Documentary Information Disclosure Policy

ICANN's Documentary Information Disclosure Policy (DIDP) is intended to ensure that ICANN makes available to the public information contained in documents concerning ICANN's operations and within ICANN's possession, custody, or control unless there is a compelling reason for confidentiality.

Overview

The DIDP is a fundamental component of ICANN's efforts at fulfilling its commitment to transparency. Anyone can request documents by emailing ICANN at didp [@] icann.org. ICANN responds to each request within 30 calendar days, even if only to inform the requester as to when a response will be provided if the organization cannot respond within the first month and explain why the extension is necessary. If ICANN denies the information request, it provides a written statement identifying the reasons for the denial. If requestors want to appeal their decision, they can file a Reconsideration request. ICANN posts all requests and responses on its website.

DIDP Process

The DIDP process is a series of steps taken after each request is submitted:

1. Upon receipt of a DIDP Request, an ICANN staffer reviews the request and identifies the information requested, who may be in possession of or have knowledge of the information.
2. The ICANN staffer then interviews the relevant staff members and performs a document search.
3. The ICANN staffer collects the documents and reviews whether they answer the questions asked in the request and/or are subject to the Defined Conditions for Nondisclosure.
4. If the document falls under any of the Defined Conditions for Nondisclosure, a review is conducted as to whether the public interest in disclosing the documentary information outweighs the harm that may be caused by such disclosure.
5. Documents that are responsive and appropriate for public disclosure are posted on ICANN’s website. If ICANN deems a document's disclosure to be premature, ICANN will indicate it in its response to the request and notify the requestor when the document is posted.
6. The ICANN staffer prepares an email response to the DIDP Request and posts the request and response and Request to the DIDP page.

These steps are strictly interpreted, and the process contains a number of intrinsic rationales for the rejection of portions or all of a DIDP request. These threshold considerations can result in partial or full rejection of a given DIDP request. The request must ask for documents that are: in ICANN's control or custody; not publicly available at the time of the request; responsive to the request; and not subject to Defined Conditions of Disclosure.

• Documents are defined as existing, written records. Documents that do not exist cannot be produced If there is information that would be responsive to the request if they existed in documentary form, or that could be compiled from other existing documents to respond to the request, ICANN is not responsible for creating or compiling those documents.
• In ICANN's control or custody generally means that ICANN, in the course of its operations, either received and retained documents from other parties, or generated them in fulfillment of a specific mandate or objective. ICANN will reject requests for documentary information that it does not control. Even in situations where ICANN is participating in a collaborative process, if the records of the process are stored outside of ICANN, a DIDP request will be met with a negative response.
• Not publicly available is a requirement that would seem straightforward. However, the quantity and breadth of information available is a challenge. As ICANN's 2021 Transparency Report notes: "Over ICANN’s history, the Board, community, and org have produced and accumulated thousands of pieces of unstructured content spread across 38 different public sites. This content continues to grow by up to 30% each year. The org currently surfaces this content through multiple unconnected platforms with differing foundational technologies that are non-scalable, may be vulnerable, and are no longer fit for purpose." The transparency and ease of access of "publicly available" information has been a topic of several specific and organizational reviews, as well as the Cross Community Working Group on Accountability. As a result, most responses to DIDP requests take pains to identify and provide links to publicly available information that may have escaped the notice of the requester.
• The identification of responsive documents is the least problematic of the criteria defined by the process. The question of whether existing, nonpublic documents are responsive to the DIDP request appears to be straightforward for staff. However, many responsive documents may be withheld for other reasons.
• Defined Conditions of Nondisclosure are discussed in the next section.

ICANN's DIDP policy reinforces these "threshold" reasons for declining requests. The policy specifies that "ICANN shall not be required to create or compile summaries of any documented information, and shall not be required to respond to requests seeking information that is already publicly available." In many responses to DIDP requests, ICANN often cites this section in responding to elements of the request.

