In light of continuing criminal activity on the Internet, Garth Bruen of Knujon makes a plea for public disclosure of Internet Registrar ownership and location This letter is from Garth Bruen of Knujon. It was written to me, but consider it written to you as well.We have before us rare opportunity to close a big Internet policy loophole. You may not be aware but Registrars (companies authorized to issue domain names) are not required to publicly disclose their ownership or location. It is my firm belief that this policy failure has helped criminals to get a foothold within the Internet infrastructure. To be specific, the standard contract given to Registrars, the Registrar Accreditation Agreement (RAA), has no provision mandating that location or ownership be disclosed to the public. In any other industry this would be intolerable. Internet users need to be aware of this and how it affects them.KnujOn has at its own expense sent Dr. Robert Bruen to the ICANN Cairo meeting to push this issue and generally for more consumer advocacy. Please consider the following information: Registrars Estdomains’ and Namejuice have had convicted felons as CEOs. Registrar Dynamic Dolphin’s CEO has been sued successfully for spamming. The officers at the companies were completely unknown until researchers and journalists pushed the information out.Also consider this: Dozens of Registrars located internationally are using “mail-drop” addresses and post office boxes in the United States and Canada as primary addresses. 70 Registrars were recently found to have no disclosed location whatsoever. Some Registrars still can’t be located but continue to operate. The Registrars in question were all sponsoring massive illicit pharmacy networks, including sites distributing Schedule 3 substances. I am recommending the addition of the following language or equivalent to the RAA:“All Accredited Registrars must submit main office location, including country, to be publicly disclosed in an ICANN web directory. Post Office boxes, Incorporation addresses, and mail-forwarding locations will not be acceptable. Registrars must also provide for public display the name of the CEO or President. ICANN must be notified within 30 days of a location or presiding officer change.”I have already sent my request for this change to ICANN staff and I am encouraging our members and the public to do the same using one of the methods listed here: https://www.knujon.com/news.html#11022008It is clear that certain players within the community have set out to deceive consumers. These conditions do not promote stability or foster faith within the industry. Additionally, it seems somewhat hypocritical to require that registrants disclose accurate contact details in Whois but Registrars have escaped this requirement. Without public disclosure there cannot be true transparency, accountability or trust. I appreciate your support.Sincerely, Garth Software Development