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@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