Defined Conditions for Nondisclosure

ICANN does not disclose documentary information that is:

1. from a government or international organization if it would prejudice ICANN's relationship with that party.
2. internal and would compromise ICANN's deliberative decision-making process by inhibiting communication with ICANN Board directors, advisors, staff, consultants, contractors, or agents.
3. prepared for exchange between ICANN, its constituents, and/or other entities with which ICANN cooperates that would compromise the decision-making process between them
4. personnel, medical, contractual, remuneration, or similar records or internal appeals mechanisms and investigations that would constitute an invasion of personal privacy
5. provided to ICANN that would materially prejudice the party's commercial, financial, and/or competitive interests or is pursuant to a nondisclosure agreement
6. confidential business information and/or internal policies and procedures
7. likely to endanger the life, health, or safety of any individual or materially prejudice the administration of justice
8. subject to attorney-client privilege, or any other applicable privilege
9. a draft of correspondence, reports, documents, agreements, contracts, emails, or any other form of communication
10. related to the security and stability of the Internet, including the operation of the L Root or any changes, modifications, or additions to the root zone.
11. a trade secret or commercial/financial information not publicly disclosed by ICANN
12. in response to an unreasonable, overly burdensome, unfeasible, or abusive/vexatious request

These twelve situations are referred to in DIDP policy documents and responses as Defined Conditions for Nondisclosure. If one or more of the Defined Conditions apply to a document, staff is instructed to conduct a balancing test:

To the extent that any responsive documents fall within any Defined Conditions for Nondisclosure, a review is conducted as to whether, under the particular circumstances, the public interest in disclosing the documentary information outweighs the harm that may be caused by such disclosure.

Although in theory, the balancing test applies to all Defined Conditions for Nondisclosure, it is most frequently cited in the assessment of conditions 2 and 3, where the conditions specifically address a risk of compromising ICANN board and org's ability to deliberate and make decisions.

History

Birth and Growth of the DIDP

From 2007 to 2008, ICANN developed the original DIDP following its community consultation on the Accountability and Transparency Frameworks and Principles. The first use of the DIDP was in September 2008, by Danny Younger, who requested information about a couple of registrar accreditation applications submitted to ICANN. In 2012, ICANN updated the policy following another community consultation, and it has remained the same since.

Outcomes Thus Far

Since the initiation of the DIDP process, 166 DIDP requests have been filed (as of December 2021). Of those, 78 requests were declined, 45 were responded to with links to publicly available information, and 41 resulted in the disclosure of some amount of new information (documentary or otherwise). These statistics are based on the review of all requests by ICANNWiki editors.

• Declined: the response included rationales for rejection of all or part of a request for additional documents
  The characterization of a request as "Declined" occurs in situations where, whether or not links to publicly available information are provided, the response includes rationales for the rejection of all or part of a request for additional documents.
• Pointed to Public Information: the response denies the request for additional documentary information; however, it sufficiently answers the questions posed by the requester by pointing to publically available documents
  The characterization of "Provided Public Information" involves situations where the vast majority of the information sought is already available in public documents. ICANN may cite a threshold rationale (i.e., no obligation to compile or create responsive documents), but there is essentially no more information beyond the publicly available resources; thus, there is nothing further to produce.
• Information Disclosed: the response either discloses actual documents or provides new information to the requester
  In most cases, only some of the documents responsive to the request were disclosed. This category also contains situations where no documents were available (or requested) but information or context could be provided nonetheless.

Top Requesters & Topics Thus Far

The Indian Centre for Internet & Society is by far the top user of the DIDP process, accounting for over a quarter of the submitted requests (as of December 2021). The most frequent requestors have tended to be lawyers, journalists, representatives from Internet governance organizations, and staunch supporters of ICANN's commitment to the Multistakeholder Model.

Often the requests have sought details about or more transparency/accountability in terms of ICANN organization or board operations. Other times, the requests reflect eras of ICANN's history, such as when ICANN was running the New gTLD Program.

Requester	Number of Requests	Topic(s)
Centre for Internet & Society	43	Various Internet governance and ICANN policy issues; ICANN financial and operational details
Michael Palage	10	ICANN board deliberations and resolutions; ICANN policy-making topics
Arif Ali	9	Requests on behalf of clients regarding the New gTLD Program
Kieren McCarthy	6	Board deliberations on various issues; staff responses to DIDP requests
George Kirikos	5	Largely addressing failures to keep specific website resources up to date
Kevin Murphy	4	Information related to ICANN Board decisions and ICANN-involved disputes

2021 Proposed Changes

In 2021, ICANN Org proposed the following changes.

