KnuJon is making false assumptions based on insufficient and inadequate research. That is what I call sloppy. To offer anything constructive for future reports: Look, instead of making assumptions. If you cannot find the whois address at the first place you consider, try to think how else this information may be reachable. > > But the question is: what to do here? Is there any recourse against a > > Registrar who wont answer questions about their contracted obligations? > > They may claim the RAA requires them to have a Port 43 address but does > > not require them to tell anyone. Interesting point. We answer this question with every whois check done, as shown above. Should we then be required to answer each and every mail requesting information that is already openly available? Contractually, we are not. We are merely required to provide the service (which we do) in a way that it can be found and used (which we do). Accusing us of "not telling anyone" is ludicrous, as this services address is provided with any webbased whois check. One thing I have learned from this debate is that KnuJon will always be the first to publicly accuse others of any perceived breach to further their interest, but will never admit to an own error. As to the other point in the report, confusing prices, I still am not sure of what that means. Everywhere our customers can actually buy domain names from us we have a clear chart of prices available. If you find anything confusing, be specific so we can improve. -- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email:vgreimann@key-systems.net Web:www.key-systems.net /www.RRPproxy.net www.domaindiscount24.com /www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.key-systems.net/facebook www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 1861 - Zweibruecken V.A.T. ID.: DE211006534 This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.

3 3

Re: [NA-Discuss] List moderation
by Garth Bruen at KnujOn July 23, 2010

July 23, 2010

Thanks Evan, wasn't seeking to remove him, just seemed curious > -------- Original Message -------- > Subject: Re: [NA-Discuss] List moderation > From: Evan Leibovitch <evan(a)telly.org> > Date: Fri, July 23, 2010 12:53 pm > To: Garth Bruen at KnujOn <gbruen(a)knujon.com> > Cc: na-discuss(a)atlarge-lists.icann.org, staff(a)atlarge.icann.org > > > Hi Garth, > > I noticed my recent response to Volker was blocked, but his emails still > > come through on the list. As far as I can tell Volker is neither in > > North America nor is he part of At-Large. > > > > > To my knowledge your reply was not blocked. I certainly was able to read it. > > As for Volker's participation on NA-Discuss, this is an open mailing list. > We do not moderate subscription requests, by design. > > While Volker may not qualify as a North American member of At-Large (for the > purpose of NARALO voting or consensus building), I don't see a reason he > should not be afforded the same ability to participate as others. If there > is abuse I will deal with it at that time. > > (Of course a reciprocal level of openness has been denied us by the > registrars, but I won't be guided by their standards.) > > - Evan

1 0

Re: [NA-Discuss] List moderation
by Garth Bruen at KnujOn July 23, 2010

July 23, 2010

Thanks Heidi. Can I subscribe to the Registrar lists? > -------- Original Message -------- > Subject: RE: List moderation > From: Heidi Ullrich <Heidi.Ullrich(a)icann.org> > Date: Fri, July 23, 2010 12:48 pm > To: Garth Bruen at KnujOn <gbruen(a)knujon.com>, > "na-discuss(a)atlarge-lists.icann.org" > <na-discuss(a)atlarge-lists.icann.org> > Cc: ICANN At-Large Staff <staff(a)atlarge.icann.org> > > > Hi Garth, > > > > Your message has been released. It was held due to too many recipients. However, given that the ceiling of recipients is five and your message only had four, we are following up with our mailing list host. > > > > The NA-Discuss list is an open, public mailing list. Anyone can subscribe to it. Volker subscribed earlier today. > > > > Kind regards, > > Heidi > > > > -----Original Message----- > > From: Garth Bruen at KnujOn [mailto:gbruen@knujon.com] > > Sent: Friday, July 23, 2010 9:15 AM > > To: na-discuss(a)atlarge-lists.icann.org > > Cc: ICANN At-Large Staff > > Subject: List moderation > > > > Folks, > > > > I noticed my recent response to Volker was blocked, but his emails still > > come through on the list. As far as I can tell Volker is neither in > > North America nor is he part of At-Large. > > > > -Garth

1 0

Re: [NA-Discuss] Fwd: [WHOIS-WG] Fwd: Roundup of WHOIS Issues
by Garth Bruen at KnujOn July 23, 2010

