I reviewed the NORC study again it was a good refresher. In my mind we have at least two choices in wording on the rec. as the comments indicated we do not use the same terminology in the recommendation as the study did. Current language 1. ICANN should take appropriate measures to reduce the number of unreachable WHOIS registrations (as defined by the NORC Data Accuracy Study, 2009/10) by 50% within 12 months and by 50% again over the following 12 months. ICANN should take appropriate measures to reduce the number of undeliverable (also mentions unreliable) WHOIS registrations (as defined by the NORC Data Accuracy Study, 2009/10) by 50% within 12 months and by 50% again over the following 12 months I think it would be abundantly clear if we used the term substantial failure in the recommendation ICANN should take appropriate measures to reduce the number of WHOIS registrations with a substantial failure (as defined by the NORC Data Accuracy Study, 2009/10) by 50% within 12 months and by 50% again over the following 12 months Page 3 of the study outlines Accuracy Groups Margin of error (4) No failure Met all three criteria fully - deliverable address, name linked to address, and registrant confirmed ownership and correctness of all details during interview 353 23,117,442 22.8% 1.4% Minimal failure All criteria met but minor fault noted by registrant during interview 17 1,101,176 1.1% 0.2% Name unable to be linked to address, but able to locate registrant and confirm ownership 312 23,024,007 22.7% 2.2% Limited failure Deliverable address, name linked and/or located, but unable to interview registrant to obtain confirmation. 365 24,893,476 24.6% 1.7% Substantial failure Undeliverable address and/or unlinkable name, however registrant located. Unable to interview registrant to obtain confirmation. 109 7,202,472 7.1% 0.9% Deliverable address, but unable to link or even locate the registrant, removing any chance of interview. 177 13,949,721 13.8% 2.2% Full failure Failed on all criteria - undeliverable address and unlinkable, missing, or patently false name, unable to locate to interview Susan Kawaguchi Domain Name Manager Facebook Legal Dept. Phone - 650 485-6064