- NA-Discuss - lists.icann.org

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 > >------

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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 > > > >

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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 >------

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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

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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

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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.

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Request to have a Fast Track PDP initiated
by Danny Younger Nov. 30, 2010

Nov. 30, 2010

Dear all, Events that have transpired in the last few days attendant to the launch of .рф have made it clear to me that although we can't deal with the troubling issues that may arise with TLD launches in the ccTLD world, we do have the ability to act to protect the public interest within the gTLD sphere by way of a policy that would govern speculation in domain names by registrars. By way of background, in the recent .рф ccTLD launch an ICANN accredited registrar, RU-Center, decided to register domain names in its own name on a priority basis and only then did it register other domain names. Approximately 24,500 premium domains registered to RU-Center were then put up for auction. The Russian Federal Antimonopoly Service (FAS) then stepped in, shut down the auctions and accused a number of registrars of collusion. What can we learn from this? Simply put... greed in the new TLD launch process can lead to abuse of the public trust, and measures need to be in place to ensure that the public is protected from the ICANN-accredited registrar community. In our gTLD world, there is at the moment no ICANN policy whatsoever governing speculation in, or warehousing of, domains by registrars. Registrars are able to game the system to their own ends however they see fit; this has to change. The current RAA (section 3.7.9) states: "Registrar shall abide by any ICANN adopted specifications or policies prohibiting or restricting warehousing of or speculation in domain names by registrars". As there is no such policy or specification, I suggest that we initiate a PDP to have such a policy created, namely a policy that would state: "No registrar, registrar affiliate, or reseller of registrar services shall engage in warehousing of or speculation in domain names." While I understand that the GNSO soon will broadly be looking at proposed amendments for the RAA, we all know that the GNSO process (if spread over the entirety of the RAA proposed amendments) can take years to arrive at a recommendation... yet with the imminent roll-out of hundreds of new gTLDs, we just don't have the luxury of waiting that long. In my view, what is called for is a Fast Track PDP approach that would focus on a single policy recommendation that could be put in place before any new gTLD is launched. I would ask the NARALO to bring this matter to the immediate attention of the ALAC. Thanks for your consideration of this issue. Danny Younger

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Re: [NA-Discuss] Request to have a Fast Track PDP initiated
by Garth Bruen at KnujOn Nov. 30, 2010

Nov. 30, 2010

Amazing Danny. You have my support. ------------------------------------- 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 > -------- Original Message -------- > Subject: [NA-Discuss] Request to have a Fast Track PDP initiated > From: Danny Younger <dannyyounger(a)yahoo.com> > Date: Mon, November 29, 2010 10:09 pm > To: na-discuss(a)atlarge-lists.icann.org > Cc: discuss(a)lists.isoc-ny.org > > > Dear all, > > Events that have transpired in the last few days attendant to the launch of .рф have made it clear to me that although we can't deal with the troubling issues that may arise with TLD launches in the ccTLD world, we do have the ability to act to protect the public interest within the gTLD sphere by way of a policy that would govern speculation in domain names by registrars. > > By way of background, in the recent .рф ccTLD launch an ICANN accredited registrar, RU-Center, decided to register domain names in its own name on a priority basis and only then did it register other domain names. Approximately 24,500 premium domains registered to RU-Center were then put up for auction. The Russian Federal Antimonopoly Service (FAS) then stepped in, shut down the auctions and accused a number of registrars of collusion. > > What can we learn from this? Simply put... greed in the new TLD launch process can lead to abuse of the public trust, and measures need to be in place to ensure that the public is protected from the ICANN-accredited registrar community. > > In our gTLD world, there is at the moment no ICANN policy whatsoever governing speculation in, or warehousing of, domains by registrars. Registrars are able to game the system to their own ends however they see fit; this has to change. > > The current RAA (section 3.7.9) states: "Registrar shall abide by any ICANN adopted specifications or policies prohibiting or restricting warehousing of or speculation in domain names by registrars". > > As there is no such policy or specification, I suggest that we initiate a PDP to have such a policy created, namely a policy that would state: > > "No registrar, registrar affiliate, or reseller of registrar services shall engage in warehousing of or speculation in domain names." > > While I understand that the GNSO soon will broadly be looking at proposed amendments for the RAA, we all know that the GNSO process (if spread over the entirety of the RAA proposed amendments) can take years to arrive at a recommendation... yet with the imminent roll-out of hundreds of new gTLDs, we just don't have the luxury of waiting that long. > > In my view, what is called for is a Fast Track PDP approach that would focus on a single policy recommendation that could be put in place before any new gTLD is launched. > > I would ask the NARALO to bring this matter to the immediate attention of the ALAC. > > Thanks for your consideration of this issue. > > Danny Younger > > > > > > > ------ > 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 > ------

