Re: [NA-Discuss] Fwd: [WHOIS-WG] Fwd: Roundup of WHOIS Issues
Volker, Thanks again for dumping those domains. <<Not the report originally presented to ICANN, and not the report I originally commented on. Stealth-added them later, did you?>> Hardly. In Section III, part C there is a lengthy piece on GlavMed. This is the version posted on our site since 20 June, the start of the Brussels conference, the same version we released publicly, the same version sent to ICANN. And this is just the part about GlavMed and eNom. Section III Part D takes a deep look at the Rx-Partner's network. Section I part D discusses eNom issues as they related to the EvaPharmacy network. Section I Part E demonstrates WHOIS compliance issues as they relate to illicit pharmacies. In general the report is focused on this specific problem. I don't know what dodgy version you have. <<Interesting offer, we may get back to you on that. I would like to see you check contents for thousands of domain names every day for a week>> Well, actually we do. Believe it or not, I think we're making progress here. Cheers, Garth
-------- Original Message -------- Subject: Re: [NA-Discuss] Fwd: [WHOIS-WG] Fwd: Roundup of WHOIS Issues From: Volker Greimann <vgreimann@key-systems.net> Date: Fri, July 23, 2010 2:59 pm To: Garth Bruen at KnujOn <gbruen@knujon.com> Cc: na-discuss@atlarge-lists.icann.org
Hi Garth,
still waiting for the apology you promised.
Thank you for removing mybuymeds[DOT]com, healthinsurancecapsule[DOT]net, and PAYPILL[DOT]NET.
Can you tell me what German law they violated that smartsshealth[dot]com did not?
Not sure what you mean, as I removed the nameservers on that one personally. It is not resolving on my end, maybe you checked to soon? You _do_ know that it takes a while until the removal of the nameservers spreads through the DNS...
(List of previously reported domain names)
Hmm, I do not see those in the abuse box. When did you report them?
Now, I never said you sponsored bestpillsroom[dot]com. What I said was healthinsurancecapsule[DOT]net looked suspended but redirected there.
Not anymore.
This is also the case with the following KEY-SYSTEMS domains:
I will check those out on Monday if you reported them to abuse. No doubt they will share a similar fate.
Yes, they are part of the report, a major part of the report. We had to leave off the list of ones KEY-SYSTEMS supports because of time and length. They will be listed in any revision as per your request.
Not the report originally presented to ICANN, and not the report I originally commented on. Stealth-added them later, did you?
<<It is however impossible for us to check the use of each domain name registered through our service.>>
I would be happy to do it for you, for free.
Interesting offer, we may get back to you on that. I would like to see you check contents for thousands of domain names every day for a week. Sadly, for security reasons, our registration lists are confidential at this time (competition and all that). If that changes, I'll definitely let you know.
<<More sadly, the registrations arrive from various sources, and do not announce themselves to be what they are upon registration.>>
I can see from your WHOIS Port 43 results that they are coming from VAHGAW[DOT]RU, NAMEOFFC[DOT]RU, JODETI[DOT]RU, and XOOXOX[DOT]RU. Are these nameservers run by your resellers? I think that would be a good place to start looking. Do you remove a reseller when their domains continue to turn up like this?
If a majority of domain names a reseller adds is bad, we do warn and then terminate the agreement, yes. We do not however geo-discriminate. As for nameserver services being run by them, we have no information on who runs those services.
Of course, this is not the case for all of them. clevermeds[DOT]net, easymed2u[DOT]com, easymedforyou[DOT]com, and mysmartmed[DOT]net are served from your very own DOMAINDISCOUNT24.NET.
Well, that happens when you run a highly automated system. Some bad customer registrations are bound to sneak in. But once we find them, they go down and the accounts are closed.
<<But I do pledge I will deactivate any domain name used for illegal (in Germany) purposes as soon as possible whenever I receive notice.>>
Well, you're changing the wording of the pledge. However, tell me in detail what constitutes a German legal violation that would be suitable for future notices (abuse is bcc'ed as requested)
In most cases, German regulations will be similar to those in the US.
<<And you still did not answer the question of what was found to be confusing.>>
Don't have to, you said: "the long list of prices may seem confusing to some"
So the solution in your view would be for us to offer less TLDs? Don't make me laugh. If we started to split up the price list, no doubt you would critize that as well and find someone who finds that "confusing". Some people just are confused, period, no matter what system they are faced with.
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
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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. 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.
-- 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.
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
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.
I should add that the technical resources available to NARALO (mailing list creation, conference call bridge, Doodle) can be made available to you should such an engagement become possible. - 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.
We'd pretty much echo Volker's sentiments Our abuse address is abuse@blacknight.com though :) And for network abuse eg. phishing etc., see: http://www.blacknight.com/abuse.html Mr Michele Neylon Blacknight Solutions Hosting & Colocation, Brand Protection ICANN Accredited Registrar http://www.blacknight.com/ http://blog.blacknight.com/ http://blacknight.mobi/ http://mneylon.tel Intl. +353 (0) 59 9183072 US: 213-233-1612 UK: 0844 484 9361 Locall: 1850 929 929 Direct Dial: +353 (0)59 9183090 Twitter: http://twitter.com/mneylon PS: Check out our latest offers on domains & hosting: http://domainoffers.me/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845
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
I don't know if this is settling anything, but I see nothing in Garth's message that I can find disagreeable. Knujon is clearly not your typical consumer complaint. It's more of a watchdog body, that looks at things and reports instances of (what it perceives as) rule breaking. I don't expect registrars to appreciate Knujon's work, or for everyone to necessarily get along. Any consumer watchdog organisation worth following has a generally adversarial relationship with the industries it monitors through no fault of its own -- the objects of its scrutiny generally don't like being watched in that leve of detail. But I still have yet to see one shred of backup for any accusations that Knujon's research methods are faulty (I think "sloppy" was the term used). I've suggested to Garth that the lack of personal response to a complaint should not put a registrar on a bad-actor list -- what counts is whether the problems are resolved, not how much acknowledgement takes place. Having said that, lack of response *and* lack of action on the complaint IMO *do* suggest a bad actor and publication is certainly warranted. So... Michele and Volker say "send me the names and we'll check them out". Garth has indicated that some registrars already work with him to get reports before they go public. This sounds like violent agreement, but I suspect it isn't. Let's seem how things play from here now that each has a better understanding of the other's position. I would also suggest taking further conversation on this topic out of the NARALO list and into the greater At-Large forum. (For example, neither Michele nor Volker is North American...). That said, I still think that Volker ought to retract his accusation of sloppiness. He may not like Knujon's process, or the haste with which it goes public, that that does not at all constitute "sloppy", which is to call into question the accuracy of the research. Short of any proof of inaccuracy, such an accusations simply constitutes a personal attack that demean the accuser more than the "victim". And if you think about it, Volker, the more that registrars complain about Knujon (without evidence), the more credible its data is perceived. The only people complaining are those targeted in its publications. Garth, you may want to -- as standard policy -- automate the sending of your lists to each registrar's abuse mailbox in advance of going public -- don't wait for them to ask for it. Then rerun your tests in a month to see if they've been acted upon. After that I see no reason *not* to go completely public about those still unchanged. If the registrars still want to complain after that, too bad. You may not like the message, and you may not like the way it's delivered, but you still have yet to prove inaccuracy. - Evan
participants (5)
-
Bob Bruen -
Evan Leibovitch -
Garth Bruen at KnujOn -
Michele Neylon :: Blacknight -
Volker Greimann