Public participation site

The domain name registration process as it stands should be completely changed and ICANN needs to involve itself more, rather than continue to further distance itself from the administration of Internet names. Allowing registrars to take people's money (with the understanding that they will then pass that money on to ICANN) is asking for trouble and should not be happening. Registration fees and renewal fees should be paid directly to ICANN (or to a specially appointed trustee) rather than directly to a registrar. Registrars should be able to act as conduits or agents for the registration/renewal process (and take commissions) but they shouldn't be empowered to collect money on behalf of ICANN. When a person clicks on a "register" or "renew" button, they should be 100% confident in knowing that their valuable domain name is being renewed, in real time, with ICANN. Registrants should be able to confirm that their domain name has been registered or renewed in a real-time look-up operated by ICANN (or its trustee).

Furthermore, when a person clicks on a button to register or renew their domain names, they should be given the option of whether or not they want their personal details made available in the Whois look-up. The issue of privacy should be directly controlled by ICANN, not by the registrars.

Registrars have too much control over domain names the way things stand and ICANN needs to re-assume control over fundamentals such as registration, renewal and privacy.

The entire focus of reform of the RAA seems to revolve around registry customers being secured, and that IS definitely a good thing for ICANN to attend and long in coming. There are other issues that ICANN could address which should be considered as well and with equal resolve. These issues have direct bearing on the overall health and stability of a registrar, the longevity of their service, and the way they will reflect on their own and ICANN's reputation in accrediting them.

When someone becomes aware of (alleged) criminal activity, or willful facilitation of (alleged) criminal activity by one of your accredited registrars, they are offered a form... the same form used to report someone failing to change their phone number timely when they relocate.

This is inadequate.

The two are in no way equal and using the form is actually part of the problem as it only serves to further the activity by alerting the registrar (and their criminal customer) to the need to jump one step ahead of getting caught. Now as much as I dislike spam, I am not referring to clumsy marketing here. I'm talking about Patently criminal activity.

Why on earth would an ICANN accredited registrar want to associate with and provide services to spammers hocking illegal sale of prescription drugs, counterfeit drugs, porn (including exceptionally offensive varieties), scams like fake banks, investment scams, 419-fake discount sales, phishing and identity theft, etc... ?

Two reasons;

They have a motivation to self-interest which exceeds their motivation to ethical behavior...

and they know that the abuse reporting process will simply be a report sent directly back to them. The report is forwarded to the spammer, several of whom have the habit of retaliating upon the outspoken opponents to their enterprise. Email origins are spoofed using the reporter's address. Websites are DDoSed out of existence using netbots. Email boxes are bombed. As the result of well meaning people reporting abuse TO YOU businesses and individuals are made to pay dearly, without recourse. How will one prove that a registrar in this way facilitated an attack on ones server that filled the hard drives with emails identical to the ones about which one complained? How will one manage to take time to prove this even if one could while trying to hold a business together against the abuse of its essential services? ICANN's reporting form is used in this way by the very spammers it should most carefully be excluding from your accredited registrar's roles.

ICANN should implement a reporting process which permits a report about a registrar rather than to him. You have left the fox in charge of the henhouse for far too long.

Information about reports that have been filed by reputable RBL and abuse tracking organizations are posted on the internet. Information about the continuing practice of these same registrars is also available.

Organizations as reputable as spamhaus.org have tracked and reported criminal activity facilitated by accredited registrars.
They have also documented the "semblance" of compliance and the reprobates responsible simply hiding the spammer for a period of cool-off time.

Now, how can ICANN concern itself intently with insuring that legitimate registry users are protected from the collapse of the registrar, without addressing the underlying fact that there are registrars which are dooming themselves to becoming the center of political and legal scandal, possible legal or criminal liability, a reputation as a criminal heaven and the specter of this rubbing off on ICANN by the mounting evidence that ICANN has made itself impervious to this information and failed to act with decision and deliberate purpose. There are registrars out there with your seal of approval upon them, a very few of whom are actively engaged in shielding criminal activity. They are indistinguishable to the average customer from those who keep their registry pristine and do not suffer to provide services to spammers regardless of the relative severity level of the abuse.

Which is more likely to suggest stability and ethical and equitable treatment of legitimate custom? Which will ICANN be more likely to clean up after in the manner of registryfly?