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[gnso-rap-dt] FW: ICANN Compliance: Response to Questions Posed by the RAPWG

  • To: <gnso-rap-dt@xxxxxxxxx>
  • Subject: [gnso-rap-dt] FW: ICANN Compliance: Response to Questions Posed by the RAPWG
  • From: "Greg Aaron" <gaaron@xxxxxxxxxxxx>
  • Date: Sat, 9 Jan 2010 20:47:24 -0500

Dear WG:

 

Attached please find additional info regarding WHOIS access provided by the
ICANN Compliance Department.

 

Also: ICANN's latest Contractual Compliance Semi-Annual Report was published
at the end of December 2009, and is available at:

http://www.icann.org/en/compliance/reports/contractual-compliance-report-24d
ec09-en.pdf

It contains statistics about WDPRS.

 

All best,

--Greg

 

  _____  

From: Stacy Burnette [mailto:stacy.burnette@xxxxxxxxx] 
Sent: Friday, January 08, 2010 5:25 PM
To: Greg Aaron
Cc: David Giza; William McKelligott; Marika Konings
Subject: RE: ICANN Compliance: Response to Questions Posed by the RAPWG

 

Hi Greg:

 

I hope this e-mail message finds you in good spirits. 

 

Attached are responses to the RAPWG's questions regarding the Whois Data
Problem Report System (WDRPS) and ICANN's Whois enforcement work.  Please
let us know if you have further questions or if you need additional
information.

 

Warmly,

 

Stacy Burnette

Director

Contractual Compliance

ICANN

4676 Admiralty Way, Suite 330

Marina del Rey, CA 90292

+1(310) 301-3860

 

  _____  

From: William McKelligott [mailto:William.McKelligott@xxxxxxxxx] 
Sent: Sunday, December 13, 2009 7:08 PM
To: Marika Konings; Greg Aaron
Cc: Stacy Burnette; David Giza
Subject: ICANN Compliance: (partial) response to questions posed by the RAP
WG
Importance: High

 

Marika and Greg,

As requested.  Per Dave's email, we will provide additional responses to
questions posed by the WG by 8 January 2010.  

Please contact me if you have any questions or if Compliance can be of
further assistance.

Best,

William

  _____  

Q1.  What are the ICANN compliance reports published in the last three years
that discuss WHOIS availability and accuracy reporting?  I am aware of the
following; are there any others?
* 2007 "ICANN's Whois Data Accuracy and Availability Program":
http://www.icann.org/en/whois/whois-data-accuracy-program-27apr07.pdf 
* October 2007 Contractual Compliance Semi-Annual Report:
http://www.icann.org/en/compliance/reports/contractual-compliance-audit-repo
rt-18oct07.pdf
* July 2008 Contractual Compliance Semi-Annual Report:
http://icann.org/en/compliance/reports/contractual-compliance-audit-report-2
9jul08-en.pdf
* February 2009 Contractual Compliance Semi-Annual Report:
http://icann.org/en/compliance/reports/contractual-compliance-report-27feb09
-en.pdf

I have been unable to find the September 2009 Semi-Annual Report.  Was one
published this autumn?
 
RESPONSE: The above reports are all of the reports published in the last
three years regarding Whois availability and Whois accuracy.  The 2009
Contractual Compliance Semi-Annual Report will be published on or about 31
December 2009 and it will include statistics regarding the WDPRS.    

Q2.  ICANN has a system to monitor and enforce registrar compliance with
port 43 Whois service requirements; the 2007 report said it would  include
both automated WHOIS server testing and manual reviews of registrar WHOIS
output on a regular basis.  Can you provide any observations and data
related to this monitoring, and is it described in any already-published
documents?  Specifically, can you tell us how many registrars ICANN found
were not providing port 43 and/or Web WHOIS access?  Has ICANN encountered
notable downtimes or lapses of registrar port 43 availability, or any other
issues of note?

RESPONSE: Section 3.3 of the RAA, "Public Access to Data on Registered
Names" defines the terms and conditions under which Registrars must provide
a Port 43 and interactive web-based Whois service available for public
query.  The timeframes mentioned in the RAA single out the frequency in
which Whois data fields must be updated (daily).  The RAA, however, is
different from the registry operator agreements in that it doesn't specify
any service level agreement (or performance metrics) of the continued
availability of the Whois service provided by registrars.  

ICANN has developed a Whois server audit tool which monitors access to
registrars' Whois servers over a Port 43 connection.  The script developed
for this task retrieves data for 4 registered domain names for each
accredited registrar.  These domains are selected from the zone file which
is obtained by ICANN periodically. The purpose of the audit is to flag Whois
servers that are down for an amount of time that is suspect and probably not
just a manifestation of periodic server maintenance or scheduled update.
What is the "reasonable amount of time" for a server to be down? Probably no
more than an hour or so per day, although these are ICANN internal, 'soft
metrics',  not agreed-upon timeframes with registrars.  The script records
the results and flags registrars that prevent access to data on registered
names.  Transient network problems are less of a concern, so ICANN focuses
on long-term behavior, i.e., registrars which ICANN is unable to communicate
with for several days in a row.  

