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Support and comments for the WHOIS RT Report from KnujOn

  • To: <whois-rt-final-report@xxxxxxxxx>
  • Subject: Support and comments for the WHOIS RT Report from KnujOn
  • From: "Garth Bruen at Knujon.com" <gbruen@xxxxxxxxxx>
  • Date: Sun, 10 Jun 2012 15:14:47 -0400

KnujOn and its membership fully support the WHOIS RT Report and recommendations with two (2) critical additional concerns:
1.	On page 79 of the final report it is noted that RAA 3.7.8 is worded in 
such a way that WHOIS inaccuracy is in fact NOT enforceable. This has been 
suspected for some time, yet ICANN has not acknowledged the problem 
officially. Without the ability to enforce against inaccuracies, 
requirements for accuracy are in fact pointless. The first step in moving 
forward on this report is for ICANN to formally confirm that RAA 3.7.8 is 
not enforceable on WHOIS accuracy. Once confirmed, let us set about to 
correct this mistake.
2.	ICANN is not enforcing other areas of the contract which are currently 
enforceable. KnujOn has provided detailed case studies which demonstrate 
that Registrars are violating the RAA, in terms of WHOIS and other 
obligations, yet have escaped sanction for unexplained reasons. A contract 
which goes unenforced is not a real contract and cannot be taken seriously 
by the community.
We are at a turning point, either the RAA means everything or it means 
nothing. If this report is simply filed and ignored like so much previous 
advice transparency and accountability are vapor.
-------------------------------------

Garth Bruen




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