Comments of Malefactors Should be Weighted Accordingly

[George Kirikos <gkirikos@xxxxxxxxx>]

It is interesting to research the history of some of the companies submitting 
comments on the STI report:

(1) Telstra -- fined $101,200 for harassing Australians on the Do Not Call 
register

http://blogs.smh.com.au/digital-life/gadgetsonthego/2009/08/18/telstrafineda.html

(2) Costco -- fined $75,000 for not closing Hawaii cesspools

http://findarticles.com/p/articles/mi_kmens/is_200606/ai_n16600595/

(3) Publix -- fined $500,000 for violating child labor laws

http://news.google.com/newspapers?nid=888&dat=19930817&id=C_UNAAAAIBAJ&sjid=f3sDAAAAIBAJ&pg=3727,1282430

(4) Yahoo -- fined for unwillingness to cooperate in a cyber-criminal 
investigation

http://www.techcrunch.com/2009/03/02/yahoo-fined-by-belgian-court-for-refusing-to-give-up-e-mail-account-info/

[The irony is in Yahoo's statement, that due process is important!

"We have a legal and policy basis for not disclosing information in this type 
of case until the recognized international legal process is followed."

"This decision could have negative implications for all foreign companies by 
unduly expanding the application of a law…." ]

(5) Time Warner -- fined $300 million to settle securities-fraud charges

http://findarticles.com/p/articles/mi_kmusa/is_200503/ai_n14728974/

(6) Coca-Cola -- anti-monopoly fine of $68 million in Mexico

http://www.npr.org/templates/story/story.php?storyId=5017396

(7) UBS -- fined $780 million in tax evasion scandal

http://www.investmentnews.com/article/20090219/FREE/902199983

(8) Nordstrom -- fined for failing to report that apparel contained drawstrings 
(that might post a strangulation hazard to children)

http://seattle.bizjournals.com/seattle/stories/2008/12/01/daily22.html

(9) Disney (member of Coalition for Online Accountability) -- fined for 
violating children's TV advertising rules

http://articles.latimes.com/2004/oct/22/business/fi-fcckids22

(10) Unilever (member of AIM - European Brands Association) -- fined for 
price-fixing in Germany

http://www.rte.ie/business/2008/0220/germany.html

I limited myself to 1 example per company, and stopped at 10 companies. I leave 
it as an exercise to ICANN staff to review the backgrounds of these 
organizations who believe they should be setting the bar for "good conduct" on 
the internet.

I would be interested in having these so-called "reputable" companies make a 
public statement as to whether 20 days is sufficient notice to defend matters 
like the above that they've been involved in, and why domain registrants 
deserve such little due process. Or, do these companies believe that the 
principles of "due process" only apply when *they* are on the defensive?

Sincerely,

George Kirikos
http://www.leap.com/