1. Delete: "NOTE: With the exception of personal email addresses, phone numbers and mailing addresses, DIDP Requests are otherwise posted in full on ICANN (Internet Corporation for Assigned Names and Numbers)’s website, unless there are exceptional circumstances requiring further redaction."
2. Replace "appeal a denial of disclosure" with "seek review of ICANN’s DIDP Response"
3. Add information on how to submit a request: "Any member of the public may submit a DIDP request to ICANN org. To submit a DIDP request, please send an email to didp@icann.org describing the documentary information you are seeking. Please provide as much detail as possible to identify the party submitting the request and the documents requested. If you have a question or need assistance with submitting a DIDP request, please contact the DIDP team at didp@icann.org."
4. Include option for additional 30 days to original 30-day response window: "ICANN org will provide a written response to all DIDP requests, as soon as practicable within 30 calendar days of receipt of the request, unless it is not feasible to do so. If that time frame cannot be met, ICANN org will inform the requestor in writing as to when a response will be provided, which shall not be longer than an additional 30 calendar days and explain the reasons necessary for the extension of time to respond."
5. Replace "Trade secrets and commercial and financial information not publicly disclosed by ICANN (Internet Corporation for Assigned Names and Numbers)." with "Materials, including but not limited to, trade secrets, commercial and financial information, confidential business information, and internal policies and procedures, the disclosure of which could materially harm ICANN’s financial or business interests or the commercial interests of its stakeholders who have those interests. Where the disclosure of documentary information depends upon prior approval from a third party, ICANN org will contact the third party to determine whether they would consent to the disclosure in accordance with the DIDP Response Process."
6. Add: "ICANN may choose to, however, create new documentary information to make public in response to a request under this DIDP as ICANN deems feasible and necessary if there is little to no information available on the ICANN website."
7. Add periodic review: "ICANN will review the DIDP Policy and the DIDP Response Process every five years."

From October to December 2021, ICANN requested feedback on several proposed changes to the DIDP based on the Cross Community Working Group on Enhancing ICANN Accountability Work Stream 2 recommendations.

Reactions to the Proposed Changes

On January 28, 2022, ICANN org released a summary report of the eight comments it received, five of which were from community groups and three from individuals, and all of which emphasized the role of the DIDP mechanism in raising ICANN's level of transparency and accountability. Only one commenter, Samwel Kariuki, supported the proposed changes. One commenter, George Kirikos on behalf of Leap of Faith, objected to the DIDP in its entirety, arguing that ICANN org should release all of its documentation.
Issues with Conditions of Nondisclosure
Arif Ali, Jan Janssen, John Murino, Michael Palage, Flip Petillion, and Mike Rodenbaugh together argued that the proposed DIDP revisions do not provide for disclosure of documents in redacted or severed form, do not require the provision of a rationale for withholding responsive information as recommended in WS2, decrease transparency, and, thus, are contrary to the WS2 recommendations and ICANN Bylaws. The BC recommended that DIDP responses either make the requested documents available or provide clear, specific reasons for nondisclosure. The ALAC, RySG, and TurnCommerce the trade secrets, commercial/financial information, and internal policies and procedures condition for nondisclosure is too broad.
Issues with the Process
Ephraim Percy Kenyanito, on behalf of Article 19, recommended that ICANN org commit to publishing a DIDP request as soon as it is received. ICANN org will consider this suggestion but noted that it would not need to reflect it within the DIDP in order for it to become part of ICANN org’s practice, and it would not change the DIDP on this issue.
Issues with Review/Challenge Mechanisms
The ALAC, A19, BC, Leap of Faith, and RySG supported expanding the role of the Ombudsman to include providing the mechanism for requestors seeking review of DIDP responses. The ALAC recommended that the DIDP and responses refer requestors to review mechanisms for challenging DIDP responses. The BC suggested a 30-day window within which a requester can seek a review of a denial of disclosure. The BC suggested that requestors submit a request for review and the reason for denial of disclosure, which the Ombudsman should assess within 30 days of receipt. The BC said the Ombuds’ review should be published as advisory to the ICANN org, with 14 days to respond. The RySG stated that the Ombuds would likely have to recuse themselves from any Reconsideration request challenging a DIDP response they had reviewed and the Complaints Office may be better suited for this role.