July 23, 2010

Dear Volker, Dear Evan, Thank you Volker, who brought this to my attention. I would like to take the opportunity to set the record straight on some issues as Volker tends to twist and misinterpret words intentionally looking for a argument where there is none. <<A wonderful example of the word-twisting and reading a statement out of context, Garth.>> Volker, this is your quote: "still thinking if suing them is the best way or not" (http://forum.icann.org/lists/gnso-vi-feb10/msg02490.html) You don't like what we have to say, so you want to sue us to stop it. Where did I twist? This is an act of intimidation, that follows a pattern of Registrars trying to intimidate us. <<We take any accusation of breach of contract seriously, as such accusations may amount to libellous[sic] interference.>> Volker, the document reads: "Registrars in Potential Breach with Relevant RAA Section" -POTENTIAL- Also reads: "The following 55 Registrars did not respond to our inquiry about their Port 43 WHOIS" Do you dispute this fact? Also reads: "Key-Systems GmbH (key-systems.net) – Reporter commented that fee policies were not clear" We asked a consumer to review your site and this was their response. <<a) Failure to find a whois service at whois.key-systems.net>> Wrong. We never failed to find it, you failed to answer a question about it. All of the comments that follow that are speculation on your part. We asked what the address was, you never responded. We sent you the actual email and you won't concede you failed to answer. That's all sloppiness on your side, not mine. We already knew where your port 43 is and we told you this, that's not the issue. The issue is that you wouldn't answer a question about it. Now you are a being dishonest about a previous conversation. <<Should we then be required to answer each and every mail requesting information that is already openly available?>> Well, yes. That's what a responsible company would do. It's not openly available if it is (1) not posted publicly on your website and (2) you fail to answer a question about it. You are expecting someone to hunt and peck for your port 43 location, which they would only find if they had one of your illicit pharmacy sites to query like smartsshealth[dot]com or healthinsurancecapsule[DOT]net which "looks" suspended by Key-Systems but actually redirects to bestpillsroom[dot]com, or mybuymeds[DOT]com, or paypill[DOT]net, or any of the other sites backed by organzied crime you sponsor that we told you about previously. I'll make a deal with you Volker. I'll issue a bleeding apology on this thread if you take a pledge not to sponsor any more GlavMed pharmacy domains. <<If you find anything confusing, be specific so we can improve.>> Sure, don't bury the information five-levels deep on your website. -Garth > -------- Original Message -------- > Subject: Re: Fwd: [WHOIS-WG] Fwd: Roundup of WHOIS Issues > From: Volker Greimann <vgreimann(a)key-systems.net> > Date: Fri, July 23, 2010 6:53 am > To: na-discuss(a)atlarge-lists.icann.org, gbruen(a)knujon.com, > evan(a)telly.org > Cc: Michele(a)mail.key-systems.net, > "Neylon:"@mail.key-systems.net:Blacknight <michele(a)blacknight.ie> > > > Dear Garth, dear Evan, > > thank you Michele, who brought this to my attention. > > I would like to take the opportunity to set the record straight on some > issues as Garth tends to twist and misinterpret words intentionally > looking for a breach where there is none. > > > -Unresponsive Registrars > > > > > > As noted above, there are many Registrars who would not disclose their > > > Port 43 address. Some have supplied it after we published our report, > > > but others remain silent. One Registrar is grumbling that he may sue us > > > to get us to stop asking: > > > http://forum.icann.org/lists/gnso-vi-feb10/msg02490.html > A wonderful example of the word-twisting and reading a statement out of > context, Garth. Key-Systems has never hidden its port 43 whois address. > In fact, it is listed in _every_ whois query of any one of our domains: > > Domain Name: KEY-SYSTEMS.NET > Registrar: KEY-SYSTEMS GMBH > Whois Server: whois.rrpproxy.net > > Yet Key-Systems is listed as registrar who may be in breach do to > possible failure to provide access to a port 43 whois server. We called > you on that and showed you that we do provide this service and also make > no effort to hide that service. Instead of admitting your error and > removing the false listing of Key-Systems from your report when I > pointed this out and requested you update your "report", you insisted > the report was still correct in all of its claims, even though you were > proven wrong. > > We take any accusation of breach of contract seriously, as such > accusations may amount to libellous interference. That is why we > considered sueing Knujon, and not to get you to stop asking. Asking > questions, based on good research is good and we support that, but > publicly making erroneous claims of contractual breach based on the > failure to do proper research and failure to correct them upon > notification of the error is libel. KnuJon is trying to paint all > registrars with the same brush, instead of singling out the actual bad > actors, not realizing that this weakens the report as a whole. > > In the chat referenced, there's an insinuation claiming you use "sloppy > > research methods". I'd like to get that allegation investigated. Is there > > anything constructive this guy Volker can offer? Or does he think that > > "sloppy" means anything that produces results he doesn't like? > I will always accept constructive criticism based on facts. In this case > however, the listing of Key-Systems in that section of the KnuJon > "report" was based on three things: > a) Failure to find a whois service at whois.key-systems.net > b) Our failure to answer an email request for that address. > c) Failure of Knujon to make even one webbased whois check of any one > of our domain names, which would have immediately revealed the address > KnuJon was unable to find: whois.rrpproxy.net > KnuJon is making false assumptions based on insufficient and inadequate > research. That is what I call sloppy. > To offer anything constructive for future reports: Look, instead of > making assumptions. If you cannot find the whois address at the first > place you consider, try to think how else this information may be reachable. > > > > But the question is: what to do here? Is there any recourse against a > > > Registrar who wont answer questions about their contracted obligations? > > > They may claim the RAA requires them to have a Port 43 address but does > > > not require them to tell anyone. > Interesting point. We answer this question with every whois check done, > as shown above. Should we then be required to answer each and every mail > requesting information that is already openly available? Contractually, > we are not. We are merely required to provide the service (which we do) > in a way that it can be found and used (which we do). Accusing us of > "not telling anyone" is ludicrous, as this services address is provided > with any webbased whois check. > > One thing I have learned from this debate is that KnuJon will always be > the first to publicly accuse others of any perceived breach to further > their interest, but will never admit to an own error. > > As to the other point in the report, confusing prices, I still am not > sure of what that means. Everywhere our customers can actually buy > domain names from us we have a clear chart of prices available. If you > find anything confusing, be specific so we can improve. > > -- > > Should you have any further questions, please do not hesitate to contact us. > > Best regards, > > Volker A. Greimann > - legal department - > > Key-Systems GmbH > Im Oberen Werk 1 > 66386 St. Ingbert > Tel.: +49 (0) 6894 - 9396 901 > Fax.: +49 (0) 6894 - 9396 851 > Email: vgreimann(a)key-systems.net > > Web: www.key-systems.net / www.RRPproxy.net > www.domaindiscount24.com / www.BrandShelter.com > > Follow us on Twitter or join our fan community on Facebook and stay updated: > www.key-systems.net/facebook > www.twitter.com/key_systems > > CEO: Alexander Siffrin > Registration No.: HR B 1861 - Zweibruecken > V.A.T. ID.: DE211006534 > > This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.

