As an employee of Intercosmos Media Group, Inc., ("Intercosmos"), I am personally made aware on a daily basis that my company is on the forefront of legal accountability with the Internet community for unjust practices. Being a part of a corporation that is growing as quickly as ours, I find it personally necessary and rewarding to be responsible for many decisions our company makes regarding such practices as it shapes our future.

As an employee and responsible Internet citizen I owe the community access to my working knowledge and educational training in respect to the criminal accountability of child pornographers. I owe the Internet community my full attention to such socially devastating matters, most importantly child exploitation and abuse. I have found there often exists an unsettling lack of urgency and ignorance when teaching others in my field how to respond to these matters. Intercosmos has continually upheld a civically responsible stand point on all of these reports. The best action to take as an individual, when uncovering child pornography, is to forward a formal report to the Federal Bureau of Investigations, police organizations and anti-child pornography advocates. These individuals have the experience and authority to determine who created the child pornography, who is hosting the site containing child pornography, and who is profiting from these child exploitations. We have helped, and continue to assist the F.B.I. in the collection of data in effort to bring criminals to justice.

Intercosmos is an ICANN accredited domain name registrar ("registrar"). Please see http://www.icann.org/registrars/accredited-list.html for more information. As a domain name registrar our over 350,000 customers have registered over 1,500,000 domain names using our service which is offered at http://directNIC.com. Our customers are the actual registrants of the domain names. The domain name registrants develop and market domain names that they register through our web site.

The 50+ employees in our company allow us to provide several other services to our customers in addition to domain name registrations. Over 300,000 domain names that are registered with us are also hosted on our servers. See http://www.directnic.com/features/hosting.php for information about our hosting products. Intercosmos also provides email services for hundreds of thousands of domains. See http://www.directnic.com/features/email.php for information about our email services. These services all require you be a registered customer of directNIC's in order to use these features.

Intercosmos does not market any domain names on behalf of its customers.

Unfortunately, with such a vast network of clients and over one million domain names sold there is an obvious risk for many of these domains to be used or involved in criminal activities. We often receive reports from organizations like the FBI, Missing and Exploited Children, the Anti-Child Porn Organization (ACPO), as well as concerned Internet citizens globally. Every time we receive tips about suspicious criminal and/or fraudulent domain names we must at that time decide how to handle each incident. Our staff initially follows a series of questions about the domain before finding an action to respond with. When we do discover there is adequate proof of illegal activity being reported we refer to our company standards and guidelines to make an informed decision of what type of action to take.

Any person that attempts to host this type of illegal content on our servers is immediately suspended or terminated for Terms of Service violations when we are made aware of such actions providing we can fully validate such activities. See: http://www.directnic.com/legal/ for information on our Terms of Service. Our Terms of Service clearly states we do not tolerate any illegal activities on our servers or with our services. Conversely, we also have a responsibility to investigate all claims so that innocent individuals are not affected by these complaints.

As a spokesperson and manager for Intercosmos Media Group, I will personally guarantee our company has not created nor consciously supported any form of child pornography. As a company; we have always taken immediate action against such practices and we look to the future to continue our efforts with diligence.

Occasionally concerned individuals do not adequately research before making accusations. In such cases Intercosmos has been falsely accused of assisting in the distribution of child pornography. In reality, the domains in this particular case used our paid directDNS service to hide their real hosting servers and use our directNIC servers to forward the domain name record to the actual servers storing the information collected or distributed from these sites in question. This is deceitful to both our company and the Internet community as a whole.

In this particular case, we were contacted by the Safe Housing Alliance representative, "Lisa". "Lisa" informed our staff that she had been notified by the Anti Child Porn Organization (ACPO) that they had discovered her contact information in association with credit card payment sites that were taking payments for child pornography distribution. "Lisa" realized at that time she did not give her permission to use her contact information nor were these domains her property. Once in contact with us, we assisted "Lisa" in filing what is called an Invalid WHOIS report on the domain name and also finding all additional domains she was falsely listed on.