Criticism

• As part of the Public Comment proceedings for ICANN's proposed revisions to its current DIDP,

• The Registries Stakeholder Group noted that the conditions for nondisclosure would be broader; advised that any additional DIDP roles for the Ombudsman should not remove or replace the Reconsideration Request process; requested clarification on community members', and the Ombuds' resultant, procedures for appealing to DIDP responses; and recommended that the Complaint’s Officer should be the home for additional review of DIDP Responses.
• ALAC expressed concern that the changes would grant "ICANN the right to refuse any and all requests." It warned that ICANN should not use DIDP to "cover up its errors or poor judgement." Finally, the committee submission recommended that ICANN:
  1. Allow Ombuds to oversee the mechanism for requestor review of ICANN DIDP responses;
  2. Document in DIDP Policy recourse when DIDP is not fully satisfied; and
  3. Revise the new language on conditions for nondisclosure.
• Kevin Murphy summarized various community members' and collectives' critiques as accusing ICANN of "shirk its transparency obligations" by granting greater ability to deny requests without any explanation.

• Dr. Sarah Clayton argues that the 12 defined conditions of non-disclosure (DCND) "essentially provide an administrative loophole for ICANN to restrict the free flow of information." Furthermore, her statistical p* models demonstrate that
  1. ICANN Organization considers lengthier submissions to be more likely to request contentious information and are more likely to apply DCND to them
  2. ICANN Stakeholder Groups/Working Groups are more likely to receive DCND in every condition category, except the "Affects Individual" condition
  3. "Burdensome conditions" are rarely imposed on law firms, which tend to request precise information about a specific case
  4. Registrants are less likely to receive ICANN "Integrity" conditions as they are more concerned about their own domain name registrations than about ICANN
  5. "Confidential External Business Information" conditions are less likely to be imposed on the internet non-profits, as they are more interested in ICANN’s interface with Internet Governance than third-party business interests.
• Indian stakeholders have cited difficulties in accessing documents under DIDP and asked for greater transparency.
  • Padmini Baruah, of The Centre for Internet and Society, explains that ICANN deflects most requests for information, using clauses about internal processes, stakeholder discussions, protecting financial interests of third parties (cited in over 50% of the responses up to 2016) to avoid disclosing its Contractual Compliance audits and reports of abuse to registrars. Baruah's complaint is that because ICANN regulates a global public good, it should be far more open. Baruah presented on this topic at an NCUC session during ICANN 55, and George Sadowsky was invited to comment on her findings. He noted that there were some discrepancies between Baruah's assessments of the history of the DIDP mechanism and ICANN staff's assessment of the same history. Baruah subsequently submitted a DIDP request in an attempt to reconcile her analysis with that of ICANN staff. ICANN responded in part:

In several instances, your characterizations of “no” or “partly” disclosed are either mistaken, do not acknowledge the information and documents identified as publicly posted, do not take into consideration the nature of the requests and the existence (or lack thereof) of responsive documents, and/or do not consider the balancing required between the public benefit and the potential harm of requested disclosures.

ICANNWiki editors' own work reviewing DIDP requests for the Summary Tables below did find that some of Baruah's assessments of staff responsiveness to requests were technically inaccurate for various reasons. However, it is notable that those inaccuracies more often erred on the side of "responsiveness," rather than refusal to submit information. This is in part because of ICANN's efforts to ensure that every DIDP response provides links to publicly available documents (which are, strictly speaking, not disclosures of documentary information). Baruah tended to note these responses as "partly" providing information under the policy.

