THANK YOU!

-------- Original Message -------- Subject: RE: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows From: ICANN At-Large Staff <staff@atlarge.icann.org> Date: Tue, December 07, 2010 3:26 pm To: <gbruen@knujon.com> Cc: Carlton Samuels <carlton.samuels@gmail.com>, <na-discuss@atlarge-lists.icann.org>, Helen <helen@dotalliance.com>, ICANN At-Large Staff <staff@atlarge.icann.org>

Hi Garth,

Compliance staff have sent the following information on DotAlliance:

**

According to our records, DotAlliance is an ICANN-accredited registrar. See below:

DotAlliance Inc.

Registrar IANA ID

1249

Registrar Corporation Type

Canada Corporation

RAA Version

2009

Accreditation Date

2009-07-01

Accreditation Expiration Date

2014-06-30

URL

www.dotalliance.com <https://connect.icann.org/,DanaInfo=www.dotalliance.com+>

It appears that they only have their email addresses posted on their website but not postal address so they are deemed non-compliant.

**

Regards,

Heidi Ullrich, Matthias Langenegger, Seth Greene, Gisella Gruber-White, Marilyn Vernon,

ICANN At-Large Staff

From: gbruen@knujon.com [mailto:gbruen@knujon.com] Sent: Tuesday, December 07, 2010 5:50 AM To: Helen; ICANN At-Large Staff Cc: Carlton Samuels; na-discuss@atlarge-lists.icann.org Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows

Hi Helen,

We're jumping from one problem to another. According to ICANN, you are a Registrar: http://www.internic.net/registrars/registrar-1249.html

I think ICANN staff needs to clarify this immediately.

Which Registrar are you a reseller for if you are reseller?

-Garth

From: Helen <mailto:helen@dotalliance.com>

Sent: Tuesday, December 07, 2010 4:24 AM

To: gbruen@knujon.com

Cc: Michele Neylon :: Blacknight <mailto:michele@blacknight.ie> ; Carlton Samuels <mailto:carlton.samuels@gmail.com>

Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the Shadows

Hi Garth! As a reseller we've never felt the address needs to be on the front page in flashing neon lights. But we have had the address on our website for years.. I believe from the start! In addition, all resellers do need to sign the registrant agreement so they must look at it. http://dotalliance.com/registrationagree.html#definitions I will ask someone to look at putting it on the contact page if this is so distressing, however we are not nor have ever been in breach with the RAA.

I wish I was able be in Columbia to see everyone, unfortunately an illness in the family prevents this or even much of a peep out of me for a while. Just remember ...someone owes me a beer in Frisco! :)

Best, Helen www.DotAlliance.com

On 06/12/2010 5:30 AM, gbruen@knujon.com wrote:

I checked into the claims by Michele (or maybe I should address you as "Blacknight"?) and my suspicions were confirmed. He has completely distorted

the issues and ignored the critical problem. Active Registrar, Compana, Directi, DOTALLIANCE, EVERYONES INTERNET, NICCO, RESELLER SERVICES, UK2 GROUP, VOLUSION, YNOT DOMAINS, and OWN IDENTITY have not corrected the problem as cited since June and ICANN compliance has not addressed the issue. You've glossed over this.

You've also glossed over the fact that OnLineNIC was allowed to sign on to the 2009 RAA without first complying and has not been held to comply since, even through we were informed they would be held to the RAA after signing.

In our original report we expressed our concern the the other Registrars would also be allowed to re-sign without meeting this requirement, and why should they have to when it's not enforced? Why would they opt for public disclosure when their competitors are not held by any standard? Does this not concern you?

The RAA has become meaningless and the Internet user DESERVERS BETTER.

If you purport to be a leader in this community you'll expect better too.

-------------------------------------------------- From: "Michele Neylon :: Blacknight" <mailto:michele@blacknight.ie> <michele@blacknight.ie> Sent: Sunday, December 05, 2010 8:31 PM To: "Carlton Samuels" <mailto:carlton.samuels@gmail.com> <carlton.samuels@gmail.com> Cc: <mailto:na-discuss@atlarge-lists.icann.org> <na-discuss@atlarge-lists.icann.org> Subject: Re: [NA-Discuss] Two Years later, Dozens of Registrars Still in the

Shadows

I checked into the claims by Knujon and my suspicions were confirmed. Of the registrars supposedly in breach 50% are NOT on the 2009 RAA. They are, therefore, NOT in breach, so I wonder how long we will have to wait for a corrected / updated version of this report

Regards

Michele

Mr. Michele Neylon Blacknight http://Blacknight.tel

Via iPhone so excuse typos and brevity

On 4 Dec 2010, at 23:14, "Carlton Samuels" <mailto:carlton.samuels@gmail.com> <carlton.samuels@gmail.com> wrote:

Garth: I commend you and KnuJon for keeping at this issue. It is one thing to be the slacker in a contract. But the fact that ICANN fails to embrace its duty of care to the community in ensuring that contracted parties live up to the terms and condition of contract remains scandalous.

The low hanging fruit of an explanation would be ignorance of its commitment. But reason and good judgment suggests that this would be a stretch for explanation. Time enough for ICANN to rise to the occasion and do its duty.

Carlton [Chair, At-Large WHOIS WG]

============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Planning, Governance, Assessment & Turnaround =============================

1. Two Years Later Dozens of Registrars Still in the Shadows (Garth Bruen at KnujOn)

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Message: 1 Date: Fri, 03 Dec 2010 11:49:35 -0700 From: "Garth Bruen at KnujOn" <mailto:gbruen@knujon.com> <gbruen@knujon.com> Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in the Shadows To: na-discuss@atlarge-lists.icann.org

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_ still_in_the_shadows/

-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

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