[At-Large] ICANN Complaint System Circumvented

gbruen at knujon.com gbruen at knujon.com
Mon Mar 13 13:18:17 UTC 2017

Dear ALAC Leadership and the greater community,

I am submitting the following memorandum for your consideration: 

What you will find in this document is an analysis of the ICANN 
complaint system (WDPRS). The analysis uses one criminally-used domain 
with false WHOIS as an example to better understand the issues with 
ICANN policy and procedure. In short, the ICANN WDPRS has been 
effectively circumvented by the owners of this criminal domain. The 
domain has had 3 different sets of false WHOIS and simply transferred 
their domain each time a complaint was filed. The domain had been 
transferred to 4 different registrars and is currently operating selling 

In short, the current system has failed in its intent and the criminals 
now know how to get around enforcement. The problem is in the contract 
and in the compliance procedures.

This is related to the earlier studies I have released to the list. I 
will be presenting at the joint session of the Public Safety Working 
Group (PSWG) and the Verified TLD (vTLD) constituency on Tuesday 14 
March from 18:30 to 19:30 in Hall B4.1. I invite all comments and will 
be talking about this in meetings.

Apologies for any cross-posting.


Garth Bruen
gbruen at knujon.com

ICANN At-Large Advisory Council
Author: WHOIS Running the Internet

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