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Message from Jan Legenhausen to Stacy Burnette

From: Jan Legenhausen
Sent: Thursday, October 02, 2008 12:30 AM
To: Stacy Burnette
Cc: Kurt Pritz; Tim Cole; Khalil Rasheed
Subject: Re: ICANN Notice of Breach - Action Required

Hello Stacy,

> Attached please find a notice of breach and supporting documentation

> regarding your registrar's failure to comply with Section 3.7.8 of the

> Registrar Accreditation Agreement (RAA). This notice requires

> JOKER.COM to take action

We are ready to take whatever action is necessary to sort this out - though we _really_ do not understand what the effective problem is. For us, it looks more like an uncertainty about the last words of 3.67.8 ("...steps to correct that inaccuracy").

Please let me add some facts about the supporting documents/domains ("breaches"?) you sent with this notice - our impression is, that 100% of the mentioned incidents have been handled correctly by

Since you still seem to consider them as "evidence of breach", i suspect that you do not agree with our method of "disabling a domain"?

This is something we explicitly asked Khalil Rasheed some time ago, when you started this discussion: Is putting a domain on "hold" (=moving out of the zone) appropriate or not, in case a whois entry is verified as wrong? We never got an indication from ICANN about this...

If my assumption is correct, this would mean that in case we change our method of "disabling a domain because of false whois data" could probably solve this issue...

Otherwise we really depend on advise what else could be done.

- reported through wdprs on 2008/06/16

- disabled by on 2008/06/20 (put on hold, status


- reported through wdprs on 2008/06/10

- disabled by on 2008/06/16 (hold,disabled-due-spam)

- reported through wdprs on 2008/05/31

- disabled by on 2008/06/02 (hold,invalid-address)

- reported through wdprs on 2008/06/18

- disabled by on 2008/06/23 (hold,disabled-due-spam)

- reported through wdprs on 2008/05/31

- disabled by on 2008/06/02 (hold,invalid-address)

- reported through wdprs on 2008/06/26

- disabled by (exact date available, but currently not for me because of RGP)

- reported through wdprs on 2008/06/15

- disabled by on 2008/06/20 (hold,disabled-due-spam)


regards, Jan Legenhausen

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."