Summary Tables of DIDP Requests & Responses

Submission Date	Requester	Subject	ICANN Response (PDF)	Nondisclosure Conditions Cited	Notes
24 September 2008	Danny Younger	Copies of RAAs for Brandon Gray Internet Services Inc., DBA Namejuice.com, EstDomains.Inc	Provided some information	5
21 November 2008	Brian Krebs	Officers listed on the RAA between ICANN and Dynamic Dolphin Inc.	No information available	No	Only officer listed on the application for accreditation was already public
6 February 2009	Christopher Cielinski, Commercial Contract Inc.	Copy of original financial support and cover letter provided to ICANN by Commercial Connect, LLC as a part of their application for the .shop/.mall/.svc TLD	Unable to provide a response	Yes - no specific condition cited. Implication is either 5 or 6	Commercial Connect, LLC was the applicant - Commercial Connect, Inc. does not have access to information that another legal entity requested be kept confidential
6 March 2009	Edward Hasbrouck	Copies of documents relating to the Independent Review Process	Partial responses to requests, largely pointing to publicly available information	References or allusions to 2, 6, 9, & 12	The response noted that no response was required when information was publicly available. "In a good faith effort to be as responsible as possible, ICANN, however, provides a point‐by‐point response below."
3 April 2009	Edward Hasbrouck	Documentation relating to the ICANN Ombudsman and his appointment	Declined - information was received and answered already		All information publicly available (specifically because Hasbrouck's questions were already answered at the ICANN 34) public forum
8 May 2009	Tim Ruiz (GoDaddy)	Full Request Here - Form 990 for Fiscal Year Ending 30 June 2008; details regarding the $240,000 expenditures for Lobbying Activities as reported on Schedule A Part VI‐B of Form 990 for Fiscal Years 2007 and 2008; identification of the contributors redacted on Schedule B of Form 990 for Fiscal Years 2007 and 2008; criteria or goals for bonuses awarded to CEO Paul Twomey during his tenure in 2004, 2005, 2006, as well as a bonus awarded in 2008; and documents relating to Vendors who provided technical or professional services to the Board and Staff for 2007, 2008, and 2009	Provided some information	2, 4, 5, 6, 11, & 12
17 September 2009	Victoria McEvedy	Contractual provisions, policies, and other protections of staff and secretariat impartiality when dealing with SOs (GNSO, specifically, but information requested for all three). Full request here	Provided partial information	4 & 6
25 September 2009	Alejandra Barrientos	Needed to learn about a specific provision of RFC 1591	Provided a link to the RFC	No
27 April 2010	Michael Palage	Basis for "funnel request" processing within the RSEP, and information related to the "project plan" for the New gTLD Program announced at ICANN 36 in Seoul.	Partially provided information	No	Project plan had not yet been posted and would be posted via usual methods
29 April 2010	Eric Brunner-Williams	“Correspondence, minutes, etc. between ICANN and CRAI, which set forth the scope of the CRAI economic research published on 10/24/08.”	Responded providing an email regarding the CRAI SOW, and pointed requester to the CRAI final report.	No
24 June 2010	Michael Palage	Documents relating to an agreement between ICANN and the New South Wales government regarding the funding of ICANN Sydney's office.	Declined because ICANN could not divulge details of a confidential agreement. ICANN subsequently requested whether NSW would allow disclosure; that request was denied.	1 & 5
20 August 2010	Barry Carter	A list of all registered domains and all public registrant information.	Pointed to publicly available records, declined to create or compile documents.	12	Given that the number of registered domain names in gTLDs in 2010 was over 120 million, this request was massively broad.
8 September 2010	Diane Duke	Documentation pertaining to ICM Registry's application for the .xxx TLD	Declined to produce documents.	5	The publicly available information regarding ICM's application was all that was available - ICM had requested that portions of their submissions be kept confidential.
27 September 2010	Evan Leibovitch and Avri Doria	Transcripts & presentation materials for the staff report to the Board retreat on the issue of the New gTLD Program Applicant Support, as well as a vote count on any decisions taken by the board regarding that topic.	No documents produced.	No	The Board Book from the retreat was scheduled to be released after approval of the minutes; preliminary report contained the relevant vote tally; staff presentations are not transcripted, so that could not be provided.
