- NA-Discuss - lists.icann.org

sorry...
by Beau Brendler July 15, 2010

July 15, 2010

...I didn't know about David Giza's departure when I wrote this...let us know if there is anything we can do... -----Original Message----- >From: Beau Brendler <beaubrendler(a)earthlink.net> >Sent: Jul 14, 2010 3:37 PM >To: Stacy Burnette <stacy.burnette(a)icann.org>, Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn <gbruen(a)knujon.com> >Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, "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? > >With all due respect intended, that's not an answer. > >-----Original Message----- >>From: Stacy Burnette <stacy.burnette(a)icann.org> >>Sent: Jul 14, 2010 3:23 PM >>To: Beau Brendler <beaubrendler(a)earthlink.net>, Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn <gbruen(a)knujon.com> >>Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, "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? >> >>All: >> >>ICANN renewed A Technology Company's accreditation. We will continue to review the compliance allegations in an expeditious manner. As previously stated, community input is very appreciated and we will consider your recommendations. >> >>Thanks for your support. >> >>Sincerely, >> >>Stacy Burnette >>Director >>Contractual Compliance >>ICANN >>4676 Admiralty Way >>Suite 330 >>Marina del Rey, CA 90292 >>+1(310) 301-3860 >> >> >>-----Original Message----- >>From: Beau Brendler [mailto:beaubrendler@earthlink.net] >>Sent: Wednesday, July 14, 2010 10:56 AM >>To: Stacy Burnette; Bob Bruen; Garth Bruen at KnujOn >>Cc: carlton.samuels(a)gmail.com; David Giza; na-discuss(a)atlarge-lists.icann.org >>Subject: Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed? >> >>So their contract was terminated for non-payment. In addition, they were out of compliance with the current (new) RAA provision on address transparency. They paid up. But why, then, did ICANN sign a new RAA contract with them while they were out of compliance? Shouldn't they have been told, "please post your address on your Web site and then ICANN will sign the agreement"? Why would ICANN, in effect, accredit a registrar that was out of compliance with the rules of accreditation? >> >>Am I missing something here? >> >>-----Original Message----- >>>From: Stacy Burnette <stacy.burnette(a)icann.org> >>>Sent: Jul 14, 2010 1:06 PM >>>To: Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn <gbruen(a)knujon.com> >>>Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, "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? >>> >>>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 >>>------ >>

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Re: [NA-Discuss] "ICANN Lose More Staff - Head of Compliance Leaves"
by Beau Brendler July 15, 2010