2 1

ALAC board position selection process and Danny Younger
by Beau Brendler July 23, 2010

July 23, 2010

greetings...I got an urgent call from Danny Younger today. Or at least he thought it was urgent. He is concerned about some facet of the approval process for the ALAC board position that I am not familiar with, having to do with the board approving (or failing to approve, if I remember correctly) the position announcement? I told him I did not have familiarity with that process but that others within NA-RALO might, and that I would ask someone to get in touch. If anyone would like to follow up with Danny on this, e-mail me off-list and I will give you his phone number if you don't have it. Thanks Beau -----Original Message----- >From: Garth Bruen at KnujOn <gbruen(a)knujon.com> >Sent: Jul 22, 2010 10:35 AM >To: Stacy Burnette <stacy.burnette(a)icann.org> >Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, "na-discuss(a)atlarge-lists.icann.org" <na-discuss(a)atlarge-lists.icann.org> >Subject: Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed? > >Stacy, > >Thank you for the policy verification. > >-Garth > > > >> -------- Original Message -------- >> Subject: RE: A Technology Company cured all breaches? Termination >> reversed? >> From: Stacy Burnette <stacy.burnette(a)icann.org> >> Date: Tue, July 20, 2010 9:07 pm >> To: Garth Bruen at KnujOn <gbruen(a)knujon.com> >> Cc: "na-discuss(a)atlarge-lists.icann.org" >> <na-discuss(a)atlarge-lists.icann.org>, "langdonorr(a)gmail.com" >> <langdonorr(a)gmail.com>, "carlton.samuels(a)gmail.com" >> <carlton.samuels(a)gmail.com>, "evan(a)telly.org" <evan(a)telly.org> >> >> >> Garth: >> >> >> >> ICANN appreciates your interest in ICANN’s compliance program. I hope the responses below assist you in understanding the facts concerning A Technology Company and how ICANN addresses various compliance matters. It is our aim to work constructively with you and others and consider all reasonable suggestions provided by the community to enhance our compliance program. >> >> >> >> Our goal is bringing registrars into compliance with their obligations. Although the transmission of enforcement notices is part of ICANN’s normal escalation process, we often attempt to resolve compliance matters informally. To that end, we send compliance notices via e-mail (and sometimes via fax) or we attempt to contact registrars via telephone to inform them that non-compliance issues need to be addressed within a specific timeframe. In most cases, registrars take corrective action after receiving our informal communications, thus avoiding the need for escalated compliance action by ICANN. >> >> >> >> I have embedded responses to your questions below. >> >> >> >> If you believe a telephone conversation would be helpful, I would be happy to schedule a mutually convenient time to discuss these matters. Please let me know. >> >> >> >> Best, >> >> >> >> Stacy Burnette >> >> Director >> >> Contractual Compliance >> >> ICANN >> >> 4676 Admiralty Way >> >> Suite 330 >> >> Marina del Rey, CA 90292 >> >> +1(310) 301-3860 >> >> >> >> -----Original Message----- >> >> From: Garth Bruen at KnujOn [mailto:gbruen@knujon.com] >> >> Sent: Tuesday, July 20, 2010 7:29 AM >> >> To: Stacy Burnette >> >> Cc: na-discuss(a)atlarge-lists.icann.org; langdonorr(a)gmail.com; carlton.samuels(a)gmail.com; evan(a)telly.org >> >> Subject: RE: A Technology Company cured all breaches? Termination reversed? >> >> >> >> Stacy, >> >> >> >> I have noted that the two issues concerning A Technology Co. have been >> >> technically corrected. Thank you. However, I have some questions about >> >> the timeline and circumstances of their re-accreditation. In reading the >> >> non-renewal notice dated June 25 I'm finding some issues. >> >> >> >> First, according to the notice A Technology Co. was issued breach >> >> notices on April 29 and May 26 but these notices are not posted along >> >> with other breach notices at http://www.icann.org/en/compliance/. >> >> >> >> RESPONSE: A Technology Company received breach notices based on failure to pay ICANN fees. Financial breach notices are not posted on our website. >> >> >> >> Next, it seems that if breach notices were issued on April 29 and May 26 >> >> the time to cure would end either on May 14th or June 10th(as indicated >> >> in the letter). They were allowed to cure on June 30th which is 47 days >> >> after the first deadline and 20 days after the second deadline. >> >> >> >> RESPONSE: While compliance activities generally work through a well-defined process at ICANN, a number of factors need to be considered when determining the next appropriate course of action and therefore timeframes for proceeding with escalated compliance actions may vary. >> >> >> >> Next, while the posting of their contact address is a matter of the 2009 >> >> RAA, WHOIS issues are a matter of their old contract. Why were they not >> >> issued a breach notice on the manipulation of their WHOIS record the >> >> week of June 21st when we filed our complaint about it? >> >> >> >> RESPONSE: As stated above, ICANN often attempts to resolve non-compliance issues informally before sending a notice of breach. >> >> >> >> Finally, for the two issues we raised with you about their address >> >> posting and WHOIS record you apparently "told" them to fix these. I'm >> >> concerned about how frequently Registrars are told to fix contract >> >> issues without public documentation. >> >> >> >> RESPONSE: Informal notices requesting that registrars take corrective action are effective, as they often result in registrars taking corrective action quickly. >> >> >> >> >> >> >> >> -----Original Message----- >> >> From: Garth Bruen at KnujOn [mailto:gbruen@knujon.com] >> >> Sent: Tuesday, July 20, 2010 7:29 AM >> >> To: Stacy Burnette >> >> Cc: na-discuss(a)atlarge-lists.icann.org; langdonorr(a)gmail.com; carlton.samuels(a)gmail.com; evan(a)telly.org >> >> Subject: RE: A Technology Company cured all breaches? Termination reversed? >> >> >> >> Stacy, >> >> >> >> I have noted that the two issues concerning A Technology Co. have been >> >> technically corrected. Thank you. However, I have some questions about >> >> the timeline and circumstances of their re-accreditation. In reading the >> >> non-renewal notice dated June 25 I'm finding some