[GNSO-Accuracy-ST] Additional questions for ICANN Org

Alan Greenberg alan.greenberg at mcgill.ca
Fri Feb 25 05:08:46 UTC 2022

I am submitting the following five questions to ICANN Compliance.

Alan Greenberg, Member representing the ALAC
The 2013 RAA Whois Accuracy Program Specification section 4 requires a 
Registrar take certain actions if it has any information that specific RDDS 
fields are wrong (fields references are any of the name, postal address, 
e-mail address, voice telephone number, and (where available) fax number).

The example given in section 4 of having such information is: “Registrar 
receiving a bounced email notification or non-delivery notification message 
in connection with compliance with ICANN's Whois Data Reminder Policy or 

Question 1: In the view of ICANN Compliance, does this example apply only 
to Registrars who happen to monitor such email bounce or non-delivery 
notifications, or are Registrars obliged to do such monitoring?

Question 2: If a Registrar is obliged to monitor such email notification 
of non-delivery, are they similarly required to monitor other delivery 
methods (such as postal mail failure to deliver, or a message to through 
the Registrar’s domain management portal never being viewed)?

Question 3: If a Registrar is obliged to do such monitoring, does ICANN 
Compliance audit this requirement?

Section 4 goes on to require that “Registrar must verify or re-verify, as 
applicable, the email address(es) as described in Section 1.f…”

Question 4: With respect to the reference to “email address(es)”, since 
the information about inaccuracy may be about any of the name, postal 
address, e-mail address, voice telephone number, and (where available) fax 
number, is the Registrar only required to verify or re-verify the email 
addresses (even if the inaccuracy was in respect to one of the other 
fields)? If other fields are included, please be specific as to what fields 
must be verified or re-verified.

Question 5: The ICANN Org comments on the RrSG definition of accuracy 
saying that accuracy requirements are not limited to syntactical and 
operational accuracy implies that it may also include the requirement that 
the field contents are in fact associated with the RNH, and lacking such 
association, they may be deemed inaccurate. Is this an accurate reading of 
the ICANN Org comment, and if not, please explain just what the 
characteristics are that might make such fields inaccurate (in cases which 
are not as blatant as Mickey Mouse residing on Main Street of Disneyland)?
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