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

Roger D Carney rcarney at godaddy.com
Fri Feb 25 16:55:20 UTC 2022

Good Morning,

As I don't think recall these questions being discussed by the Scoping Team, I assume Alan, that you are sending these to ICANN Compliance in your own capacity and not from the Accuracy Scoping Team?


From: GNSO-Accuracy-ST <gnso-accuracy-st-bounces at icann.org> on behalf of Alan Greenberg <alan.greenberg at mcgill.ca>
Sent: Thursday, February 24, 2022 11:08 PM
To: Accuracy Scoping Team <gnso-accuracy-st at icann.org>
Subject: [GNSO-Accuracy-ST] Additional questions for ICANN Org

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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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