KnujOn (nûj-ôn)

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KnujOn will begin featuring serious policy issues here that the public can participate in changing and improving.

Issue 1: Ending Registrar Secrecy

One of the reasons we have so much chaos in the Registrar community is because of secrecy and a lack of public accountability. There are at least 100 Registrars currently using "mail drop" addresses or post office boxes for their disclosed location. KnujOn found 70 Registrars with no disclosed location at all. Dozens of Registrars claim to be in one country but are really in another. KnujOn has also found registrars with false or incorrect address information in their own Whois records. The hidden ownership of some Registrars has also caused considerable controversy when eventually disclosed.

At the core of this problem is the fact that ICANN doesn't require registrars to publicly disclose their place of incorporation. We have trouble finding any other industry (ones that involve so much importance and trust) where this type of obfuscation is a standard practice. Furthermore, it seems somewhat hypocritical for registrants to be required to enter accurate registration data when the same is not expected of the Registrars collecting that data.

In order to assist ICANN achieve its stated goal of transparency and accountability, we propose a modification to the Registrar Accreditation Agreement (RAA), the core contract ICANN uses to issue certifications to Registrars. A review of the RAA is currently underway and KnujOn is seeking the following language (or equivalent) be added to the RAA:
"All Accredited Registrars must submit main office location, including country, to be publicly disclosed in ICANN web directory. Post Office boxes, Incorporation addresses, and mail-forwarding locations will not be acceptable. Registrars must also provide for public display the name of CEO or President. ICANN must be notified within 30 days of a location or presiding officer change.

This is suggested language. Any version that addresses the issues discussed above and meets the requirements of public disclosure.

If you wish to support this proposal, please write a brief and polite email as an Internet user to expressing your concern of the lack of public Registrar disclosure and request that the new version of the RAA include a section requiring owner and location disclosure. You may use the suggested language above, your own version, or simply a personal statement of concern over the issue.

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