[GNSO-Accuracy-ST] Identity Proofing Clarity - Follow Up Homework

Michael Palage michael at palage.com
Fri Oct 22 10:39:17 UTC 2021

Hello All,


I was reviewing my notes from yesterday's meeting as well as reviewing some
of the previous email list exchanges between and I was hoping that my
Registrar colleagues could provide a little clarity, especially Volker given
his participation in the 2013 RAA negotiations.


I believe what I have heard and read from my Registrar colleagues is that
there is no "identity proofing" requirements in their contracts - accuracy
is merely syntactical and operational. I apologizes in advance if I am
mischaracterizing this and welcome any corrections. However, in Assignment
#1, the follow excerpt from ICANN Organization Enforcement of Registration
Data Accuracy Obligations Before and After GDPR states:


[I]f the complaint is about identity (e.g., the registrant is not who they
say they are), Contractual Compliance may ask the registrar to provide
further information concerning their findings and the results of their
investigation specific to the facts of the complaint.


So it appears based on this excerpt that ICANN Contractual Compliance does
reserve some right to inquiry about the "identity" of the Registrant.
Therefore, I believe potential clarifying questions to ICANN Org could might
include: does ICANN Compliance believe that it has the ability to inquiry
about the "identity" of a registrant? If so, what is the contractual basis
of this authority. Finally, what are the numbers associated with these types
of inquiries, e.g. percentage of overall accuracy complaints and raw


Thoughts? Comments?


Best regards,









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