1 December 2010	Iliya Bazlyankov	The criteria and decision process used to assess, and ultimately "reject" Bulgaria's application for an IDN string	Declined	2, 3, 5, & 11	Response notes that IDN applications are not "rejected"
7 December 2010	Jorge Sabate	A list of all registered domains and registrant information - failing that, the "dste [sic] was created the domain name christiansmith.com"	Declined	12	Overly broad; WHOIS search would provide information about specific domains
4 November 2010	Denise Subramaniam	Requests for information regarding the de-accreditation of 4Domains, Inc., including whether 4Domains maintained commercial liability insurance, and what measures ICANN typically took to protect registrants.	Provided partial response, including the insurance certificate for 4Domains from the original RAA process.	4
10 March 2011	Michael Palage	Information related to ICANN's management of the L root server, including documents or explanations regarding why the L root's directory might not have been identical to the A root server in 2007. Full request here	Linked to public information, declined to produce documents on threshold and DCND grounds.	5, 8, 9, & 10	Response notes both that information is publicly available, and that ICANN is not responsible for "compiling" information in response to a DIDP request.
16 March 2011	Kieren McCarthy	Documents related to correspondence between ICANN and the GAC, including subsequent discussions regarding how to handle disagreements between ICANN and the GAC.	Request was deemed moot	No	By the time ICANN issued a response, almost all of the information had been published, and the remainder was scheduled to be released upon approval of the minutes in which they were contained.
11 April 2011	Diane Duke	Documentation relating to the International Foundation for Online Responsibility, and ICM Registry's contracts for labeling and monitoring (still regarding ICM's .xxx application)	Declined to produce documents on threshold grounds	No	ICANN did not possess that information
23 May 2011	Kevin Murphy	Transcripts, documents, and any other record of Larry Strickling's meeting with ICANN board members at ICANN 39 in Cartagena, as well as any similar materials from ICANN 40 in San Francisco if a similar meeting occurred there	Provided link to Cartagena meeting; could not produce documentation re: San Francisco	No	No meeting occurred in San Francisco
13 June 2011	Kieren McCarthy	Scorecard with respect to the status of implementation of the ATRT	Pointed to publicly available report from the ATRT team; no documents were produced	No
8 July 2011	John Bell, The .JOBS Charter Compliance Coalition	Information related to the change of the .jobs "Purpose" field in the IANA Root Zone Database.	Provided partial information, including a redacted copy of the TLD change request submitted to IANA	6, 8, & 10	Also referenced the DIDP provision that ICANN is not responsible for "compiling" information
10 August 2011	James Keener	Copy of the Registrar Accreditation Agreement between ICANN and Dynamic Dolphins Inc. as well as names on the application	Information provided - 2005 RAA and 2010 RAA	No
20 August 2011	Kieren McCarthy	List of Board Meetings, and their agendas and minutes, between 29 July 2011 and 16 August 2011	Pointed to Board Meetings page on ICANN.org; no new documents produced	No
2 September 2011	Paul McGrady	Recordings and transcripts from "all public meetings" from May 2009 to the present (September 2011), "in which a non-Staff member made a comment which was recorded or transcribed."	Declined to produce non-public documents; pointed to public records	"May include, but are not limited to," 1	Also noted that ICANN is not obligated to compile information in response to requests
16 September 2011	Michael Palage	Information and financial disclosures regarding ICANN's IDN Fast Track applications processing, including an assessment of the cost efficiency of the processing of the applications, and a request to square the relatively minimal fee amounts collected for all the relevant IDN fast track applications, with the $185,000 application proposed for the New gTLD Program. (Full request included in ICANN's response.)	Provided links to publicly available cost and budget reports	No	Declined to respond to questions that were not specific to "documents" - suggested that Palage speak directly with staff outside DIDP process
19 September - 20 October 2011	Kieren McCarthy	Three separate DIDP requests related to McCarthy's earlier request for information about board meetings that occurred in the summer of 2011; the staff's interpretation of DIDP's scope and breadth; and the process used in researching & creating the responses to the DIDP requests.	Provided context but declined to produce documents initially; second response declining to produce internal documents or correspondence; third response declining to produce documents specific to the deliberations and process of responding to prior DIDP requests.	2, 3, 6, 8, & 9	This "conversation" via DIDP is noteworthy for providing some insight into ICANN's interpretation of the DIDP and its implementation practices.