issues. >> >> >> >> First, according to the notice A Technology Co. was issued breach >> >> notices on April 29 and May 26 but these notices are not posted along >> >> with other breach notices at http://www.icann.org/en/compliance/. >> >> >> >> Next, it seems that if breach notices were issued on April 29 and May 26 >> >> the time to cure would end either on May 14th or June 10th(as indicated >> >> in the letter). They were allowed to cure on June 30th which is 47 days >> >> after the first deadline and 20 days after the second deadline. >> >> >> >> Next, while the posting of their contact address is a matter of the 2009 >> >> RAA, WHOIS issues are a matter of their old contract. Why were they not >> >> issued a breach notice on the manipulation of their WHOIS record the >> >> week of June 21st when we filed our complaint about it? >> >> >> >> Finally, for the two issues we raised with you about their address >> >> posting and WHOIS record you apparently "told" them to fix these. I'm >> >> concerned about how frequently Registrars are told to fix contract >> >> issues without public documentation. >> >> >> >> Thank you for your attention to this. >> >> >> >> -Garth >> >> >> >> >> >> >> >> > -------- Original Message -------- >> >> > Subject: RE: A Technology Company cured all breaches? Termination >> >> > reversed? >> >> > From: Stacy Burnette <stacy.burnette(a)icann.org> >> >> > Date: Wed, July 14, 2010 1:06 pm >> >> > To: Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn >> >> > <gbruen(a)knujon.com> >> >> > Cc: "na-discuss(a)atlarge-lists.icann.org" >> >> > <na-discuss(a)atlarge-lists.icann.org>, David Giza <David.Giza(a)icann.org>, >> >> > "langdonorr(a)gmail.com" <langdonorr(a)gmail.com>, >> >> > "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, >> >> > "evan(a)telly.org" <evan(a)telly.org> >> >> > >> >> > >> >> > Dear Garth and Bob: >> >> > >> >> > Thanks for your comments. This registrar recently signed the 2009 RAA, effective 13 July 2010, which includes a "new" requirement that the registrar post a valid address on its website. The registrar was informed of this requirement and advised to make the adjustments to its website ASAP. >> >> > >> >> > ICANN is reviewing the Whois related complaint you mentioned below and we are in communication with the registrar about the matter. >> >> > >> >> > We appreciate your interest in making sure registrars comply with the terms of the RAA and we hope that you will continue to work collaboratively with us in the future. Working together with the community has enhanced ICANN's effort to address registrar non-compliance in several areas, such as the UDRP, Whois related provisions and Registrar Data Escrow. Please see our website for details regarding our escalated compliance actions http://www.icann.org/en/compliance/. >> >> > >> >> > >> >> > Sincerely, >> >> > >> >> > Stacy Burnette >> >> > Director >> >> > Contractual Compliance >> >> > ICANN >> >> > 4676 Admiralty Way >> >> > Suite 330 >> >> > Marina del Rey, CA 90292 >> >> > +1(310) 301-3860 >> >> > >> >> > >> >> > -----Original Message----- >> >> > From: Bob Bruen [mailto:bruen@coldrain.net] >> >> > Sent: Wednesday, July 14, 2010 8:36 AM >> >> > To: Garth Bruen at KnujOn >> >> > Cc: na-discuss(a)atlarge-lists.icann.org; David Giza; langdonorr(a)gmail.com; carlton.samuels(a)gmail.com; evan(a)telly.org; Stacy Burnette >> >> > Subject: Re: A Technology Company cured all breaches? Termination reversed? >> >> > >> >> > >> >> > They must have paid off their outstanding biils. The loss of accreditation >> >> > was for not paying their bills, not for any other failure under the RAA. >> >> > This offers up evidence for what ICANN believes is important: money, not >> >> > good behavior. It's very sad. >> >> > >> >> > --bob >> >> > >> >> > On Wed, 14 Jul 2010, Garth Bruen at KnujOn wrote: >> >> > >> >> > > Hello all, >> >> > > >> >> > > To my chagrin I just read that that A Technology Company's termination >> >> > > was reversed and their accreditation renewed under the new 2009 RAA. >> >> > > (http://www.icann.org/en/compliance/#updates) >> >> > > >> >> > > "13 July 2010: A Technology Company, Inc. cured all outstanding contract >> >> > > breaches as of 30 June 2010. A Technology Company, Inc.'s accreditation >> >> > > was renewed on 13 July 2010." >> >> > > >> >> > > >> >> > > I'm very confused by this for two specific reasons: >> >> > > >> >> > > 1. A Technology Company does not post their mailing address on their >> >> > > website as required by the 2009 RAA in section 3.16 >> >> > > >> >> > > The address is not on their home page, contact us, FAQ, company info, >> >> > > about us, or in any of their agreement or legal documents. >> >> > > >> >> > > AND >> >> > > >> >> > > 2. They have been manipulating their own WHOIS record in the web and >> >> > > Port 43. >> >> > > >> >> > > Trying to get the record returns one of these statements: >> >> > > >> >> > > "Sorry, Domainname does not exists in our DB" - From A Technology >> >> > > Company own web WHOIS at https://www.namesystem.com/website/whois.jsp >> >> > > >> >> > >> From Port 43: >> >> > > "Checking server [whois.namesystem.com] >> >> > > Results: >> >> > > Sorry, Domain does not exist in the null system." >> >> > > >> >> > > However, "NameSystem" is the Registrar for "namesystem.com", see >> >> > > http://reports.internic.net/cgi/whois?whois_nic=namesystem.com&type=domain, >> >> > > which means what? They are manipulating the search. >> >> > > >> >> > > >> >> > > A Technology Company has deeply obfuscated themselves. Even the Better >> >> > > Business Bureau says "Company Cannot Be Located" when trying to resolve >> >> > > consumer disputes! >> >> > > >> >> > > This case would make it seem that as long as a Registrar pays the bills, >> >> > > everything else is permissible. >> >> > > >> >> > > >> >> > > I'm shocked. >> >> > > >> >> > > -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 >> >> > > >> >> > > >> >> > >> >> > -- >> >> > Dr. Robert Bruen >> >> > Knujon >> >> > http://knujon.com >> >> > http://coldrain.net/bruen >> >> > +1.802.579.6288 > > >------ >NA-Discuss mailing list >NA-Discuss(a)atlarge-lists.icann.org >http://atlarge-lists.icann.org/mailman/listinfo/na-discuss_atlarge-lists.ic… > >Visit the NARALO online at http://www.naralo.org >------

