[Comments-com-amendment-3-03jan20] Verisign Agreement

John Carr john at johncarr.eu
Thu Feb 13 15:48:45 UTC 2020


Dear ICANN,

Because I represent children's organizations that do not  have the money to hire lawyers who could engage with this process I do not have a polished or crafted amendment to propose to the Verisign Agreement. All I can say is it is utterly scandalous that  .com remains the gTLD most frequently associated with the distribution of child pornography on the internet. Last year, for example, 50% of all the child pornography found on the internet by or  reported to the UK's IWF was found within .com. That has been the pattern for many years.

Howsoever the original arrangements were arrived at between the Federal Government and Verisign, and irrespective of how they were  subsequently  continued  between ICANN and Verisign, these arrangements are plainly not working well enough to protect children. They ought to be changed to place an explicit obligation on Verisign to reduce the levels of criminal abuse taking place on their watch and from which they profit as a company.

One obvious way, perhaps not the only way,  would be to place an explicit duty on Verisign to require all of the Registrars with whom it contracts to gather accurate,  verified information about the  real world identities of every entity buying, renewing  or managing a domain within .com.

Verisign should also  be required to terminate the contracts with any and all Registrars shown to be persistently failing to collect  and securely store that information.

Yours sincerely,

John Carr
Secretary of the Children's Charities' Coalition on Internet Safety.
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