Thanks for the opportunity to comment Danny. I have two main concerns in response to your items. <<2. Which of the proposed amendments would have full consensus if drafted differently, and what specific revisions are required to gain full consensus?>> Recently I and many others submitted a request to ICANN to add wording in the RAA similar to the following: "All Accredited Registrars must submit main office location, including country, to be publicly disclosed in ICANN web directory. Post Office boxes, Incorporation addresses, and mail-forwarding locations will not be acceptable. Registrars must also provide for public display the name of CEO or President. ICANN must be notified within 30 days of a location or presiding officer change.” While we are pleased the general topic is on the list amendments, the language has been seriously watered down to read: "Registrar Contact Information – Requires registrars to provide their accurate contact details on their websites including valid email and mailing addresses." The new language does not address issues concerning the use of "mail-drop" or "mail-forwarding" addresses. Nor does it address disclosure of ownership or actual location. We are aware of many Registrars claiming to be located in the United States which are truly located in a variety of countries. This lack of disclosure erodes public trust and does not contribute to transparency. The above language does not even mention an accurate phone number. <<4. What other issues with the RAA are not addressed by the proposed set of Amendments? >> Section 3.7.8 of the RAA reads: "Registrar shall abide by any specifications or policies established according to Section 4 requiring reasonable and commercially practicable (a) verification, at the time of registration, of contact information associated with a Registered Name sponsored by Registrar or (b) periodic re-verification of such information. Registrar shall, upon notification by any person of an inaccuracy in the contact information associated with a Registered Name sponsored by Registrar, take reasonable steps to investigate that claimed inaccuracy. In the event Registrar learns of inaccurate contact information associated with a Registered Name it sponsors, it shall take reasonable steps to correct that inaccuracy." The word "or" in line 4 should be changed to "and". This is an ambiguous situation that could be easily remedied by requiring both activities. Verification at registration and regular checking should go hand in hand. Checking at the origin point can prevent the need for checking later and would improve security and general stability of the registry system. Also, how is one to determine which action a Registrar opted to use? How is this verified? It is better to know that both verifications are occurring, it will save the Registrars many headaches in dealing with abusive registrants BEFORE they get in as opposed to after.

-------- Original Message -------- Subject: [NA-Discuss] RAA Amendments Update From: Danny Younger <dannyyounger@yahoo.com> Date: Mon, February 16, 2009 2:49 pm To: NA Discuss <na-discuss@atlarge-lists.icann.org> Cc: ga@gnso.icann.org

The BC's Mike Rodenbaugh has introduced the following motion to the GNSO Council; the motion has been seconded by Nominating Committee appointee Terry Davis:

Whereas, the RAA has not been amended since inception, and there is widespread community support for amendments to various provisions of the RAA.

Whereas, the Registrars Constituency and ICANN Staff have agreed on a set of proposed amendments to the RAA, and that set of amendments has been considered for approval by the GNSO Council.

Whereas, a majority of GNSO Council members have refused to support the set of proposed amendments as drafted, but many of those members support many of the proposed amendments.

Whereas, the Council wishes to approve the non-contentious, proposed amendments agreed between Staff and the Registrars Constituency as quickly as possible so that the ICANN Board may review them, and if approved then implement them as quickly as possible.

RESOLVED:

The GNSO Council will form a fast-track Working Group to convene and discuss the proposed set of RAA Amendments, reporting back to Council within 30 days with answers to the following questions:

1. Which of the proposed amendments have full consensus as drafted?

2. Which of the proposed amendments would have full consensus if drafted differently, and what specific revisions are required to gain full consensus?

3. Which of the proposed amendments do not have consensus?

4. What other issues with the RAA are not addressed by the proposed set of Amendments?

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