27 October 2011	Kieren McCarthy	Requesting a copy of ICANN's whistleblower policy	Provided context but not the policy	4, 6, & 9
27 October 2011	Kieren McCarthy	Requesting a copy of the ATRT1 implementation plan	Plan was detailed in an ATRT report; did not disclose additional documents	No
29 November 2011	R. Shawn Gunnarson	Staff response to McCarthy's DIDP request regarding ATRT1 contained a broken link	Provided correct URL	No
7 December 2011	R. Shawn Gunnarson	Information related to the implementation of the ATRT1 recommendation that ICANN hire an independent expert to review its transparency mechanisms	No such documents	No
17 January 2012	George Todoroff	Names of the six DNS stability panel members that reviewed and subsequently rejected the Bulgarian IDN ccTLD Fast Track Process application in 2010.	Declined	2, 3, 5, & 11
15 March 2012	George Kirikos	Copies of "all correspondence submitted to ICANN in the past 24 months (from this request) that the staff have censored from the correspondence page"	Declined	12	Apart from citing the "overly broad" exclusion, ICANN noted that it is not responsible for "compiling" information.
3 April 2012	John Bell, The .jobs Charter Compliance Coalition	Documents, party correspondence, and other information relating to the arbitration initiated by Employ Media LLC (the registry for .jobs) arising from the breach notice issued by ICANN on February 27, 2011. Full request	Provided context and the link to publicly available information about the arbitration; declined to produce other documents	1, 2, 4, 5, & 7
29 May 2012	Phil Corwin, Internet Commerce Association	Regarding the inclusion of a "URS Summit" line item in the proposed budget for the next fiscal year, a list of staff & board members who played "any non-clerical role whatsoever" in the implementation of Uniform Rapid Suspension, and all of their correspondence within and without the organization. [Full request]	Provided some history regarding the "URS Summit" line item, and the email chain that led to its removal from the draft budget	5, 8, & 9
8 August 2012	David Maher	All documents related to the creation & operation of the Trademark Clearinghouse, including the contract with the third party operator of the TMCH, and all information related to claims of intellectual property rights in specific strings. Full request	Provided context information & links to published information, but declined to produce new documents	5, 6, 8, 9, & 11
27 September 2012	George Kirikos	Updates to, and general improvement of, ICANN's litigation information and Independent Review Process pages. Full request	Thanked Kirikos for the suggestions, and noted that most of the specific pages he referenced had been updated.	No
29 January 2013	Igor Petrenko	A list of all registered domains	Declined	12	Noted that much of that information is publicly available
5 February 2013	Garth Bruen	Nine separate requests for documents regarding Bruen's Contractual Compliance WHOIS Data Problem Reporting Service tickets submitted in 2011, including correspondence between the registrars reported and ICANN, as well as ICANN internally	Declined on DCND grounds	2, 3, 5, 6, & 9
5 February 2013	Mary Blasy	Documents relating to Verisign's renewal of the .com domain name registry agreement, including communications with the US government's Department of Commerce and Justice, correspondence regarding renewal details, and other information	Pointed to publicly available information; declined to produce more	1, 2, 3, 5, 8, & 9
5 February 2013	Compwiz LLC	Requested printed copies of all correspondence between Network Solutions & ICANN regarding compwiz.com	Declined	2, 3, 5, 6, 8, & 9
26 March 2013	Oksana Prykhodko	Information re: delegation of the IDN ccTLD .ykp to Ukraine Full request	Pointed to public information, otherwise declined	1, 2, 3, 5, 6, 8, 9, & 10
28 March 2013	Flip Petillion	Documents regarding the decision to place .hotels and .hoteis in a string contention set; and a follow-up request for more specifics that were not previously answered in the first response.	Pointed to public information & provided some context; provided additional context in response to the subsequent request. Declined to produce documents.	3, 5, 6, 8, 9, & 11
13 April 2013	Kevin Murphy	Recordings and transcripts of the meetings between ICANN and community members in Belgium and Los Angeles in November 2012 relating to the Trademark Clearinghouse, from which the "strawman" solution emerged and was accepted.	Brussels was not recorded, LA was, recordings & transcripts would be posted shortly. No non-public documentation provided.	No
