Hi Volker, I would like to point out a few things that may help frame why we do things the way we do. We have been working on this for over five years. During that time we have some success and a lot of pushback, however we have had the most success with public reporting, shining a light on problems. As a recent example, last year KnujOn and Legitscript published reports on sponsored illicit pharmacy advertisements on Bing, Yahoo and Google. Google was the only one that took us seriously and did something about it. Microsoft and Yahoo complained about us, insisting that things were fine, but a few months ago, they agreed to verify the sites that were buying pharmacy ads. They did not involve us in the agreement or admit that we pushed them into it, but we were happy because now illicit sponsored ads on the three biggest search engines are very hard to come by. We filed so many complaints at ICANN that three years ago, all other complaints combined were not one tenth of ours. We increased the number of complaints until ICANN's complaint system broke down. We then helped them set up a new system that could handle a large volume of complaints. A few years ago, we published a top ten worst registrars for spam, and followed it up with a second list eight months later. The second list only had two registrars from the first list on it, the rest either fixed what they needed to or lost their accreditation. Later on, China shut down of one those two, leaving just one, eNom, which was the star of our recent report. We have also had a few major and very public wars of words with a few registrars, which resulted in them changing their approaches to how they operate and cleaning up the bad sites. With less public debates, we were instrumental in getting some large registrars to improve their Terms of Service Agreements. We have previously offered to send bulk complaints to registrars directly, bypassing ICANN. Some have taken our offer, most do not. If you, or any registrar, would like to set this up, let us know. There is more, but that should make the point. We understand that there will never be a 100% elimination of bad actors, but we do believe the problem can be mitigated to tolerable levels. For example, we would like to see the 90%-spam/10%-ham traffic ratio inverted. We believe that registrars have the ability to contribute significantly to this effort by making some changes in how they operate. The war of words we are involved in right now is a repeat of history. We stand ready to transition from the public debate to actual work. KnujOn has demonstrated its ability and willingness to fix the problems it has brought to light. regards, bob