July 15, 2010

I'm going to take this to the global list (not forward, I will just reference Michele's blog) -----Original Message----- >From: Garth Bruen at KnujOn <gbruen(a)knujon.com> >Sent: Jul 15, 2010 1:56 PM >To: Beau Brendler <beaubrendler(a)earthlink.net> >Cc: na-discuss(a)atlarge-lists.icann.org >Subject: "ICANN Lose More Staff - Head of Compliance Leaves" > >"Several people have made comments about how ICANN has been losing staff >over the last few months. >The most recent departure is their head of compliance - David Giza. His >interim replacement will be Pam Little. What makes this departure >noteworthy is the level of activity in the compliance department over >the past 18 months - the number of registrars whose accreditations were >terminated due to non-compliance increased by several hundred percent" - >Michele Nelyon in a blog > >http://www.irishblogs.ie/similar-to/icann-lose-more-staff-head-of-complianc… > > >Why did the Registrars find out first? > > > >> -------- Original Message -------- >> Subject: [NA-Discuss] rumor >> From: Beau Brendler <beaubrendler(a)earthlink.net> >> Date: Thu, July 15, 2010 1:26 pm >> To: na-discuss(a)atlarge-lists.icann.org >> >> >> Far be it from me to pass on hearsay, being a responsible journalist type and all of that, but apropos of the discussion below, I heard David Giza of compliance is either leaving or has already left. >> >> If that's the case, and far be it from me to speculate, the problems in ICANN's compliance department must be rather deep. >> >> Anyone heard anything about this for real? >> >> BB >> >> >> -----Original Message----- >> >From: Garth Bruen at KnujOn <gbruen(a)knujon.com> >> >Sent: Jul 15, 2010 10:07 AM >> >To: "John R. Levine" <johnl(a)iecc.com> >> >Cc: "na-discuss(a)atlarge-lists.icann.org" <na-discuss(a)atlarge-lists.icann.org>, Stacy Burnette <stacy.burnette(a)icann.org>, bruen(a)coldrain.net, carlton.samuels(a)gmail.com, David.Giza(a)icann.org, langdonorr(a)gmail.com, beaubrendler(a)earthlink.net >> >Subject: RE: [NA-Discuss] A Technology Company cured all breaches? Termination reversed? >> > >> >John, >> > >> >Thanks for bringing this up, the issue was discussed in a Brussels >> >session. While the breach notice ostensibly gives the Registrar 15 days >> >to correct, the result is not seen outside of ICANN unless it results in >> >a termination. If the Registrar does cure and how they cure is unknown >> >and uncontested. >> > >> >For example, Alantron was issued a breach notice on April 15th for not >> >providing Port 43 WHOIS access. We, and others, have tracked them since >> >and they continue to have regular outages. >> > >> >In a different contractual time limit, one of 45 days to correct WHOIS >> >inaccuracies, we continue to record domains remaining on-line after the >> >45 day period without a correction, or records being corrected only >> >after a follow up report has been issued declaring that the record was >> >not fixed. >> > >> >My understanding of the cycle is that the Registrant has 15 days to >> >correct the record: >> > >> ><< If the registrant fails to respond "for over fifteen calendar days to >> >inquiries by Registrar concerning the accuracy of contact details", then >> >pursuant to RAA Subsection 3.7.7.2 the registrant is in "material >> >breach" of its registration agreement with the registrar. That >> >subsection also provides that "willful provision of inaccurate or >> >unreliable information" shall constitute a material beach of the >> >registration agreement. Under either of these circumstances, the RAA >> >provides that the material breach of the registration agreement shall be >> >"a basis for cancellation of the Registered Name registration." >> >Accordingly, if the registrar's investigation results in a determination >> >that the registrant is in material breach of its registration agreement, >> >then in the absence of extenuating circumstances the registrar should >> >cancel the domain registration. >> >> >http://www.icann.org/en/announcements/advisory-10may02.htm >> > >> >And the Registrar has an additional 30 days to investigate and delete >> >the domain name: << Subsection 3.7.8 of the RAA obliges registrars to >> >"take reasonable steps to investigate" any inaccuracy in Whois data upon >> >notification from "any person." >> >> > >> >But, as I said, we see this continuously ignored. We have one domain in >> >question that is currently on its THIRD WDPRS. >> > >> >-Garth >> > >> > >> > >> > >> > >> >> -------- Original Message -------- >> >> Subject: Re: [NA-Discuss] A Technology Company cured all breaches? >> >> Termination reversed? >> >> From: "John R. Levine" <johnl(a)iecc.com> >> >> Date: Wed, July 14, 2010 8:58 pm >> >> To: "Stacy Burnette" <stacy.burnette(a)icann.org> >> >> Cc: "na-discuss(a)atlarge-lists.icann.org" >> >> <na-discuss(a)atlarge-lists.icann.org> >> >> >> >> >> >> > ICANN renewed A Technology Company's accreditation. We will continue to review the compliance allegations in an expeditious manner. As previously stated, community input is very appreciated and we will consider your recommendations. >> >> >> >> It'd be helpful to understand more about the way that ICANN's compliance >> >> works, rather than looking it it one issue at a time. >> >> >> >> Are ICANN's compliance plans written down anywhere? For example, when you >> >> give a notice of breach to a registrar, how long do they have to cure it, >> >> and does the time allowed vary depending on what the breach is? >> >> >> >> Regards, >> >> John Levine, johnl(a)iecc.com, Primary Perpetrator of "The Internet for Dummies", >> >> Information Superhighwayman wanna-be, http://www.johnlevine.com, ex-Mayor >> >> "More Wiener schnitzel, please", said Tom, revealingly. >> >> >> >> ------ >> >> 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 >> >> ------ >> > >> >> >> ------ >> 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 >> ------ >

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"ICANN Lose More Staff - Head of Compliance Leaves"
by Garth Bruen at KnujOn July 15, 2010