5 7

Re: [NA-Discuss] [governance] Fwd: [] CALL FOR STATEMENTS OF INTEREST: ALAC-selected
by Cheryl Langdon-Orr July 23, 2010

July 23, 2010

Karl we have specifically discussed this and taken the advice of ICANN Legal Council and the SIC so we (At-Large) are proceeding in a manner that will allow us to meet our planned time table and the recent resolution of the Board... so again as happens from time to time this is one of those points where we will just have to "agree to Disagree" with each other... Cheryl Langdon-Orr (CLO) On 23 July 2010 19:14, Karl Auerbach <karl(a)cavebear.com> wrote: > On 07/22/2010 06:34 PM, Cheryl Langdon-Orr wrote: > >> Hi Karl and list, inserted below is (part) of an email I sent on this >> matter to the NARALO list from a question raised by Avri on the matter >> of approved processes... I trust these links will assist you re >> background on this... >> > > All of the materials are "draft" of "preliminary". Indeed even a proposed > bylaw amendment is still open for comment. > > One usually discovers that it is unwise to pour concrete before the > architectural design is established. > > In other words it is premature to start gathering names. > > In addition the proposed methods are in conflict with our recommendations > in the board-level review of the at-large that the process for the public to > chose its ICANN director(s) reach far beyond the bounds of the ALAC to > encompass potentially any interested person affected by the internet whether > or not that person chooses to participate in any ALAC body or sub-body. > > As it stands it appears that what is being created is a YANC - Yet Another > Nominating Committee. In which case an appropriate question would be "why > bother?" > > Which brings to mind MacBeth's metaphor upon hearing of the death of his > wife: have all of our years of effort to give the community of internet > users a real voice within ICANN come to be nothing more than "a tale told by > an idiot, full of sound and fury, signifying nothing"? > > --karl-- > >

1 0

Online Survey on "Meetings for the Next Decade"
by ICANN At-Large Staff July 23, 2010

July 23, 2010

Dear All, ICANN’s meetings department launched an online survey as part of their public consultation on how to improve ICANN’s international conferences in the coming years. Members of the At-Large community members are invited to participate in this online survey under: https://www.bigpulse.com/33025/register?l=en You can find the complete information on this consultation under http://icann.org/en/meetings2010/ -- Regards, Heidi Ullrich, Matthias Langenegger, Seth Greene, Gisella Gruber-White, Marilyn Vernon, Kristina Nordström ICANN At-Large Staff email: staff[at]atlarge.icann.org website: www.atlarge.icann.org

1 0

Re: [NA-Discuss] ALAC board position selection process and Danny Younger
by Alan Greenberg July 22, 2010

