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