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KnujOn Releases Internet “Doomsday Book”

Reporting from Brussels, Belgium. Since January KnujOn has been conducing its own audit of ICANN Registrar contractual compliance and illicit commerce within the generic Top-Level Domain (gTLD) space. Our findings are shocking. The full report is available here: http://www.knujon.com/knujon_audit0610.pdf but we will just hit some of the highlights (or lowlights):

• 162 Registrars may be in breach of the RAA, several of them seriously so

• As stated in our recent release, Who is Blocking WHOIS? over 80 Registrars are blocking, hiding or just providing poor WHOIS access

• Several Registrars have bad WHOIS for their own websites

• Thousands of NameServers are unaccountable

• We’ve caught Registrars flat-out refusing services they’re contracted to perform

• Several Registrars have not posted required customer policies on their websites or their addresses as required

• There are a dozen or so terminated Registrars still selling gTLD and claiming ICANN accreditation

• Some Registrars have developed tools that help trademark infringement. We link these cases to criminal activity as well.

We will be discussing specific points of the report at various forums throughout the week in Brussels. Please seek me out if you have questions about any of them.

By Garth Bruen, Internet Fraud Analyst and Policy Developer

Filed Under


Typical John Berryhill  –  Jun 21, 2010 10:47 PM


It is customary to check your facts before publication.  You had earlier reported that Abacus America was “delinquent” - meaning that they were late filing their annual registration fee in Kansas, although it is in fact a California corporation. 

What is surprising is that despite having these facts pointed out to you here, you did not bother to even check I’d Abacus America paid the Kansas fee by the deadline, and went to publication with false information. 

Your publication is false as issued, and readily shown as such:


Current Entity Name   Business Entity ID Number
Current Mailing Address:  Tax Department -  3680 Victoria St N, Shoreview, MN 55126   
Business Entity Type: FOREIGN FOR PROFIT
Date of Formation in Kansas: 08/07/2007
State of Organization: CA


Resident Agent and Registered Office

Abacus is also in Floridia Garth Bruen  –  Jun 21, 2010 11:05 PM

Oh John, they’re in Kansas, they’re in California, they’re in Minnesota, they’re in Florida…Who can keep track!?!? What a joke of obfuscation. This is but one point of the report. When you’ve run out of sexual innuendo I suppose you go to your back-channel contact at ICANN to get your dirt.

Bizarre John Berryhill  –  Jun 21, 2010 11:23 PM


I simply went to the Kansas Secretary of State website to check a factual assertion in your report, and found that your report was not true in relation to that fact. 

A single corporation may have presence in several places. The registrar accreditation is held by the California entity, since that is chronologically obvious. 

That you made an untrue factual assertion is neither “dirt” nor “back channel” information.  It is a simple and demonstrable point made clear by consulting the relevant public record.

I simply went to the Kansas Secretary Garth Bruen  –  Jun 21, 2010 11:34 PM

I simply went to the Kansas Secretary of State website to check a factual assertion in your report, and found that your report was not true in relation to that fact.

I’m glad they complied. Would they have were it not for the report?

It wouldn't have mattered John Berryhill  –  Jun 21, 2010 11:59 PM


There was nothing with which to “comply”.  The accreditation is held by the California corporation, which has never been out of status.  They could have allowed the Kansas registration to lapse, and still been in compliance with ICANN, because the Kansas registration is not an issue in relation to the accredited entity. It is only relevant to your lack of concern for factual accuracy and truth.

Ah, truth Garth Bruen  –  Jun 22, 2010 10:37 PM

It's factually accurate and true they were in delinquency. It's factually accurate and true that they are now current. It's factually accurate and true they have a business registration in Florida but their outward facing ICANN location is FLORIDA (see http://www.internic.org/registrars/registrar-52.html). It's factually accurate and true that following this entry in the report we FULLY DISCLOSE that ICANN responded to this issue and confirmed they were not in violation, so you are repeating what we said in the report. It's factually accurate and true we never said they had an issue in California. It's factually accurate and true they still sponsor the illegal pharmacy domain multihgroup.com which sells controlled substances. So John, in the interests of factual accuracy and truth I need to correct your sin of omission by highlighting what we said about this issue in the report and what you failed to acknowledge: "We have reported the corporate delinquency to ICANN’s compliance department and they have informed us that since Abacus America is principally registered in California this issue does not constitute a breach of their contract. However, we still believe this a poor reflection [on] the responsibility of the Registrar to the Internet community." Yes, it's a moot issue but one completely factually accurate and truthful.

John Bob Mountain  –  Jun 22, 2010 6:29 PM

Geez John, remind me never to get on your bad side ;)

Eh... John Berryhill  –  Jun 23, 2010 3:47 PM

Online communications have a depersonalization aspect which sometimes render them to be unduly contentious. Personal communications are frequently... different: http://tweetphoto.com/28699627

Yup Garth Bruen  –  Jun 23, 2010 4:23 PM

John and I had a nice chat

eNom plays weak Hand against KnujOn Garth Bruen  –  Jun 23, 2010 8:09 AM

eNom (Demand Media) has issued a weak and irrelevant response to the KnujOn Registrar Audit. This response is actually the first time eNom has responded to any of our concerns about illicit pharmacy domains they sponsor, and they were initially sent comprehensive data six months ago. It is important to note that eNom does not refute any of our facts in the report concerning their sponsorship of illicit and illegal pharmacies. Instead, they have responded with personal ad hominem attacks which are factually incorrect. It is a common tactic, if you cannot challenge the data attack the author. This is Senior Vice President of Demand Media Quinn Daly’s comment about KnujOn: ” KnujOn is an individual whose research has been called into question in the past.” KnujOn is a company not an individual, and Ms. Daly does not provide a single example of what she claims. This is their characterization of LegitScript: ” LegitScript is a pharmacy trade organization.” Wrong. LegitScript works for the consumer to ensure that online pharmacies are safe. The idea that Ms. Daly completely dismissed LegitScript demonstrates eNom’s lack of concern about rampant criminality occurring in their space and their lack of concern for the Internet consumer. This is at the heart of our issue with eNom, they don’t care.

Ms. Daly also states: “We cooperate with multiple law enforcement agencies, as this is our policy and meets ICANN requirements.” Not only is this wrong, because they have ignored letters from the National Association of Boards of Pharmacy (NABP), which is the regulatory enforcement body for pharmacies, but the last portion about eNom’s policy meeting ICANN requirements sounds as if this is their only concern and crime can exist in their space as long as it does not break ICANN policy. Additionally, their sponsorship of illicit pharmacies DOES violate ICANN policy.

The statement is also self-contradictory. In one sentence they dismiss LegitScript and KnujOn out of hand, and in another Ms. Daly states “We can confirm that we received the complaint issued by LegitScript and KnujOn, and the complaint is currently under review.” Why? If our reports are irrelevant, why bother reading them? The fact that they are just now reading the notices after six months only because of recent publicity is extremely cynical.

The idea that they have to be “told by the police” to remove an illegal domain they know is illegal is ridiculous. This response may be problematic for eNom because they are admitting they know about illegal activity but will not take action and not report the illegal activity to law enforcement themselves. eNom is now in the odd position of using their policy to preserve the illicit pharmacies. This response also violates their contract with ICANN because their contract obligates them to “abide by applicable laws and governmental regulations.” This is a condition of the contract, it does not say anything about court orders or notifications from law enforcement.

This story is ongoing…

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