July 15, 2010

"Several people have made comments about how ICANN has been losing staff over the last few months. The most recent departure is their head of compliance - David Giza. His interim replacement will be Pam Little. What makes this departure noteworthy is the level of activity in the compliance department over the past 18 months - the number of registrars whose accreditations were terminated due to non-compliance increased by several hundred percent" - Michele Nelyon in a blog http://www.irishblogs.ie/similar-to/icann-lose-more-staff-head-of-complianc… Why did the Registrars find out first? > -------- Original Message -------- > Subject: [NA-Discuss] rumor > From: Beau Brendler <beaubrendler(a)earthlink.net> > Date: Thu, July 15, 2010 1:26 pm > To: na-discuss(a)atlarge-lists.icann.org > > > Far be it from me to pass on hearsay, being a responsible journalist type and all of that, but apropos of the discussion below, I heard David Giza of compliance is either leaving or has already left. > > If that's the case, and far be it from me to speculate, the problems in ICANN's compliance department must be rather deep. > > Anyone heard anything about this for real? > > BB > > > -----Original Message----- > >From: Garth Bruen at KnujOn <gbruen(a)knujon.com> > >Sent: Jul 15, 2010 10:07 AM > >To: "John R. Levine" <johnl(a)iecc.com> > >Cc: "na-discuss(a)atlarge-lists.icann.org" <na-discuss(a)atlarge-lists.icann.org>, Stacy Burnette <stacy.burnette(a)icann.org>, bruen(a)coldrain.net, carlton.samuels(a)gmail.com, David.Giza(a)icann.org, langdonorr(a)gmail.com, beaubrendler(a)earthlink.net > >Subject: RE: [NA-Discuss] A Technology Company cured all breaches? Termination reversed? > > > >John, > > > >Thanks for bringing this up, the issue was discussed in a Brussels > >session. While the breach notice ostensibly gives the Registrar 15 days > >to correct, the result is not seen outside of ICANN unless it results in > >a termination. If the Registrar does cure and how they cure is unknown > >and uncontested. > > > >For example, Alantron was issued a breach notice on April 15th for not > >providing Port 43 WHOIS access. We, and others, have tracked them since > >and they continue to have regular outages. > > > >In a different contractual time limit, one of 45 days to correct WHOIS > >inaccuracies, we continue to record domains remaining on-line after the > >45 day period without a correction, or records being corrected only > >after a follow up report has been issued declaring that the record was > >not fixed. > > > >My understanding of the cycle is that the Registrant has 15 days to > >correct the record: > > > ><< If the registrant fails to respond "for over fifteen calendar days to > >inquiries by Registrar concerning the accuracy of contact details", then > >pursuant to RAA Subsection 3.7.7.2 the registrant is in "material > >breach" of its registration agreement with the registrar. That > >subsection also provides that "willful provision of inaccurate or > >unreliable information" shall constitute a material beach of the > >registration agreement. Under either of these circumstances, the RAA > >provides that the material breach of the registration agreement shall be > >"a basis for cancellation of the Registered Name registration." > >Accordingly, if the registrar's investigation results in a determination > >that the registrant is in material breach of its registration agreement, > >then in the absence of extenuating circumstances the registrar should > >cancel the domain registration. >> > >http://www.icann.org/en/announcements/advisory-10may02.htm > > > >And the Registrar has an additional 30 days to investigate and delete > >the domain name: << Subsection 3.7.8 of the RAA obliges registrars to > >"take reasonable steps to investigate" any inaccuracy in Whois data upon > >notification from "any person." >> > > > >But, as I said, we see this continuously ignored. We have one domain in > >question that is currently on its THIRD WDPRS. > > > >-Garth > > > > > > > > > > > >> -------- Original Message -------- > >> Subject: Re: [NA-Discuss] A Technology Company cured all breaches? > >> Termination reversed? > >> From: "John R. Levine" <johnl(a)iecc.com> > >> Date: Wed, July 14, 2010 8:58 pm > >> To: "Stacy Burnette" <stacy.burnette(a)icann.org> > >> Cc: "na-discuss(a)atlarge-lists.icann.org" > >> <na-discuss(a)atlarge-lists.icann.org> > >> > >> > >> > ICANN renewed A Technology Company's accreditation. We will continue to review the compliance allegations in an expeditious manner. As previously stated, community input is very appreciated and we will consider your recommendations. > >> > >> It'd be helpful to understand more about the way that ICANN's compliance > >> works, rather than looking it it one issue at a time. > >> > >> Are ICANN's compliance plans written down anywhere? For example, when you > >> give a notice of breach to a registrar, how long do they have to cure it, > >> and does the time allowed vary depending on what the breach is? > >> > >> Regards, > >> John Levine, johnl(a)iecc.com, Primary Perpetrator of "The Internet for Dummies", > >> Information Superhighwayman wanna-be, http://www.johnlevine.com, ex-Mayor > >> "More Wiener schnitzel, please", said Tom, revealingly. > >> > >> ------ > >> 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 > >> ------ > > > > > ------ > 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 > ------

