[Policy-forum] THE TRUTH ABOUT THE .US REGISTRANT REQUIREMENTS

[GREGG MOSCOE]

For those of us who have been following policy changes regarding the .US
domains, "America's home on the Internet", I like to share the following
opinions and facts.

The registration requirements behind the .US domains are meaningless window
dressing; because the registrar (Neustar), its .US Policy Councel, and its
resellers make no effort to police them unless badgered, and take no actions
of any consequence to correct problems when they're clearly pointed out.

Recently, Mr. Jeffrey J. Neuman, Esq., who is Director, Law & Policy at 
NeuStar, Inc. notified me that the registrants of a domain I had complained
about would be investigated, and if the results were unsatisfactory, the
domain would be returned to the public pool for registration.

After two subsequent inquiries, I received Mr. Neuman's response which I have
shared here previously, that ALL 1900 .US DOMAINS of the registrant had been
investigated and "inaccurate information" had been corrected -- which I
presume meant the still-existing phone, fax and e-mail contacts of the
original registrant of record, Jason Namour of Melborne, Australia, had been
expunged and amended to indicate Brad Norrish, whose supplied address is in
New York, as the registrant.  Mr. Namour's information had previously
populated EVERY FIELD OF THE ORIGINAL 'WHO-IS' RECORD except for billing
contact, which was Mr. Norrish.  Mr. Neuman indicated that the registrant was
in compliance, and no further action would be taken.

No explanation of the investigation was provided.  No evidence of any
fulfillment of Mr. Neuman's promise was given.

The icing on the cake is as follows:

*  The domains STILL are housed on nameservers with a .com.au (Australia)
extension.  Commerce Dept. regs state that the domain must be housed on a
U.S.-based server.

*  The domain I was pursuing, www.brt.us, points to www.iregistrations.com,
which, according to 'who-is' is based in Australia, as noted below:

Domain name: IREGISTRATIONS.COM

Name servers: 
    ns1.iregistrations.com
    ns2.iregistrations.com

Registrant Contact-
   iRegistrations.com
   Peter Jacobs   (info at iregistrations.com)
   +61.892252136
   FAX- +61.892257276
   Level 2
   297 Hay St
   East Perth, WA 6004
   AU


Administrative Contact-
   iRegistrations.com
   Peter Jacobs   (info at iregistrations.com)
   +61.892252136
   FAX- +61.892257276
   Level 2
   297 Hay St
   East Perth, WA 6004
   AU

*  Mr. Norrish's company Internet Registrations Worldwide, (IRWW) is based in
Australia, as indicated below.

Domain name: IRWW.COM

Name servers: 
    ns1.irww.com
    ns2.irww.com

Registrant Info:
   Internet Registrations Worldwide
   Peter Jacobs   (info at irww.com)
   +61.892252136
   FAX: +61.892257276
   Level 2
   297 Hay St
   East Perth, WA 6004
   AU

Administrative Info:
   Internet Registrations Worldwide
   Peter Jacobs   (info at irww.com)
   +61.892252136
   FAX: +61.892257276
   Level 2
   297 Hay St
   East Perth, WA 6004
   AU

Furthermore, the Registrant and Administrative contact info is identical. 
Only the nameserver information differs.

I don't know how much more transparent this can be: to reasonable observation,
Enom and Neustar seem to be participating in documenting a front, allowing
apparently unqualified foregin registrants with no immediately discernable
business presence in the U.S. other than domain reselling and hosting, to
register and resell .US domains.  There appears to have been a paper switch,
substituting the name and some contact information of a U.S. contact for the
real registrants, the Australian entities who were originally identified in
the registration documents and who are behind both iregistrations.com and
irww.com as of today.

It is my belief that these people do NOT meet Nexus 3, or any of the other
Nexus requirements, and they are apparently violating U.S. Commerce Dept.
policy in housing .US domains on foreign-based servers.

They should not be allowed to register and resell .US domains, nor should
other similar registrants, and this burden for policing should fall on Neustar
and the resellers like Enom, not on qualified applicants who wish to obtain
these domains at reasonable prices, rather than 100 times or more than what
they were improperly purchased for.

These domains should go back into the public pool, for legitimate, active use
by qualified applicants.

I have pointed this information out privately to Mr. Neuman.  He has chosen
not to respond, so I am making it known in this more public forum.

Because if the registrar, Neustar, cannot police basic eligibility, how can
they be relied on to police a kid-safe space like "kids.us", even with charges
of $65 or more PER DOMAIN and a proposed $250 annual content review?

I hope that the people in the Commerce Department, the House and the Senate
will choose to respond.  

Gregg Moscoe
Sherman Oaks, CA