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

Roger D Carney rcarney at godaddy.com
Fri Oct 22 19:30:40 UTC 2021

Good Afternoon,

This ICANN compliance enforcement process does not assign identity verification responsibility to the Registrar, it only stipulates that ICANN (when considering an identity complaint) may request the Registrar to "...provide further information concerning their findings and the results of their investigation...". This is not asking for more work to be done, just more data on what has already been done by the registrar. If a Registrar does do identity verification like Volker suggests, that is above and beyond what is required and is not part of accuracy as it is defined today.


From: GNSO-Accuracy-ST <gnso-accuracy-st-bounces at icann.org> on behalf of Volker Greimann <volker.greimann at centralnic.com>
Sent: Friday, October 22, 2021 6:18 AM
To: michael at palage.com <michael at palage.com>
Cc: gnso-accuracy-st at icann.org <gnso-accuracy-st at icann.org>
Subject: Re: [GNSO-Accuracy-ST] Identity Proofing Clarity - Follow Up Homework

Hi Michael,

all such investigations are based on a substantiated whois inaccuracy complaint where the complainant states that the registrant has provided false details. As this regards a potential violation of our registration agreement with the registrant we will investigate the identity of the registrant in this specific case only. The usual complaint is from the party listed in the registration record that they did not register the domain name in the first place or sold it a while ago and now found that the record was never updated by the old registrant.

That said, aside from the investigation following a substantiated inaccuracy complaint, identity of the registrant is not required under current policies. These cases are rather rare and are usually detected when the listed registrant contact receives their annual WDRP mail. In these cases we contact our customer and ask that they reach out to the registrant with the request to update the registration details.

Volker A. Greimann
General Counsel and Policy Manager

T: +49 6894 9396901
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On Fri, Oct 22, 2021 at 12:39 PM Michael Palage <michael at palage.com<mailto:michael at palage.com>> wrote:

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 numbers.

Thoughts? Comments?

Best regards,


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