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rumor
by Beau Brendler July 15, 2010

July 15, 2010

Far be it from me to pass on hearsay, being a responsible journalist type and all of that, but apropos of the discussion below, I heard David Giza of compliance is either leaving or has already left. If that's the case, and far be it from me to speculate, the problems in ICANN's compliance department must be rather deep. Anyone heard anything about this for real? BB -----Original Message----- >From: Garth Bruen at KnujOn <gbruen(a)knujon.com> >Sent: Jul 15, 2010 10:07 AM >To: "John R. Levine" <johnl(a)iecc.com> >Cc: "na-discuss(a)atlarge-lists.icann.org" <na-discuss(a)atlarge-lists.icann.org>, Stacy Burnette <stacy.burnette(a)icann.org>, bruen(a)coldrain.net, carlton.samuels(a)gmail.com, David.Giza(a)icann.org, langdonorr(a)gmail.com, beaubrendler(a)earthlink.net >Subject: RE: [NA-Discuss] A Technology Company cured all breaches? Termination reversed? > >John, > >Thanks for bringing this up, the issue was discussed in a Brussels >session. While the breach notice ostensibly gives the Registrar 15 days >to correct, the result is not seen outside of ICANN unless it results in >a termination. If the Registrar does cure and how they cure is unknown >and uncontested. > >For example, Alantron was issued a breach notice on April 15th for not >providing Port 43 WHOIS access. We, and others, have tracked them since >and they continue to have regular outages. > >In a different contractual time limit, one of 45 days to correct WHOIS >inaccuracies, we continue to record domains remaining on-line after the >45 day period without a correction, or records being corrected only >after a follow up report has been issued declaring that the record was >not fixed. > >My understanding of the cycle is that the Registrant has 15 days to >correct the record: > ><< If the registrant fails to respond "for over fifteen calendar days to >inquiries by Registrar concerning the accuracy of contact details", then >pursuant to RAA Subsection 3.7.7.2 the registrant is in "material >breach" of its registration agreement with the registrar. That >subsection also provides that "willful provision of inaccurate or >unreliable information" shall constitute a material beach of the >registration agreement. Under either of these circumstances, the RAA >provides that the material breach of the registration agreement shall be >"a basis for cancellation of the Registered Name registration." >Accordingly, if the registrar's investigation results in a determination >that the registrant is in material breach of its registration agreement, >then in the absence of extenuating circumstances the registrar should >cancel the domain registration. >> >http://www.icann.org/en/announcements/advisory-10may02.htm > >And the Registrar has an additional 30 days to investigate and delete >the domain name: << Subsection 3.7.8 of the RAA obliges registrars to >"take reasonable steps to investigate" any inaccuracy in Whois data upon >notification from "any person." >> > >But, as I said, we see this continuously ignored. We have one domain in >question that is currently on its THIRD WDPRS. > >-Garth > > > > > >> -------- Original Message -------- >> Subject: Re: [NA-Discuss] A Technology Company cured all breaches? >> Termination reversed? >> From: "John R. Levine" <johnl(a)iecc.com> >> Date: Wed, July 14, 2010 8:58 pm >> To: "Stacy Burnette" <stacy.burnette(a)icann.org> >> Cc: "na-discuss(a)atlarge-lists.icann.org" >> <na-discuss(a)atlarge-lists.icann.org> >> >> >> > ICANN renewed A Technology Company's accreditation. We will continue to review the compliance allegations in an expeditious manner. As previously stated, community input is very appreciated and we will consider your recommendations. >> >> It'd be helpful to understand more about the way that ICANN's compliance >> works, rather than looking it it one issue at a time. >> >> Are ICANN's compliance plans written down anywhere? For example, when you >> give a notice of breach to a registrar, how long do they have to cure it, >> and does the time allowed vary depending on what the breach is? >> >> Regards, >> John Levine, johnl(a)iecc.com, Primary Perpetrator of "The Internet for Dummies", >> Information Superhighwayman wanna-be, http://www.johnlevine.com, ex-Mayor >> "More Wiener schnitzel, please", said Tom, revealingly. >> >> ------ >> 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 >> ------ >

