Dear all, For the proposed recommendations, I’d suggest to merge #1 and #7 into one, #2 and #6 into one. I support that “all domain name registrations adhere to the WHOIS requirements in the 2013 Registrar Accreditation Agreement”, but I’m cautious about the necessity of a new policy to be developed (maybe it’s a routine within ICANN?). My impression is that there are too many policies in the realm of Whois rather than not enough. By the end of this year, all registrars will shift to 2013 RAA, it’s time to endorse a standardized requirement for all gTLDs. I’d like to propose a new recommendation as below: Recommendation: Following a valid WHOIS ARS ticket, or Whois inaccuracy complaint, an full audit targeting the relating registrar should be initiated, to check if the registrar follows the contractual obligations, the consensus policies, etc. Sanctions should be applied if deficiencies identified. Findings: All current compliance activities are separate and conducted individually. WHOIS ARS sampled Whois records to do accuracy test, the Audit programme sampled registrars to conduct audit, no synergies have been gained through different action tracks. Rationale: If a Whois record is not accurate due to registrar didn’t conduct validation and verification, it shouldn’t be a standalone case. A follow up audit will help to mitigate all issues regarding the outstanding registrar. Impact of Recommendation: Only related registrars will be impacted by this recommendation along with the compliance team. Feasibility of Recommendation: This recommendation will make the Audit program more targeted. The compliance team may need further assessment of resources to implement this recommendation. Thanks, Lili From: RDS-WHOIS2-RT [mailto:rds-whois2-rt-bounces@icann.org] On Behalf Of Volker Greimann Sent: Saturday, 26 May, 2018 12:02 AM To: rds-whois2-rt@icann.org Subject: Re: [RDS-WHOIS2-RT] Compliance subgroup draft report Hi Susan, regarding the analysis section, one brief point: The cancellation or suspension of the registration does not necessarily mean that the data was incorrect. In many cases, the registrant simply ignored the message, saw it too late, did not have it forwarded by a reseller, etc and therefore did not respond by the time the registrar is obliged to take action. So if you take a nice three week hiking tour, that is the best time for anyone who wants to take down your domain name. Let's be careful with drawing conclusions from data that can be interpreted in many ways. To the next paragraph, ICANN actually monitors suspended domains and reaches out to registrars when such domains are unsuspended. I disagree with the conclusion that a suspended domain should not be unsuspended without verification as the suspension can have occurred for a multitude of reasons that have nothing to do with the registration data. (Most common on our registrar: Hacked wordpress blogs with subsites that lead to phishing sites - usually fixed by removing the subpages and updating the WordPress by the registrant). As for the recommendation, that is a significant implementation impact for little to no benefit. I see no harm in having false data in the whois of a suspended domain. And I also disagree with the second part of the recommendation, as detailed above. And to the added question, yes, suspended domain names can and will be renewed. Re: Grandfathered domains: I have significant concerns about the logistics of this recommendation. Not having to touch legacy domains and their owners unless there is active cause to do so has been a significant part of the agreement between Registrars and ICANN under the 2013 RAA negotiations. I also note that that usually older domains are not as much a cause for Re: Bulk Submission tool: We should add something that submissions remain manageable by registrars of all sizes, since receiving 300 single tickets or one ticket with 300 domains can overwhelm the abuse function of smaller registrars. So complaints using such a tool need to be for one issue with multiple domains, not various issues with multiple domains. So if they all use the same incorrect whois for example, that would be a valid use, but if they all use different whois data, they should be submitted individually. Rules for combining UDRP complaints could inform on what should be applied here to keep this tool relevant. Proactive: The ARS is quite proactive and feeds directly into compliance. Should ICANN undertake two or more projects with the same goal at the same time? Also, is there actual value in improving whois data quality where no other issue exists? We have many cases where data is outdated because people moved and forgot to update their whois. When we notice this we ask them to update, but is this really an issue that needs fixing by the community? Is Whois accuracy an aboslute goal in and of itself? I do not support the recommendation that compliance should be more proactive in monitoring. With Whois ARS and volunteer community effort, sufficient proactive efforts exist. Cross validation: Cannot be a compliance issue until it is agreed between ICANN and registrars. The working group is still deliberating. Table on Page 18: The RT1 Recommendation refers to proactive management and scaling of compliance activities, not proactive assessment and enforcement. The RT1 Rec means that Compliance should be proactive with regard to its own ability to perform its function, not to expand on that function as the comment in the table suggests. Finally, the document keeps using the term TLDs where domain names are meant. This should be updated. Example: "legacy tlds" Recommendations: #1: We should not recommend enforcement of a registry policy against registrars. If anything, it is a contractual issue between registries and registrars and thus behind the picket fence. If anything, it would have to be enforced against registries not properly implementing it. It therefore cannot be part of the registrar audit. #2: Strongly disagree with this recommendation, as detailed above. Highly