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Re: [NA-Discuss] Request to have a Fast Track PDP initiated
by Alan Greenberg Nov. 30, 2010

Nov. 30, 2010

Danny, I have taken the liberty of forwarding your message to the at <at-large(a)atlarge-lists.icann.org> list, as I think that the issue has far wider impact than just North America. I will respond to it there. For those not on that list, self-subscription and the archives are available at https://atlarge-lists.icann.org/mailman/listinfo/at-large. Alan At 29/11/2010 10:09 PM, Danny Younger wrote: >Dear all, > >Events that have transpired in the last few days attendant to the >launch of .?? have made it clear to me that although we can't deal >with the troubling issues that may arise with TLD launches in the >ccTLD world, we do have the ability to act to protect the public >interest within the gTLD sphere by way of a policy that would govern >speculation in domain names by registrars. > >By way of background, in the recent .?? ccTLD launch an ICANN >accredited registrar, RU-Center, decided to register domain names in >its own name on a priority basis and only then did it register other >domain names. Approximately 24,500 premium domains registered to >RU-Center were then put up for auction. The Russian Federal >Antimonopoly Service (FAS) then stepped in, shut down the auctions >and accused a number of registrars of collusion. > >What can we learn from this? Simply put... greed in the new TLD >launch process can lead to abuse of the public trust, and measures >need to be in place to ensure that the public is protected from the >ICANN-accredited registrar community. > >In our gTLD world, there is at the moment no ICANN policy whatsoever >governing speculation in, or warehousing of, domains by >registrars. Registrars are able to game the system to their own >ends however they see fit; this has to change. > >The current RAA (section 3.7.9) states: "Registrar shall abide by >any ICANN adopted specifications or policies prohibiting or >restricting warehousing of or speculation in domain names by registrars". > >As there is no such policy or specification, I suggest that we >initiate a PDP to have such a policy created, namely a policy that would state: > >"No registrar, registrar affiliate, or reseller of registrar >services shall engage in warehousing of or speculation in domain names." > >While I understand that the GNSO soon will broadly be looking at >proposed amendments for the RAA, we all know that the GNSO process >(if spread over the entirety of the RAA proposed amendments) can >take years to arrive at a recommendation... yet with the imminent >roll-out of hundreds of new gTLDs, we just don't have the luxury of >waiting that long. > >In my view, what is called for is a Fast Track PDP approach that >would focus on a single policy recommendation that could be put in >place before any new gTLD is launched. > >I would ask the NARALO to bring this matter to the immediate >attention of the ALAC. > >Thanks for your consideration of this issue. > >Danny Younger

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Fwd: ICE seizes 82 website domains involved in selling counterfeit goods as part of Cyber Monday crackdown
by Joly MacFie Nov. 29, 2010