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Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed?
by Garth Bruen at KnujOn July 15, 2010

July 15, 2010

John, Thanks for bringing this up, the issue was discussed in a Brussels session. While the breach notice ostensibly gives the Registrar 15 days to correct, the result is not seen outside of ICANN unless it results in a termination. If the Registrar does cure and how they cure is unknown and uncontested. For example, Alantron was issued a breach notice on April 15th for not providing Port 43 WHOIS access. We, and others, have tracked them since and they continue to have regular outages. In a different contractual time limit, one of 45 days to correct WHOIS inaccuracies, we continue to record domains remaining on-line after the 45 day period without a correction, or records being corrected only after a follow up report has been issued declaring that the record was not fixed. My understanding of the cycle is that the Registrant has 15 days to correct the record: << If the registrant fails to respond "for over fifteen calendar days to inquiries by Registrar concerning the accuracy of contact details", then pursuant to RAA Subsection 3.7.7.2 the registrant is in "material breach" of its registration agreement with the registrar. That subsection also provides that "willful provision of inaccurate or unreliable information" shall constitute a material beach of the registration agreement. Under either of these circumstances, the RAA provides that the material breach of the registration agreement shall be "a basis for cancellation of the Registered Name registration." Accordingly, if the registrar's investigation results in a determination that the registrant is in material breach of its registration agreement, then in the absence of extenuating circumstances the registrar should cancel the domain registration. >> http://www.icann.org/en/announcements/advisory-10may02.htm And the Registrar has an additional 30 days to investigate and delete the domain name: << Subsection 3.7.8 of the RAA obliges registrars to "take reasonable steps to investigate" any inaccuracy in Whois data upon notification from "any person." >> But, as I said, we see this continuously ignored. We have one domain in question that is currently on its THIRD WDPRS. -Garth > -------- Original Message -------- > Subject: Re: [NA-Discuss] A Technology Company cured all breaches? > Termination reversed? > From: "John R. Levine" <johnl(a)iecc.com> > Date: Wed, July 14, 2010 8:58 pm > To: "Stacy Burnette" <stacy.burnette(a)icann.org> > Cc: "na-discuss(a)atlarge-lists.icann.org" > <na-discuss(a)atlarge-lists.icann.org> > > > > ICANN renewed A Technology Company's accreditation. We will continue to review the compliance allegations in an expeditious manner. As previously stated, community input is very appreciated and we will consider your recommendations. > > It'd be helpful to understand more about the way that ICANN's compliance > works, rather than looking it it one issue at a time. > > Are ICANN's compliance plans written down anywhere? For example, when you > give a notice of breach to a registrar, how long do they have to cure it, > and does the time allowed vary depending on what the breach is? > > Regards, > John Levine, johnl(a)iecc.com, Primary Perpetrator of "The Internet for Dummies", > Information Superhighwayman wanna-be, http://www.johnlevine.com, ex-Mayor > "More Wiener schnitzel, please", said Tom, revealingly. > > ------ > 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 > ------

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12 July 2010 NARALO Action Items
by ICANN At-Large Staff July 15, 2010

July 15, 2010

Dear All, The action items from today’s NARALO are attached below and linked to agenda page under: https://st.icann.org/naralo/index.cgi?12_july_2010 Action Items 12 July 2010 AI: Darlene, Evan and Matthias will work together on a process to ask individual NARALO members to submit an SOI and incorporate them in the member database. AI: Evan will draft an outreach proposal based on the discussions held during today's call and submit it to the ALAC for discussion during the next meeting. AI: Matthias will send out an announcement to the NARALO mailing list once the FR and ES version of the brochures are online. AI: Annalisa will draft a NARALO position paper on new gTLD and send it to the NARALO mailing list for comments. AI: Annalisa will send her question on the role of registrars in the IPv6 Implementation to the NARALO list AI: Annalisa will send the updated contact information for her ALS to Matthias, Evan and Darlene AI: Matthias will send the VI Overview document presented in Brussels to the NARALO list AI: Matthias will look for the transcription of the VI session in Seoul and send it to the NARALO mailing list. AI: Staff will liaise with Evan and Darlene to organize a specific meeting on Vertical Integration -- 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