unfeasible due to requirement to touch hundreds of thousands of customers to basically ask them to add or change formatting on certain data. Customer support nightmare and costs highly outweighing the benefits. Strongly opposed. #3: Opposed, as detailed above. #5: Agreed, provided we include measures to keep such reports manageable, applying rules similar to the ones for joining UDPR complaints together. Rationale: See above. #6 Seems to duplicate Rec 2? Strongly opposed as detailed above. Logistical nightmare. #7 Opposed: This issue has been addressed by the GNSO, see: https://gnso.icann.org/en/group-activities/inactive/2015/dmpm Let us not re-open issues that have already been debated at length by the community. And why only the compliance team? Volker Am 24.05.2018 um 20:54 schrieb Susan Kawaguchi: Hello All, Please see the attached Compliance subgroup draft report. Apologies to the subgroup in not providing this to you earlier in the week for your review but thought it best to hit the deadline for the draft report to the full working group. This report still needs more work, I definitely did not organize the information optimally and will continue to work on that. I intend to use a table format for some of our analysis as we did for the RT1 compliance recommendation. Also there may be duplicative language as I moved things around I may not have caught all of the changes. I also intentionally left some duplicative language to remind me to continue editing. I am hoping the subgroup will meet next week for additional discussion on the findings and recommendations. Best regards, Susan _______________________________________________ RDS-WHOIS2-RT mailing list RDS-WHOIS2-RT@icann.org<mailto:RDS-WHOIS2-RT@icann.org> https://mm.icann.org/mailman/listinfo/rds-whois2-rt -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> 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. *************************************************************************************************** This message, and any attachment contained, are confidential and subject of legal privilege. It may be used solely for the designated police/justice purpose and by the individual or entity to whom it is addressed. The information is not to be disseminated to another agency or third party without the author’s consent, and must not be retained longer than is necessary for the fulfilment of the purpose for which the information is to be used. All practicable steps shall be taken by the recipients to ensure that information is protected against unauthorised access or processing. INTERPOL reserves the right to enquire about the use of the information provided. If you are not the intended recipient, be advised that you have received this message in error. In such a case, you should not print it, copy it, make any use of it or disclose it, but please notify us immediately and delete the message from any computer. *************************************************************************************************

My comments inserted in lines in blue. From: RDS-WHOIS2-RT [mailto:rds-whois2-rt-bounces@icann.org] On Behalf Of Volker Greimann Sent: Tuesday, 5 June, 2018 7:43 PM To: rds-whois2-rt@icann.org Subject: Re: [RDS-WHOIS2-RT] Compliance subgroup draft report With all due respect, I utterly reject this recommendation. If contracted parties had to undergo a full audit for every ARS complaint, we would get nothing else done. This suggested recommendation is so far beyond the pale, it defies any common sense. There are dozens of registrars go through audit process every year while keep their business running. The intention of this recommendation is to make the audit more targeted rather than sampled. As I explained before, receipt of a whois inaccuracy complaint or an ARS ticket does not indicate the registrar is not complying with its contractual or policy obligations. It merely means some data is incorrect. This can have many reasons outside the registrar not doing his job. I object to any attempt to include this or a similar recommendation in the report. There is simply no need for such a recommendation. Further, this recommendation is not based on any facts or findings of patters where these obligations are regularly violated. It is entirely based on a ficticious assumption that has no basis in reality - that the occurance of whois inaccuracies mean that someone is violating their obligations. I also want to point out that compliance does inquire about validation and verification methods being correctly implemented in case there are indications of misconduct and registrars that receive greater than average numbers of complaints are already targeted more often in the scheduled audit runs. The audit criteria is copied below, in which I don’t see strong indication on that. And according to Compliance written reply, they treat all registrars equally. Do you have any other evidence on this? [cid:image001.png@01D3FD20.2E79EE80] [cid:image002.png@01D3FD20.2E79EE80] Volker Am 03.06.2018 um 11:54 schrieb SUN Lili: Dear all, For the proposed recommendations, I’d suggest to merge #1 and #7 into one, #2 and #6 into one. I support that “all domain name registrations adhere to the WHOIS requirements in the 2013 Registrar Accreditation Agreement”, but I’m cautious about the necessity of a new policy to be developed (maybe it’s a routine within ICANN?). My impression is that there are too many policies in the realm of Whois rather than not enough. By the end of this year, all registrars will shift to 2013 RAA, it’s time to endorse a standardized requirement for all gTLDs. I’d like to propose a new recommendation as below: Recommendation: Following a valid WHOIS ARS ticket, or Whois inaccuracy complaint, an full audit targeting the relating registrar should be initiated, to check if the registrar follows the contractual obligations, the consensus policies, etc. Sanctions should be applied if deficiencies identified. Findings: All current compliance activities are separate and conducted individually. WHOIS ARS sampled