Nov. 29, 2010

---------- Forwarded message ---------- From: U.S. Immigration and Customs Enforcement (ICE) < ice.dhs(a)service.govdelivery.com> Date: Mon, Nov 29, 2010 at 11:11 AM Subject: ICE seizes 82 website domains involved in selling counterfeit goods as part of Cyber Monday crackdown To: joly(a)punkcast.com <http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…> *ICE seizes 82 website domains involved in selling counterfeit goods as part of Cyber Monday crackdown* *List of domain names seized<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…> * WASHINGTON - Seizure orders have been executed against 82 domain names of commercial websites engaged in the illegal sale and distribution of counterfeit goods and copyrighted works as part of Operation In Our Sites v. 2.0, as part of an ongoing investigation by U.S. Immigration and Customs Enforcement<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>(ICE). "The sale of counterfeit U.S. brands on the Internet steals the creative work of others, costs our economy jobs and revenue and can threaten the health and safety of American consumers," said ICE Director John Morton<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>. "The protection of intellectual property is a top priority for Homeland Security Investigations<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>and the National Intellectual Property Rights Coordination Center<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>. We are dedicated to protecting the jobs, the income and the tax revenue that disappear when counterfeit goods are trafficked." <http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…> The coordinated federal law enforcement operation targeted online retailers of a diverse array of counterfeit goods, including sports equipment, shoes, handbags, athletic apparel and sunglasses as well as illegal copies of copyrighted DVD boxed sets, music and software. During the course of the operation, federal law enforcement agents made undercover purchases from online retailers suspected of selling counterfeit goods. In many instances, the goods were shipped directly into the United States from suppliers in other countries using international express mail. If the goods were confirmed as counterfeit or otherwise illegal, seizure orders for the domain names of the websites that sold the goods were obtained from U.S. magistrate judges. Individuals attempting to access the websites will now find a banner notifying them that the domain name of that website has been seized by federal authorities. "By seizing these domain names, we have disrupted the sale of thousands of counterfeit items, while also cutting off funds to those willing to exploit the ingenuity of others for their own personal gain," said Attorney General Eric Holder. "Intellectual property crimes are not victimless. The theft of ideas and the sale of counterfeit goods threaten economic opportunities and financial stability, suppress innovation and destroy jobs. The Justice Department, with the help of our law enforcement partners, is changing the perception that these crimes are risk-free with enforcement actions like the one announced today." The operation builds upon Operation in Our Sites I<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>, which was announced in June 2010<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>. In that first action of this broader law enforcement initiative, authorities executed seizure warrants against nine domain names of websites offering pirated copies of first-run movies. The nationwide operation was spearheaded by the National Intellectual Property Rights Coordination Center<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>(IPR Center) led by ICE’s Office of Homeland Security Investigations (HSI), in coordination with the Criminal Division’s Computer Crime and Intellectual Property Section and nine U.S. Attorneys’ Offices including the Southern District of New York; District of Columbia; Middle District of Florida; District of Colorado; Southern District of Texas; Central District of California; Northern District of Ohio; District of New Jersey; and the Western District of Washington. The Criminal Division’s Asset Forfeiture and Money Laundering Section also provided significant assistance. The IPR Center is one of the U.S. government’s key weapons in the fight against criminal counterfeiting and piracy. The IPR Center is led by ICE HSI and includes partners from U.S. Customs and Border Protection; the FBI; the Department of Commerce; the Food and Drug Administration; the Postal Inspection Service; the General Services Administration, Office of the Inspector General; the Naval Criminal Investigative Service; the Defense Criminal Investigative Service; the Army Criminal Investigative Division’s Major Procurement Fraud Unit; the Consumer Product Safety Commission, INTERPOL; and the Government of Mexico Tax Administrative Service. The IPR Center allows law enforcement and the private sector jointly to address the growing transnational problem of counterfeit products. The IPR Center coordinates outreach to U.S. rights holders and conducts domestic and international law enforcement as well as coordinates and directs anti-counterfeiting investigations. To learn more about the IPR Center, visit http://www.ice.gov<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…> . ------------------------------ This email was sent to joly(a)punkcast.com. Modify subscriptions or unsubscribe<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…>| Need assistance? Please contact support(a)govdelivery.com. 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[image: Bookmark and Share]<http://links.govdelivery.com:80/track?type=click&enid=bWFpbGluZ2lkPTExMDA4N…> U.S. Immigration and Customs Enforcement (ICE) · U.S. Department of Homeland Security · Washington, DC 20528 · 202-732-4242 -- --------------------------------------------------------------- Joly MacFie 218 565 9365 Skype:punkcast WWWhatsup NYC - http://wwwhatsup.com http://pinstand.com - http://punkcast.com Secretary - ISOC-NY - http://isoc-ny.org ---------------------------------------------------------------

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