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Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed?
by Beau Brendler July 15, 2010

July 15, 2010

So their contract was terminated for non-payment. In addition, they were out of compliance with the current (new) RAA provision on address transparency. They paid up. But why, then, did ICANN sign a new RAA contract with them while they were out of compliance? Shouldn't they have been told, "please post your address on your Web site and then ICANN will sign the agreement"? Why would ICANN, in effect, accredit a registrar that was out of compliance with the rules of accreditation? Am I missing something here? -----Original Message----- >From: Stacy Burnette <stacy.burnette(a)icann.org> >Sent: Jul 14, 2010 1:06 PM >To: Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn <gbruen(a)knujon.com> >Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, "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? > >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 >------

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Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed?
by Garth Bruen at KnujOn July 14, 2010

July 14, 2010

Not withstanding Stacy's promise, Eduardo has an excellent point > -------- Original Message -------- > Subject: Re: [NA-Discuss] A Technology Company cured all breaches? > Termination reversed? > From: Eduardo Diaz <eduardodiazrivera(a)gmail.com> > Date: Wed, July 14, 2010 3:06 pm > To: Stacy Burnette <stacy.burnette(a)icann.org> > Cc: Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn > <gbruen(a)knujon.com>, "carlton.samuels(a)gmail.com" > <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, > "na-discuss(a)atlarge-lists.icann.org" > <na-discuss(a)atlarge-lists.icann.org> > > > I am concerned about the ASAP date that was given to this company as a > dateline for publishing a valid address. In my experience ASAP means > whenever you want. I recommend that ICANN gives them and specific date, i.e. > let's say...by tomorrow?. It just take a few minutes or less to update a web > page. > > Eduardo Diaz > ISOC-PR > > On Wed, Jul 14, 2010 at 1:06 PM, Stacy Burnette <stacy.burnette(a)icann.org>wrote: > > > 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 bills. 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 > > ------ > > > > > > -- > NOTICE: The information contained in this e-mail message is intended only > for the personal and confidential use of the recipient(s) named above. If > you have received this communication by error, please notify us immediately > by e-mail, and delete the original message.

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Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed?
by Beau Brendler July 14, 2010

July 14, 2010

With all due respect intended, that's not an answer. -----Original Message----- >From: Stacy Burnette <stacy.burnette(a)icann.org> >Sent: Jul 14, 2010 3:23 PM >To: Beau Brendler <beaubrendler(a)earthlink.net>, Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn <gbruen(a)knujon.com> >Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, "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? > >All: > >ICANN renewed A Technology Company's accreditation. We will continue to review the compliance allegations in an expeditious manner. As previously stated, community input is very appreciated and we will consider your recommendations. > >Thanks for your support. > >Sincerely, > >Stacy Burnette >Director >Contractual Compliance >ICANN >4676 Admiralty Way >Suite 330 >Marina del Rey, CA 90292 >+1(310) 301-3860 > > >-----Original Message----- >From: Beau Brendler [mailto:beaubrendler@earthlink.net] >Sent: Wednesday, July 14, 2010 10:56 AM >To: Stacy Burnette; Bob Bruen; Garth Bruen at KnujOn >Cc: carlton.samuels(a)gmail.com; David Giza; na-discuss(a)atlarge-lists.icann.org >Subject: Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed? > >So their contract was terminated for non-payment. In addition, they were out of compliance with the current (new) RAA provision on address transparency. They paid up. But why, then, did ICANN sign a new RAA contract with them while they were out of compliance? Shouldn't they have been told, "please post your address on your Web site and then ICANN will sign the agreement"? Why would ICANN, in effect, accredit a registrar that was out of compliance with the rules of accreditation? > >Am I missing something here? > >-----Original Message----- >>From: Stacy Burnette <stacy.burnette(a)icann.org> >>Sent: Jul 14, 2010 1:06 PM >>To: Bob Bruen <bruen(a)coldrain.net>, Garth Bruen at KnujOn <gbruen(a)knujon.com> >>Cc: "carlton.samuels(a)gmail.com" <carlton.samuels(a)gmail.com>, David Giza <David.Giza(a)icann.org>, "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? >> >>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 >>------ >

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Re: [NA-Discuss] A Technology Company cured all breaches? Termination reversed?
by Stacy Burnette July 14, 2010

July 14, 2010

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

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