July 22, 2010

I got one also. He was concerned that we were starting the process without due process and without an opportunity for the community to comment on the process. I assured him that this was being monitored by two Board committees, that ICANN legal counsel had been involved, and that there was a full public comment period (on the White Paper which outlined the process that we are using). For the record, if I remember correctly, we have approval to proceed up until the actual election. Holding the election should not happen until the new Bylaws are in place. Of course, there is always the chance that the Board will decide to rethink the whole thing or alter our process, but the chances are not thought to be high, and if it happens, we have no control over it. Alan At 22/07/2010 04:00 PM, Beau Brendler wrote: >greetings...I got an urgent call from Danny >Younger today. Or at least he thought it was >urgent. He is concerned about some facet of the >approval process for the ALAC board position >that I am not familiar with, having to do with >the board approving (or failing to approve, if I >remember correctly) the position announcement? I >told him I did not have familiarity with that >process but that others within NA-RALO might, >and that I would ask someone to get in touch. If >anyone would like to follow up with Danny on >this, e-mail me off-list and I will give you his >phone number if you don't have it. > >Thanks > >Beau > > > >-----Original Message----- > >From: Garth Bruen at KnujOn <gbruen(a)knujon.com> > >Sent: Jul 22, 2010 10:35 AM > >To: Stacy Burnette <stacy.burnette(a)icann.org> > >Cc: "carlton.samuels(a)gmail.com" > <carlton.samuels(a)gmail.com>, > "na-discuss(a)atlarge-lists.icann.org" <na-discuss(a)atlarge-lists.icann.org> > >Subject: Re: [NA-Discuss] A Technology Company > cured all breaches? Termination reversed? > > > >Stacy, > > > >Thank you for the policy verification. > > > >-Garth > > > > > > > >> -------- Original Message -------- > >> Subject: RE: A Technology Company cured all breaches? Termination > >> reversed? > >> From: Stacy Burnette <stacy.burnette(a)icann.org> > >> Date: Tue, July 20, 2010 9:07 pm > >> To: Garth Bruen at KnujOn <gbruen(a)knujon.com> > >> Cc: "na-discuss(a)atlarge-lists.icann.org" > >> <na-discuss(a)atlarge-lists.icann.org>, "langdonorr(a)gmail.com" > >> <langdonorr(a)gmail.com>, "carlton.samuels(a)gmail.com" > >> <carlton.samuels(a)gmail.com>, "evan(a)telly.org" <evan(a)telly.org> > >> > >> > >> Garth: > >> > >> > >> > >> ICANN appreciates your interest in ICANNâs > compliance program. I hope the responses below > assist you in understanding the facts > concerning A Technology Company and how ICANN > addresses various compliance matters. It is > our aim to work constructively with you and > others and consider all reasonable suggestions > provided by the community to enhance our compliance program. > >> > >> > >> > >> Our goal is bringing registrars into > compliance with their obligations. Although the > transmission of enforcement notices is part of > ICANNâs normal escalation process, we often > attempt to resolve compliance matters > informally. To that end, we send compliance > notices via e-mail (and sometimes via fax) or > we attempt to contact registrars via telephone > to inform them that non-compliance issues need > to be addressed within a specific > timeframe. In most cases, registrars take > corrective action after receiving our informal > communications, thus avoiding the need for > escalated compliance action by ICANN. > >> > >> > >> > >> I have embedded responses to your questions below. > >> > >> > >> > >> If you believe a telephone conversation > would be helpful, I would be happy to schedule > a mutually convenient time to discuss these matters. Please let me know. > >> > >> > >> > >> Best, > >> > >> > >> > >> Stacy Burnette > >> > >> Director > >> > >> Contractual Compliance > >> > >> ICANN > >> > >> 4676 Admiralty Way > >> > >> Suite 330 > >> > >> Marina del Rey, CA 90292 > >> > >> +1(310) 301-3860 > >> > >> > >> > >> -----Original Message----- > >> > >> From: Garth Bruen at KnujOn [mailto:gbruen@knujon.com] > >> > >> Sent: Tuesday, July 20, 2010 7:29 AM > >> > >> To: Stacy Burnette > >> > >> Cc: na-discuss(a)atlarge-lists.icann.org; > langdonorr(a)gmail.com; carlton.samuels(a)gmail.com; evan(a)telly.org > >> > >> Subject: RE: A Technology Company cured all > breaches? Termination reversed? > >> > >> > >> > >> Stacy, > >> > >> > >> > >> I have noted that the two issues concerning A Technology Co. have been > >> > >> technically corrected. Thank you. However, I have some questions about > >> > >> the timeline and circumstances of their re-accreditation. In reading the > >> > >> non-renewal notice dated June 25 I'm finding some issues. > >> > >> > >> > >> First, according to the notice A Technology Co. was issued breach > >> > >> notices on April 29 and May 26 but these notices are not posted along > >> > >> with other breach notices at http://www.icann.org/en/compliance/. > >> > >> > >> > >> RESPONSE: A Technology Company received > breach notices based on failure to pay ICANN > fees. Financial breach notices are not posted on our website. > >> > >> > >> > >> Next, it seems that if breach notices were issued on April 29 and May 26 > >> > >> the time to cure would end either on May 14th or June 10th(as indicated > >> > >> in the letter). They were allowed to cure on June 30th which is 47 days > >> > >> after the first deadline and 20 days after the second deadline. > >> > >> > >> > >> RESPONSE: While compliance activities > generally work through a well-defined process > at ICANN, a number of factors need to be > considered when determining the next > appropriate course of action and therefore > timeframes for proceeding with escalated compliance actions may vary. > >> > >> > >> > >> Next, while the posting of their contact address is a matter of the 2009 > >> > >> RAA, WHOIS issues are a matter of their old contract. Why were they not > >> > >> issued a breach notice on the manipulation of their WHOIS record the > >> > >> week of June 21st when we filed our complaint about it? > >> > >> > >> > >> RESPONSE: As stated above, ICANN often > attempts to resolve non-compliance issues > informally before sending a notice of breach. > >> > >> > >> > >> Finally, for the two issues we raised with you about their address > >> > >> posting and WHOIS record you apparently "told" them to fix these. I'm > >> > >> concerned about how frequently Registrars are told to fix contract > >> > >> issues without public documentation. > >> > >> > >> > >> RESPONSE: Informal notices requesting that > registrars take corrective action are > effective, as they often result in registrars taking corrective action quickly. > >> > >> > >> > >> > >> > >> > >> > >> -----Original Message----- > >> > >> From: Garth Bruen at KnujOn [mailto:gbruen@knujon.com] > >> > >> Sent: Tuesday, July 20, 2010 7:29 AM > >> > >> To: Stacy Burnette > >> > >> Cc: na-discuss(a)atlarge-lists.icann.org; > langdonorr(a)gmail.com; carlton.samuels(a)gmail.com; evan(a)telly.org > >> > >> Subject: RE: A Technology Company cured all > breaches? Termination reversed? > >> > >> > >> > >> Stacy, > >> > >> > >> > >> I have noted that the two issues concerning A Technology Co. have been > >> > >> technically corrected. Thank