Once ICANN identifies the registrar(s), ICANN Compliance conducts Port 43
queries from alternate IP addresses to ensure that the communication error
was not due to a problem with  ICANN's server.  If the problem is verified,
ICANN reaches out to the registrar.  The same occurs when ICANN obtains
complaints from the community that experience either trouble locating the
interactive web-based search tool for Whois queries for a registrar or are
unable to obtain any results from these queries.  The RAA requires that
registrars provide access to data on registered names but also recognizes
that, in some instances, the data can later be used for the wrong purpose...
This may be one of the reasons why registrars commonly block specific IP
addresses from resolving queries on their Whois server and place them on a
black list.  There is no set definition on the number of queries that would
be 'reasonable' before a specific IP address is blocked and potentially
blacklisted.  After reaching out to registrars to resolve access issues,
they frequently create 'white lists' of IP addresses that are brought to
their attention to allow them to access Whois data.  ICANN Compliance
regularly follows up with the complainant to see if the problem persists
and, fortunately, this appears to be an effective (informal) mechanism to
resolve these problems. 

ICANN also reaches out to registrars that provide access to data on
registered names but provide 'thin', not 'think', Whois data.  The former
does not provide details on the registered name holder and additional
contacts, which is required by the RAA.

Aside from metrics on informal outreach to resolve blocked Whois servers and
incomplete, or 'thin', Whois data with registrars, which have been more than
two dozen in the past 6-8 months, Compliance could provide bi-weekly
statistics to the WG from here on out to on the number of registrars that
showed a pattern of restricting access to their Whois server over a Port 43
connection. 

These statistics have not been published before.  Details to follow.   
 
Q4:  In the last three years, how many notices of breach of the Registrar
Accreditation Agreement has ICANN sent to registrars for failure to adhere
to WHOIS-related obligations?  (Including failure to provide Web-based or
port 43 access, or related to WHOIS data inaccuracies.) 

ICANN sent eleven (11) escalated compliance notices (e.g. notices of breach,
termination or non-renewal) to registrars for failure to comply with Whois
provisions of the Registrar Accreditation Agreement. This information is
published on the Contractual Compliance website at
http://www.icann.org/en/compliance/.  For your convenience, please see the
links below for detailed information regarding the escalated compliance
notices sent.
 
Notices of Breach, Termination and Non-Renewal
19 November 2009: ICANN Notice of Non-Renewal of RAA
<http://www.icann.org/correspondence/burnette-to-dicker-19nov09-en.pdf>
(Domain Jingles, Inc.)
9 October 2009: ICANN Notice of Non-Renewal of RAA
<http://www.icann.org/correspondence/burnette-to-bahlitzanakis-09oct09-en.pd
f>  (BP Holdings Group, Inc. dba IS.COM)
8 October 2009: ICANN Sends Notice of Breach to Registrar
<http://www.icann.org/correspondence/burnette-to-bahlitzanakis-08oct09-en.pd
f>  (CodyCorp)
11 September 2009: ICANN Sends Notice of Termination to Registrar
<http://www.icann.org/correspondence/burnette-to-sundin-11sep09-en.pdf>
(Red Register, Inc.)
30 July 2009: ICANN Notice of Non-Renewal of RAA
<http://www.icann.org/correspondence/burnette-to-friedman-30jul09-en.pdf>
(South America Domains Ltd. dba namefrog.com)
9 April 2009: ICANN Sends Notice of Termination to Registrar
<http://www.icann.org/correspondence/burnette-to-valdes-09apr09-en.pdf>
(Parava Networks, Inc. dba 10-Domains.com) 
8 April 2009: ICANN Sends Notice of Termination to Registrar
<http://www.icann.org/correspondence/burnette-to-bordes-08apr09-en.pdf>
(DropLimited.com, Inc.) 
27 February 2009: ICANN Sends Notice of Breach to Registrar
<http://www.icann.org/correspondence/burnette-to-valdes-27feb09-en.pdf>
(Parava Networks, Inc.) 
4 February 2009: ICANN Sends Notice of Breach to Registrar
<http://www.icann.org/correspondence/burnette-to-bordes-04feb09-en.pdf>
(DropLimited.com, Inc.) 
30 September 2008: ICANN Sends Notice of Breach to Registrar
<http://www.icann.org/correspondence/burnette-to-hu-30sep08-en.pdf>
(Beijing Innovative Linkage Technology) 
30 September 2008: ICANN Sends Notice of Breach to Registrar
<http://www.icann.org/correspondence/burnette-to-legenhausen-30sep08-en.pdf>
(CSL Computer Service Langenbach GmbH) 

Attachment: RAPWG Responses (final1).pdf
Description: Adobe PDF document



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