Whois records to do accuracy test, the Audit programme sampled registrars to conduct audit, no synergies have been gained through different action tracks. Rationale: If a Whois record is not accurate due to registrar didn’t conduct validation and verification, it shouldn’t be a standalone case. A follow up audit will help to mitigate all issues regarding the outstanding registrar. Impact of Recommendation: Only related registrars will be impacted by this recommendation along with the compliance team. Feasibility of Recommendation: This recommendation will make the Audit program more targeted. The compliance team may need further assessment of resources to implement this recommendation. Thanks, Lili From: RDS-WHOIS2-RT [mailto:rds-whois2-rt-bounces@icann.org] On Behalf Of Volker Greimann Sent: Saturday, 26 May, 2018 12:02 AM To: rds-whois2-rt@icann.org<mailto:rds-whois2-rt@icann.org> Subject: Re: [RDS-WHOIS2-RT] Compliance subgroup draft report Hi Susan, regarding the analysis section, one brief point: The cancellation or suspension of the registration does not necessarily mean that the data was incorrect. In many cases, the registrant simply ignored the message, saw it too late, did not have it forwarded by a reseller, etc and therefore did not respond by the time the registrar is obliged to take action. So if you take a nice three week hiking tour, that is the best time for anyone who wants to take down your domain name. Let's be careful with drawing conclusions from data that can be interpreted in many ways. To the next paragraph, ICANN actually monitors suspended domains and reaches out to registrars when such domains are unsuspended. I disagree with the conclusion that a suspended domain should not be unsuspended without verification as the suspension can have occurred for a multitude of reasons that have nothing to do with the registration data. (Most common on our registrar: Hacked wordpress blogs with subsites that lead to phishing sites - usually fixed by removing the subpages and updating the WordPress by the registrant). As for the recommendation, that is a significant implementation impact for little to no benefit. I see no harm in having false data in the whois of a suspended domain. And I also disagree with the second part of the recommendation, as detailed above. And to the added question, yes, suspended domain names can and will be renewed. Re: Grandfathered domains: I have significant concerns about the logistics of this recommendation. Not having to touch legacy domains and their owners unless there is active cause to do so has been a significant part of the agreement between Registrars and ICANN under the 2013 RAA negotiations. I also note that that usually older domains are not as much a cause for Re: Bulk Submission tool: We should add something that submissions remain manageable by registrars of all sizes, since receiving 300 single tickets or one ticket with 300 domains can overwhelm the abuse function of smaller registrars. So complaints using such a tool need to be for one issue with multiple domains, not various issues with multiple domains. So if they all use the same incorrect whois for example, that would be a valid use, but if they all use different whois data, they should be submitted individually. Rules for combining UDRP complaints could inform on what should be applied here to keep this tool relevant. Proactive: The ARS is quite proactive and feeds directly into compliance. Should ICANN undertake two or more projects with the same goal at the same time? Also, is there actual value in improving whois data quality where no other issue exists? We have many cases where data is outdated because people moved and forgot to update their whois. When we notice this we ask them to update, but is this really an issue that needs fixing by the community? Is Whois accuracy an aboslute goal in and of itself? I do not support the recommendation that compliance should be more proactive in monitoring. With Whois ARS and volunteer community effort, sufficient proactive efforts exist. Cross validation: Cannot be a compliance issue until it is agreed between ICANN and registrars. The working group is still deliberating. Table on Page 18: The RT1 Recommendation refers to proactive management and scaling of compliance activities, not proactive assessment and enforcement. The RT1 Rec means that Compliance should be proactive with regard to its own ability to perform its function, not to expand on that function as the comment in the table suggests. Finally, the document keeps using the term TLDs where domain names are meant. This should be updated. Example: "legacy tlds" Recommendations: #1: We should not recommend enforcement of a registry policy against registrars. If anything, it is a contractual issue between registries and registrars and thus behind the picket fence. If anything, it would have to be enforced against registries not properly implementing it. It therefore cannot be part of the registrar audit. #2: Strongly disagree with this recommendation, as detailed above. Highly unfeasible due to requirement to touch hundreds of thousands of customers to basically ask them to add or change formatting on certain data. Customer support nightmare and costs highly outweighing the benefits. Strongly opposed. #3: Opposed, as detailed above. #5: Agreed, provided we include measures to keep such reports manageable, applying rules similar to the ones for joining UDPR complaints together. Rationale: See above. #6 Seems to duplicate Rec 2? Strongly opposed as detailed above. Logistical nightmare. #7 Opposed: This issue has been addressed by the GNSO, see: https://gnso.icann.org/en/group-activities/inactive/2015/dmpm Let us not re-open issues that have already been debated at length by the community. And why only the compliance team? Volker Am 24.05.2018 um 20:54 schrieb Susan Kawaguchi: Hello All, Please see the attached Compliance subgroup draft report. Apologies to the subgroup in not providing this to you earlier in the week for your review but thought