Letter from Nancy J. Victory to M. Stuart Lynn
25 July 2002
Mr. M. Stuart Lynn
Dear Mr. Lynn:
As you are aware, the .com, .net and .org Registry Agreements provide for annual independent audits of compliance by VeriSign, Inc. with the agreements' equivalent access provisions. Those provisions require that VeriSign's registry business offer equivalent access to its services to all registrars. The Department of Commerce required the audits to ensure the integrity of the firewalls between VeriSign's registry and affiliated registrar businesses, and thus help to preserve an open and competitive marketplace for registrations in the .com, .net, and .org domains.
The Department of Commerce has received and reviewed the Annual Independent Neutrality Audit Report for the year ended December 31, 2001. While the auditor generally concluded that VeriSign met its equivalent access obligations, we are concerned that the auditors had insufficient information to determine compliance with certain of those requirements because VeriSign did not maintain relevant historical data. In its June 24, 2002 response to the audit report, VeriSign indicated that it will await recommendations from the auditors regarding the best methods to keep records of this information.
The Department of Commerce believes that prompt action by VeriSign is necessary to meet the Department's objectives and VeriSign's obligations. Therefore, as the Internet Corporation for Assigned Names and Numbers continues to assess VeriSign's compliance, it should require VeriSign to meets its obligations by establishing the controls and mechanisms to capture and to maintain this data as soon as possible. Such action appears necessary to enable the auditors to complete an accurate and timely audit at the conclusion of this year.
Thank you for your attention to this matter.
Nancy J. Victory
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