On 28 July 2010 09:31, Volker Greimann <vgreimann@key-systems.net> wrote:

Dear Garth,

Thanks again for dumping those domains.

...

There is nothing to it. Thats what we do everytime we receive a complaint: Investigate, and if found to be in breach of our policies, we take down. I hope we can continue working together without resorting to post each potentially infringing domain name on public lists before launching a complaint with us.

Perhaps if there was better engagement, there may be a process through which Knujon will release a draft list of domains to registrars, which would allow them to act before the list goes public. This would give the opportunities for the genuine "good actors" to respond as required, while enabling the "bad actors" (who will ignore or defer the Knujon lists) to be revealed. And if there are items in the Knujon lists that are indeed legitimate, then that discrepancy ought to be resolved as well before they go public. Volker, perhaps you and Michele (if he agrees with this) might again advance such engagement within the registrar community. It doesn't have to be everyone; those who choose not to engage are free to stay away, but they shouldn't prevent those who do want to do the right thing to do so. In this respect Knujon can be seen as a valuable tool (to help catch the bad domains that 'slip through the cracks') rather than just a source of confrontation.

Believe it or not, I think we're making progress here.

...

Each and every illegally used domain name we can take down is a success for us too. So keep those abuse reports coming, but please, use our proper abuse channels.

Volker, perhaps it would be in your mutual best interests to meet Garth part-way here. Asking him to inform registrars in advance of going public, while expecting him to automate every single registrar's different complaint system, is not reasonable. Perhaps there is a way to take his lists in a format that allows you to bulk-process the identified domains. You already know that Knujon does more than just occasional single complaints. He is doing you a service and simplifying your task of identifying illegal and improper registrations. If you're asking him to work with you rather than to be confrontational, then it makes sense not to put obstacles in his way of doing that. - Evan

Dear Evan, thank you for your comments.

Thanks again for dumping those domains.

There is nothing to it. Thats what we do everytime we receive a complaint: Investigate, and if found to be in breach of our policies, we take down. I hope we can continue working together without resorting to post each potentially infringing domain name on public lists before launching a complaint with us.

Perhaps if there was better engagement, there may be a process through which Knujon will release a draft list of domains to registrars, which would allow them to act before the list goes public. This would give the opportunities for the genuine "good actors" to respond as required, while enabling the "bad actors" (who will ignore or defer the Knujon lists) to be revealed.

We would appreciate such a mechanism. It is essentially impossible to prevent all illegal or abusive registrations beforehand, and we therefore rely on third party abuse reports to shut down such domain names as soon as possible.

And if there are items in the Knujon lists that are indeed legitimate, then that discrepancy ought to be resolved as well before they go public. I agree. The current procedure of KnuJon of going public before or at the same time as sending the abuse reports to the registrar paints us in a negative light, as we are not even given a chance to investigate and remove any illegal names before we are cast as the black hats. This has resulted in a lot of bad blood in the registrar community, and KnuJon is mainly perceived not as someone who genuinely cares about the problem, but more about painting registrars in a bad light in order to stand in the spotlight (and maybe sell their services). Working in the background means less time in the spotlight for the reporter, but usually results in better and quicker results. Where it does not, one could still go public.

Volker, perhaps you and Michele (if he agrees with this) might again advance such engagement within the registrar community. It doesn't have to be everyone; those who choose not to engage are free to stay away, but they shouldn't prevent those who do want to do the right thing to do so. In this respect Knujon can be seen as a valuable tool (to help catch the bad domains that 'slip through the cracks') rather than just a source of confrontation. Not sure what engagement you are looking for, but according to the RAA we are already engaged and obliged to stamp out illegal registrations where we find them. Most registrars are not looking for confrontation, but are forced into one when they are first put on the spot before having a fair opportunity to deal with the problem first.

Believe it or not, I think we're making progress here.

Each and every illegally used domain name we can take down is a success for us too. So keep those abuse reports coming, but please, use our proper abuse channels.

Volker, perhaps it would be in your mutual best interests to meet Garth part-way here. Asking him to inform registrars in advance of going public, while expecting him to automate every single registrar's different complaint system, is not reasonable. Perhaps there is a way to take his lists in a format that allows you to bulk-process the identified domains. Is it reasonable to expect each and every registrar to scour the net for each and every site, forum or board where someone complains about misuse of domain names? We have neither the manpower not the time to hunt for the data, so we rely on complainants coming to us. Our complaint procedure is clear: send an email to abuse@key-systems.net, include as much evidence as possible, and we will investigate each and every complaint. Even with bulk complaints, we still need to look at each and every domain name. You already know that Knujon does more than just occasional single complaints. He is doing you a service and simplifying your task of identifying illegal and improper registrations. If you're asking him to work with you rather than to be confrontational, then it makes sense not to put obstacles in his way of doing that.

We ask KnuJon and any other party interested in removing illegal content to cooperate with us and provide us with the information we need to take down illegal content. -- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.key-systems.net/facebook www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 1861 - Zweibruecken V.A.T. ID.: DE211006534 This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.

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