Intercosmos also took immediate action to de-activate all hosting with these domains after receiving full report of the activities on these directNIC hosted sites. There were clear cut violations of our Terms of Service from these reports.

The Invalid WHOIS report system is a tool managed by The Internet Corporation for Assigned Names and Numbers (ICANN). See: http://reports.internic.net/cgi/rpt_whois/rpt.cgi

ICANN requires that all Names, email addresses, street addresses and phone numbers listed for a domain name are valid and true for the domain owner to be contacted if ever needing to be held accountable for their actions regarding their domain practices.

At the time, the domains in question were listing the Safe Housing Alliance's contact information; however, the domains were in no way associated with this company. It was quite obvious at that time we were dealing with a client that used another person's legitimate information in order to keep their own information private regarding these domains. This situation with third party falsified contacts was one we had encountered before.

"Lisa" stated she had been notified by the ACPO about illegal activities on these domains; however, Intercosmos had no proof of said illegal activities. In order to help "Lisa" with this particular incident, we took the route of reporting the contact violations as there were the only complaint or violation we had proof of.

ICANN allows for a report interface that lets any Internet user report domains that are not posting valid information and not being accountable for their online services or businesses. This interface helps to keep everyone informed as to what the exact complaint is about a domain name. In this case, all information was completely fraudulent for that domain owner.

When this type of report is filed it is a matter of waiting out the allotted time for the client to update. Generally, a report sent through this interface will take a few days to be processed on the ICANN level. Expect the registrar, such as Intercosmos to be notified about the domain complaint ten days after your report is filed. Each of these reports is manually processed by an individual at least one or more times before any domain is de-activated. Human mediation is necessary with these reports so that malicious Internet users do not falsely accuse innocent domain owners.

Once the Registrar has the invalid WHOIS report from ICANN, they can begin addressing the matter by first contacting the client to verify they are aware of the invalid WHOIS complaint against their domain. All clients are offered a fifteen day window to update this information. Due to new regulations by ICANN reported domains must send documented proof of their updated information once they change their contacts so there is proof they are not still attempting to post invalid information.

This particular domain owner was not pleased with our request for them to validate their changes with documented proof and then reported our company to ICANN in hopes of getting our organization in trouble.

At that time we explained the situation to ICANN and all the multiple names this domain owner had given us as to "whom" they really were. The client never did validate their information with us, nor did they retain ownership of these domains after "Lisa's" complaint to us.

This particular domain owner learned a difficult lesson from this situation. The client lost not only the ability to use these domain names during the time they have them currently registered for, along with all possible options to use our hosting services, the client also learned a valuable lesson on what happens when he hides behind falsified information.

Intercosmos has a reputation of providing quality service to our customers and even those that are not our customers. "Lisa's" first contact to use us was due to a claim received by Natasha at the ACPO about her domains taking payments for child pornography. As Intercosmos had no way of proving the Credit Card payment processing claim we follow up with "Lisa" regarding the Invalid WHOIS issue that was completely validated. "Lisa's" claim about a third party using her information falsely was valid and the client was acting illegally in doing so. Whether "Lisa" was our customer or not, we could not sit by and let an innocent party be blamed for an illegal activity they had no knowledge of or participation in. Anytime we receive a report on these types of activities, be it false information or potential child exploitation; we do take these matters seriously and follow through with an investigation and resolution in our timeliest of manners.

Since our introduction to the ACPO and Natasha's work, we have decided to assist in anyway we can with her organization and other institutions that fight for this worthy cause.

Our company has been discussing over the last year to begin production on a registry wide motivation to bring other registrar's together on these same issues. We hope to some day find that all domain registrars feel this type of content should be banned from our lives and our Internet travels.

Abuse Department
Intercosmos Media Group, Inc.

 

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