you. However, I have some questions about > >> > >> the timeline and circumstances of their re-accreditation. In reading the > >> > >> non-renewal notice dated June 25 I'm finding some issues. > >> > >> > >> > >> First, according to the notice A Technology Co. was issued breach > >> > >> notices on April 29 and May 26 but these notices are not posted along > >> > >> with other breach notices at http://www.icann.org/en/compliance/. > >> > >> > >> > >> Next, it seems that if breach notices were issued on April 29 and May 26 > >> > >> the time to cure would end either on May 14th or June 10th(as indicated > >> > >> in the letter). They were allowed to cure on June 30th which is 47 days > >> > >> after the first deadline and 20 days after the second deadline. > >> > >> > >> > >> Next, while the posting of their contact address is a matter of the 2009 > >> > >> RAA, WHOIS issues are a matter of their old contract. Why were they not > >> > >> issued a breach notice on the manipulation of their WHOIS record the > >> > >> week of June 21st when we filed our complaint about it? > >> > >> > >> > >> Finally, for the two issues we raised with you about their address > >> > >> posting and WHOIS record you apparently "told" them to fix these. I'm > >> > >> concerned about how frequently Registrars are told to fix contract > >> > >> issues without public documentation. > >> > >> > >> > >> Thank you for your attention to this. > >> > >> > >> > >> -Garth > >> > >> > >> > >> > >> > >> > >> > >> > -------- Original Message -------- > >> > >> > Subject: RE: A Technology Company cured all breaches? Termination > >> > >> > reversed? > >> > >> > From: Stacy Burnette <stacy.burnette(a)icann.org> > >> > >> > Date: Wed, July 14, 2010 1:06 pm > >> > >> > To: Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn > >> > >> > <gbruen(a)knujon.com> > >> > >> > Cc: "na-discuss(a)atlarge-lists.icann.org" > >> > >> > <na-discuss(a)atlarge-lists.icann.org>, David Giza <David.Giza(a)icann.org>, > >> > >> > "langdonorr(a)gmail.com" <langdonorr(a)gmail.com>, > >> > >> > "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, > >> > >> > "evan(a)telly.org" <evan(a)telly.org> > >> > >> > > >> > >> > > >> > >> > Dear Garth and Bob: > >> > >> > > >> > >> > Thanks for your comments. This registrar > recently signed the 2009 RAA, effective 13 July > 2010, which includes a "new" requirement that > the registrar post a valid address on its > website. The registrar was informed of this > requirement and advised to make the adjustments to its website ASAP. > >> > >> > > >> > >> > ICANN is reviewing the Whois related > complaint you mentioned below and we are in > communication with the registrar about the matter. > >> > >> > > >> > >> > We appreciate your interest in making sure > registrars comply with the terms of the RAA and > we hope that you will continue to work > collaboratively with us in the future. Working > together with the community has enhanced > ICANN's effort to address registrar > non-compliance in several areas, such as the > UDRP, Whois related provisions and Registrar > Data Escrow. Please see our website for > details regarding our escalated compliance > actions http://www.icann.org/en/compliance/. > >> > >> > > >> > >> > > >> > >> > Sincerely, > >> > >> > > >> > >> > Stacy Burnette > >> > >> > Director > >> > >> > Contractual Compliance > >> > >> > ICANN > >> > >> > 4676 Admiralty Way > >> > >> > Suite 330 > >> > >> > Marina del Rey, CA 90292 > >> > >> > +1(310) 301-3860 > >> > >> > > >> > >> > > >> > >> > -----Original Message----- > >> > >> > From: Bob Bruen [mailto:bruen@coldrain.net] > >> > >> > Sent: Wednesday, July 14, 2010 8:36 AM > >> > >> > To: Garth Bruen at KnujOn > >> > >> > Cc: na-discuss(a)atlarge-lists.icann.org; > David Giza; langdonorr(a)gmail.com; > carlton.samuels(a)gmail.com; evan(a)telly.org; Stacy Burnette > >> > >> > Subject: Re: A Technology Company cured > all breaches? Termination reversed? > >> > >> > > >> > >> > > >> > >> > They must have paid off their outstanding > biils. The loss of accreditation > >> > >> > was for not paying their bills, not for any other failure under the RAA. > >> > >> > This offers up evidence for what ICANN believes is important: money, not > >> > >> > good behavior. It's very sad. > >> > >> > > >> > >> > --bob > >> > >> > > >> > >> > On Wed, 14 Jul 2010, Garth Bruen at KnujOn wrote: > >> > >> > > >> > >> > > Hello all, > >> > >> > > > >> > >> > > To my chagrin I just read that that A Technology Company's termination > >> > >> > > was reversed and their accreditation renewed under the new 2009 RAA. > >> > >> > > (http://www.icann.org/en/compliance/#updates) > >> > >> > > > >> > >> > > "13 July 2010: A Technology Company, > Inc. cured all outstanding contract > >> > >> > > breaches as of 30 June 2010. A > Technology Company, Inc.'s accreditation > >> > >> > > was renewed on 13 July 2010." > >> > >> > > > >> > >> > > > >> > >> > > I'm very confused by this for two specific reasons: > >> > >> > > > >> > >> > > 1. A Technology Company does not post their mailing address on their > >> > >> > > website as required by the 2009 RAA in section 3.16 > >> > >> > > > >> > >> > > The address is not on their home page, contact us, FAQ, company info, > >> > >> > > about us, or in any of their agreement or legal documents. > >> > >> > > > >> > >> > > AND > >> > >> > > > >> > >> > > 2. They have been manipulating their own WHOIS record in the web and > >> > >> > > Port 43. > >> > >> > > > >> > >> > > Trying to get the record returns one of these statements: > >> > >> > > > >> > >> > > "Sorry, Domainname does not exists in our DB" - From A Technology > >> > >> > > Company own web WHOIS at https://www.namesystem.com/website/whois.jsp > >> > >> > > > >> > >> > >> From Port 43: > >> > >> > > "Checking server [whois.namesystem.com] > >> > >> > > Results: > >> > >> > > Sorry, Domain does not exist in the null system." > >> > >> > > > >> > >> > > However, "NameSystem" is the Registrar for "namesystem.com", see > >> > >> > > > http://reports.internic.net/cgi/whois?whois_nic=namesystem.com&type=domain, > >> > >> > > which means what? They are manipulating the search. > >> > >> > > > >> > >> > > > >> > >> > > A Technology Company has deeply obfuscated themselves. Even the Better > >> > >> > > Business Bureau says "Company Cannot Be > Located" when trying to resolve > >> > >> > > consumer disputes! > >> > >> > > > >> > >> > > This case would make it seem that as > long as a Registrar pays the bills, > >> > >> > > everything else is permissible. > >> > >> > > > >> > >> > > > >> > >> > > I'm shocked. > >> > >> > > > >> > >> > > -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 > >> > >> > > > >> > >> > > > >> > >> > > >> > >> > -- > >> > >> > Dr. Robert Bruen > >> > >> > Knujon > >> > >> > http://knujon.com > >> > >> > http://coldrain.net/bruen > >> > >> > +1.802.579.6288 > > > > > >------ > >NA-Discuss mailing list > >NA-Discuss(a)atlarge-lists.icann.org > >http://atlarge-lists.icann.org/mailman/listinfo > /na-discuss_atlarge-lists.icann.org > > > >Visit the NARALO online at http://www.naralo.org > >------ > > >------ >NA-Discuss mailing list >NA-Discuss(a)atlarge-lists.icann.org >http://atlarge-lists.icann.org/mailman/listinfo/na-discuss_atlarge-lists.ic… > >Visit the NARALO online at http://www.naralo.org >------

