Support and comments for the WHOIS RT Report from KnujOn
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