It's true, ICANN's compliance is a lot better than it used to be, but since it used to be nonexistent, that's faint praise. And if Joker got their breach letter in September rather than October, so it was two years and 11 months late rather than three years late, well, OK. But ICANN's compliance is still weak. Last night I did a little experiment looking to see if registrars provide the required port 43 WHOIS server, and found several dozen that as, far as I can tell, don't. (I also found several whose alleged web sites are parking pages, making me wonder just how rigorous the accreditation process is.) As I said originally, compliance is hard but it's not rocket science, so I wish ICANN would learn from organizations that have been doing it for a long time rather than making it up as they go along.

We're in agreement about one thing - ICANN's compliance program used not to be as good as it needed to be. But from there, particularly this arbitrary idea that ICANN is "making it up as it goes along", we have to differ and I would point you again to the compliance newsletters and semi-annual reports for evidence, rather than conjecture. The fact is that compliance is not a switch. You can't turn it on and everything suddenly works fine. The compliance team in ICANN are taking a clear, methodical approach to compliance matters and clamping down on abuse as it is uncovered. If you read the August newsletter (http://www.icann.org/en/compliance/archive/compliance-newsletter-200808.html#3) you will see that ICANN has engaged the National Opinion Research Center (NORC) - "one of the largest and most respected social research organizations in the United States" - to develop a new methodology for assessing Whois accuracy. In the meantime, the results of the previous audits are available online, and the evidence of the action taken following those audits is also online. ICANN would ask only that people read it before making broad and inaccurate comments about the state of the compliance program. It is going to take time for this approach to run through the system. Registrars have been to be given an opportunity to correct any holes in their compliance because that it industry best practice and it is also the responsible and reasonable thing to do. If they don't, they will lose their accreditation, pure and simple. Will you be able to find examples of non-compliance? Yes. And that is never going to end, in the same way that there will always be companies in every sector of business that push the boundaries. But if you want a competitive market, you have to deal with a bit of that. Is there too much non-compliance at the moment in the registrar market at the moment? Yes. Is ICANN doing what it can to fix that? Yes it is. You can already see the fruits of the compliance's department's work, and you will continue to see that as the market gradually gets used to a firmer response. If you want to know what ICANN is doing, subscribe to the newsletter, or attend one of the compliance events at an ICANN meeting, or - even better - help play a pro-active role as a member of the community by reporting Whois inaccuracy through the WDPRS system. Kieren McCarthy General manager of public participation, ICANN

Having a process is better than not having a process, but having a process is not the same as having an effective process, or having adequate results. The compliance newsletter reports lots of registrars cancelled for non-compliance, although for most of them the problem is the most mortal of ICANN sins, not paying their bill, which is not exactly the kind of compliance the rest of the world is worried about. But this really says it all about the bureaucratic mindset: help play a pro-active role as a member of the community by reporting Whois inaccuracy through the WDPRS system. ICANN can't audit the WHOIS data, so it's my job to do so? Aw, come on. WDPRS is a useful band-aid to help with the enormous backlog of bogus WHOIS, but if the compliance process worked, ICANN would find the bad stuff themselves rather than expecting unpaid volunteers to do their work for them. Perhaps you should hire the Knujon guys. And, as I've pointed out, the compliance issues only begin with bogus WHOIS. There's registrars with no WHOIS at all, and lots of other egregious violations that I know that Kieren knows about.

The Internet community has always taken ICANN and its work very personally, and I think your response reflects that John. The point I have tried to make is that ICANN is doing alot of compliance work, and it is making that work public through newsletters and reports. With any luck the results will be such that in a year's time, this same sort of discussion will occur on CircleID, but on a completely different topic. Kieren

I have repeatedly reported the false telephone number in the whois data for wipo.org. I even used it as an example in a compliance session at the Paris ICANN meeting. Still the domain name remains registered. Why?

Hi Michael, You can subscribe to ICANN's compliance newsletter at http://www.icann.org/newsletter, and read previous editions at http://www.icann.org/en/compliance/newsletter/. If you feel that ICANN is missing something in its compliance work, then the best way to change it directly is to provide details of what ICANN could do to improve in this area in the public comment period that the organization is holding right now on "Improving Institutional Confidence". An online, interactive forum is available here: http://comment.icann.org/en/iic/ You will note that compliance is specifically mentioned, and you can make your comment on this precise topic by just clicking on this link and registering to make a comment (just like CircleID) : http://comment.icann.org/.ee7b92f Hopefully a clear, direct, public and simple method to provide solid input directly to the President's Strategy Committee will alleviate some of your concerns. Thanks Kieren McCarthy General manager of public participation, ICANN

Allowing direct public input without taking serious action is really a cop out when there is more than sufficient evidence to warrant or justify timely action. The solution is not to put up a bunch of red tape and barriers by calling for more public input when you have more than enough to act. As a a Government employee, I see this type of stuff far too often. Sounds like your major role in this Karen is largely PR work, so thanks but no thanks. I have made my input and feedback quite evident by posting my concerns. As ICANN's PR Agent maybe you can share this with the appropriate individuals. There is more than enough evidence(previous and present) and more than sufficient public input has been provided that we don't need to put up barriers, minimize the severity of the issues, and continually dance around this while the malware authors, cyberterrorsists, trojan and spam distributors continue to run amok with the full blessing of some registars who continue to allow these individuals to continue to register domains with false Whois data. The problem is simple, there is a very serious issue of some registars registering with false Whois data which inturn has serious implications. How many times do you feel that the Public needs to hammer home this home before ICANN takes this seriously enough to act in a more timely manner. Let's get serious and cut through the bull. By the way Karen, do you have an E-Mail address and do you enjoy being constantly bombarded with all kinds of unsolicitated spam. Perhaps if you experience this on a regular basis, you may have a better appreciation of why many of us feel so victimized and violated by this kind of stuff.

I'm not sure I agree with your characterisation of direct input to the people in a position to make changes as "red tape". I'd argue it was the complete opposite in fact. I can however guarantee you that it will be more effective than your current approach. Use the system for public input, or don't, it's entirely up to you. My job as general manager of public participation is to create such systems in case people do want that direct approach. Either way, this conversation should be moot with a year as the compliance efforts underway - and outlined in the newsletters previously linked to - start to get a grip on what everyone agrees is a problem. Thanks Kieren McCarthy

Seems that I logged onto your "system of public input" but was only able to view written re: changes considered or made all of which primarily focused on issues pertaining to ICANN itself, and not really public concerns. I was even unable to post this as a comment or input as the message "no access" in red popped up. Talk about a wild goose chase and further evidence of red tape. Anyway, since your system of public input does not allow public input Kieren and you are the manager of public participation. I will clearly tell you what I think needs to be seriously looked at. A change in the Registrar Accreditation Agreement that will improve transparency and accountability is required. There is no requirement in the standard Registrar contract that requires public disclosure of Registrar ownership or location. I am concerned that this loophole in the agreement opens the door to fraud, secrecy and consumer abuse. Please consider adding the following language or equivalent 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.” Without public disclosure there cannot be true transparency, accountability or trust.