1 0

Additional Documents on Vertical Integration
by Matthias Langenegger July 22, 2010

July 22, 2010

Dear All, As agreed during the NARALO Call on Monday, here are some additional documents on Vertical Integration presented during recent ICANN meetings. ICANN Meeting Brussels 2010: During the ALAC Policy Discussion Part 1 ( http://brussels38.icann.org/node/12463) the Chair of the Working Group on Vertical Integration, Mike O’Connor, gave a presentation on the current status of the Vertical Integration PDP. Attached you find: * Presentation on Vertical Integration PDP (.ppt) * Matrix of Vertical Integration Proposal (.xls) * Transcription of Mike’s Presentation (ALAC Policy Discussion Part 1) (.doc) ICANN Meeting Seoul 2009: During the panelist discussion on Registry/Registrar Separation ( http://sel.icann.org/node/7083) Brian Cute and Richard Tindal discussed the advantages and disadvantages of Vertical Integration. * Presentation “The Case for a Registry Owning a Registrar in Its TLD” (download under http://sel.icann.org/meetings/seoul2009/presentation-registry-registrar-own…) * Presentation “The Issue: Vertical Separation of Registry and Registrar Functions” (download under http://sel.icann.org/meetings/seoul2009/presentation-vertical-separation-26…) * Transcription of panelist discussion (download under: http://sel.icann.org/meetings/seoul2009/transcript-registry-registrar-separ…) Best Regards, -- Matthias Langenegger Manager, At-Large Regional Affairs Internet Corporation for Assigned Names and Numbers (ICANN) Email: matthias.langenegger(a)icann.org Main Tel: +41 (79) 644 65 35 Fax: +41 (22) 594 85 44 Skype ID: matthiaslangenegger

2 1

David Giza and Round up of WHOIS issues to be addressed
by Garth Bruen at KnujOn July 22, 2010

July 22, 2010

Folks, I was really hoping to push forward on this with David Giza’s input. His departure may signal a set-back but I’m hoping this is not the case. While I’m determined to get these issues addressed I am open to suggestions as to how to get ICANN compliance moving again on them. In general I think it is imperative that ICANN disclose what happened here with Giza. There are rumors circulating that David was pushed out for saying he didn’t have enough staff or for actually doing his job and enforcing the RAA. If this is true, it represents a serious breach of trust with the community and an undeserved turn for someone trying to do the right thing. But to continue, there are a number of WHOIS-related problems that need addressing, but I’ll start with immediate ones brought up in Brussels and situations that have surfaced recently. -Info and utility for At-Large Members: I promised to post a utility and WHOIS address list for all Registrars and all ccTLDs, but I want the list to be as complete as possible before sending it out, and also to supply a location for updates. The remaining Registrars who wont disclose their Port 43 address are delaying the final list, but I’ll get all the information soon. -Unresponsive Registrars As noted above, there are many Registrars who would not disclose their Port 43 address. Some have supplied it after we published our report, but others remain silent. One Registrar is grumbling that he may sue us to get us to stop asking: http://forum.icann.org/lists/gnso-vi-feb10/msg02490.html But the question is: what to do here? Is there any recourse against a Registrar who wont answer questions about their contracted obligations? They may claim the RAA requires them to have a Port 43 address but does not require them to tell anyone. -Problem Port 43 ICANN compliance is not being equal in its dispensing of breach notices. There are Registrars with poor WHOIS access that have not been notified, while others in jeopardy of loosing their accreditation may have better access records. -“Domain Check” As noted, many Registrars do not have a full WHOIS on their website, but rather a look up that merely tells you if the domain is taken, not who owns it. I will ask compliance about these one more time before filing individual complaints against each. -Bulk Purchases of WHOIS, what’s the story? There is much confusion here that needs to be sorted out by compliance. As part of our research we asked the 5 largest Registrars about accessing WHOIS in bulk as required by RAA 3.3.6. eNom, Dotster, and Moniker/Oversee/Snapnames did not respond at all to the request. NameScout said they did not offer the service. Network Solutions also said they did sell access, and then posted publicly that they were not required to (http://www.circleid.com/posts/who_is_blocking_whois_part_2/) which was then quickly retracted, but the main question goes unanswered. -AIT’s Hidden WHOIS Another question that is emerging is the way WHOIS is accessed. In one example AIT “has” a web WHOIS but finding it is a challenge. On their main page they have a “domain lookup” which will tell you if the domain is taken. If you happen to accidentally click on the little red star next to the domain name it will launch a CAPTCHA window, and once you enter the code correctly it will present the WHOIS data. But is this really compliant? -Registrar Complaint Process Unlike the WDPRS system, the complaint interface (http://reports.internic.net/cgi/registrars/problem-report.cgi) for filing a complaint against a Registrar has no ticket, no confirmation email, no time-frame, no feedback, and no official resolution from compliance staff. In fact, to view the brief overview of the process: http://www.icann.org/en/compliance/compliance-flowchart.htm, one will see there is no space for responding to the complainant. The first step in the process is “Investigation or Dismissal” but no where is there feedback for the user as to why the complaint would be dismissed. We have, in fact, never received a response for a complaint filed through this interface. -Garth ------------------------------------- What is the Doomsday Book? http://knujon.com/doomsday 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

3 2