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

Garth Bruen at KnujOn gbruen at knujon.com
Wed Dec 8 14:44:47 UTC 2010


<<Yes, we are an ICANN-accredited registrar supply services to
resellers.>>

You just said you were a reseller

<<We have always had a valid mailing address on our website.>>

Where?

<<We have always been ICANN compliant.>>

Staff just said otherwise

<<We can make our address easier for Garth to find if desired.>>

It's not about me, this is about adhering to the contract

Stay tuned for an announcement at noon


> -------- Original Message --------
> Subject: Re: [NA-Discuss] Two Years later,	Dozens of Registrars Still
> in the Shadows
> From: helen at dotalliance.com
> Date: Tue, December 07, 2010 10:25 pm
> To: "ICANN At-Large Staff" <staff at atlarge.icann.org>, gbruen at knujon.com
> Cc: "Carlton Samuels" <carlton.samuels at gmail.com>,       
> na-discuss at atlarge-lists.icann.org
> 
> 
> Hi!
> 
> Yes, we are an ICANN-accredited registrar supply services to resellers.
> 
> Please feel free to ask me directly if you have any questions.
> 
> We have always had a valid mailing address on our website.
> 
>  We have always been ICANN compliant.
> 
> We can make our address easier for Garth to find if desired.
> 
> Sent from my BlackBerry and all typos are its fault!
> 
> Best regards, Helen
> 
> www.DotAlliance.com
> 
> 
> 
> -----Original Message-----
> 
> From: ICANN At-Large Staff <staff at atlarge.icann.org>
> 
> Date: Tue, 7 Dec 2010 12:26:32 
> 
> To: <gbruen at knujon.com>
> 
> Cc: Carlton Samuels<carlton.samuels at gmail.com>; <na-discuss at atlarge-lists.icann.org>; Helen<helen at dotalliance.com>; ICANNAt-Large Staff<staff at atlarge.icann.org>
> 
> Subject: RE: [NA-Discuss] Two Years later,	Dozens of Registrars Still in the Shadows
> 
> 
> 
> 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 at knujon.com [mailto:gbruen at knujon.com] 
> 
> Sent: Tuesday, December 07, 2010 5:50 AM
> 
> To: Helen; ICANN At-Large Staff
> 
> Cc: Carlton Samuels; na-discuss at 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 at dotalliance.com>  
> 
> 
> 
> Sent: Tuesday, December 07, 2010 4:24 AM
> 
> 
> 
> To: gbruen at knujon.com 
> 
> 
> 
> Cc: Michele Neylon :: Blacknight <mailto:michele at blacknight.ie>  ; Carlton
> 
> Samuels <mailto:carlton.samuels at 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 at 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 at blacknight.ie>
> 
> <michele at blacknight.ie>
> 
> Sent: Sunday, December 05, 2010 8:31 PM
> 
> To: "Carlton Samuels"  <mailto:carlton.samuels at gmail.com>
> 
> <carlton.samuels at gmail.com>
> 
> Cc:  <mailto:na-discuss at atlarge-lists.icann.org>
> 
> <na-discuss at 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 at gmail.com> <carlton.samuels at 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)
> 
>  
> 
>  
> 
> ----------------------------------------------------------------------
> 
>  
> 
> Message: 1
> 
> Date: Fri, 03 Dec 2010 11:49:35 -0700
> 
> From: "Garth Bruen at KnujOn"  <mailto:gbruen at knujon.com>
> 
> <gbruen at knujon.com>
> 
> Subject: [NA-Discuss] Two Years Later Dozens of Registrars Still in
> 
>       the     Shadows
> 
> To: na-discuss at 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 at 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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> 
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> 
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> 
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> 
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> 
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> 
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> 
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>  
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> 
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> 
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> 
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