it best to hit the deadline for the draft report to the full working group. This report still needs more work, I definitely did not organize the information optimally and will continue to work on that. I intend to use a table format for some of our analysis as we did for the RT1 compliance recommendation. Also there may be duplicative language as I moved things around I may not have caught all of the changes. I also intentionally left some duplicative language to remind me to continue editing. I am hoping the subgroup will meet next week for additional discussion on the findings and recommendations. Best regards, Susan _______________________________________________ RDS-WHOIS2-RT mailing list RDS-WHOIS2-RT@icann.org<mailto:RDS-WHOIS2-RT@icann.org> https://mm.icann.org/mailman/listinfo/rds-whois2-rt -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> 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. *************************************************************************************************** This message, and any attachment contained, are confidential and subject of legal privilege. It may be used solely for the designated police/justice purpose and by the individual or entity to whom it is addressed. The information is not to be disseminated to another agency or third party without the author’s consent, and must not be retained longer than is necessary for the fulfilment of the purpose for which the information is to be used. All practicable steps shall be taken by the recipients to ensure that information is protected against unauthorised access or processing. INTERPOL reserves the right to enquire about the use of the information provided. If you are not the intended recipient, be advised that you have received this message in error. In such a case, you should not print it, copy it, make any use of it or disclose it, but please notify us immediately and delete the message from any computer. ************************************************************************************************* _______________________________________________ RDS-WHOIS2-RT mailing list RDS-WHOIS2-RT@icann.org<mailto:RDS-WHOIS2-RT@icann.org> https://mm.icann.org/mailman/listinfo/rds-whois2-rt -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> 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, If a WHOIS ARS ticket, or Whois inaccuracy complaint was a result of no validation and/or verification of registrar, I do recommend a follow up audit, since I tend to believe that will not be a standalone case. In this context, the Audit Program doesn’t accommodate this recommendation efficiently. The text of the recommendation may be refined later. Regards, Lili From: Volker Greimann [mailto:vgreimann@key-systems.net] Sent: Tuesday, 5 June, 2018 11:08 PM To: SUN Lili <L.SUN@interpol.int> Cc: rds-whois2-rt@icann.org Subject: Re: [RDS-WHOIS2-RT] Compliance subgroup draft report Hi Lili, if that is what you meant, then your suggested recommendation should be reworded, as I read it to mean that an audit should be triggered automatically upon receipt of one inaccuracy complant or ARS report, outside the regular audit cycle, regardless of when they had been previously audited. Being audited each time whenever we receive a first notice is not something I or any registrar would accept. Especially since the recommendation did not even specify that the complaint must be ultimately correct. If I now understand you correctly, your recommendation is actually superfluous as ICANN is already doing that as has been confirmed repeatedly by compliance in the regular registrar-compliance meetings held at ICANN. That does not contradict the statement that registrars are not rated. The selection program for the audit is somewhat opaque and you will not know if you will be audited (and in effect be forced to waste about a complete man-month of ressources for this make-work exercise) until you receive the notice. Compliance (Maguy) has said (on the record, which I have no time to dig up right now) that they will ensure registrars that receive significantly higher numbers of complaints than the average will be more likely to be part of the next audit cycle. So what I now assume you are recommending is already being done. This is also confirmed by the compliance response you included, in factor number 3 of the audit criteria. Best, Volker Am 05.06.2018 um 16:54 schrieb SUN Lili: Recommendation: Following a valid WHOIS ARS ticket, or Whois inaccuracy complaint, an full audit targeting the relating registrar should be initiated, to check if the registrar follows the contractual obligations, the consensus policies, etc. Sanctions should be applied if deficiencies identified. Findings: -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- 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<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> 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. *************************************************************************************************** This message, and any attachment contained, are confidential and subject of legal privilege. It may be used solely for the designated police/justice purpose and by the individual or entity to whom it is addressed. The information is not to be disseminated to another agency or third party without the author’s consent, and must not be retained longer than is necessary for the fulfilment of the purpose for which the information is to be used. All practicable steps shall be taken by the recipients to ensure that information is protected against unauthorised access or processing. INTERPOL reserves the right to enquire about the use of the information provided. If you are not the intended recipient, be advised that you have received this message in error. In such a case, you should not print it, copy it, make any use of it or disclose it, but please notify us immediately and delete the message from any computer. *************************************************************************************************