22 April 2013	Thomas Indelicarto, Verisign	All correspondence received by ICANN regarding the organization's readiness to launch the New gTLD Program, all ICANN responses, and all communications between ICANN staff and any member of the SSAC from January 2013 to date of request	Pointed to the New gTLD Program's correspondence page, and declined to produce any other documents	2, 3, 5, 6, 8, 9, 10, & 12	Although the "SSAC communications" request only covered a four-month period, ICANN cited both the volume and variety of communications between ACs and staff and noted that Verisign did not specify what they were looking for with any particularity
7 May 2013	George Kirikos	ICANN's Board Finance Committee page was out of date; IRS form 990 for the fiscal year ending in June 2012 had not been published	Thanked Kirikos, noted that the BFC meeting minutes had been posted and that Form 990 would be posted once filed	No
26 June 2013	George Kirikos	Documents, recordings, and transcripts of meetings, presentations, and other work of the Expert Working Group on gTLD Directory Services	Pointed to public records, otherwise declined	2, 3, 5, & 9
24 July 2013	NCSG	Documents, recordings, transcripts, and communications related to the implementation of the Trademark Clearinghouse; the "TM+50" rule (allowing trademark owners to specify up to 50 previous infringing domain strings); the development of the "strawman" solution; the processing and evaluation of NCSG's Reconsideration Request 13-3 (dealing with the same topics); and correspondence between ICANN and specific parties in relation to those topics. Full request	Pointed to public record & otherwise declined	1, 2, 3, 6, 8, 9, 11, & 12
10 August 2013	Mathilde Frison	Exchanges between ICANN and Registrars who had invoked ICANN's procedure for dealing with WHOIS conflicts with privacy laws; copies of the 2013 Registrar Accreditation Agreements; and the contents of a letter mentioned at ICANN 46, from Europol to ICANN and the GAC expressing demands from law enforcement bodies regarding provisions in the 2013 RAA.	Responded that no documents related to the WHOIS policy existed, each RAA would be published once ICANN set a procedure for doing so, and declined to provide correspondence from Europol	2 & 9	The "letter" mentioned at the GAC meeting with law enforcement may never have been finalized by Europol - other communications were covered by the conditions for nondisclosure
13 January 2014	Kelsey Britton	Requesting the inclusion of information on new domain registrations within ICANN's Monthly Registry Reports	Information is not included in what is reported to ICANN. Directed Ms. Britton to the zone file database.	No
20 March 2014	ICOMP	Correspondence, deliberations, and other documents related to ICOMP's Community Objection to Google's application for .search. Full request	Declined - all information that was not already public was subject to a condition of nondisclosure	2, 5, 6, 9, & 11
15 May 2014	George Kirikos	ICANN’s unredacted Form 990 for the period ending 30 June 2013	Responded that the form was publicly posted once filed with the IRS	No
23 May 2014	Amazon EU S.a.r.l.	Extensive list of disclosure requests related to ICANN's acceptance of the third party neutral's decision to place Amazon's application for .amazon, as well as Chinese & Japanese character strings for the same name, be placed on hold.	Pointed to public record, declined to produce other documents on threshold & DCND grounds	2, 3, 8, & 12	The request also asked for GAC deliberations & records on the issue, which ICANN noted was not something they would normally be in possession of.
4 August 2014	Donuts, Inc.; FairWinds Partners, LLC; Fegistry LLC; Famous Four Media Limited; Minds + Machines; and Radix FZC	All communications related to the successful Community Priority Evaluation (“CPE”) of HOTEL Top-Level-Domain S.a.r.l.'s community application for .hotel; all communications related to the appointment of the CPE Panel that produced the Report. Full request	Pointed to public information, declined to produce non-public documents	2, 3, 5, 6, & 9	The request made efforts to preempt possible conditions of nondisclosure. However, from the ICANN response: "Although your analysis in the Request concluded that no Conditions for Nondisclosure should apply, ICANN must independently undertake the analysis of each Condition as it applies to the documentation at issue, and make the final determination as to whether any Nondisclosure Conditions apply. Here, for example, ICANN cannot violate contractual conditions that require ICANN to maintain items as confidential solely because the Request proffers that no such conditions apply. Similarly, ICANN does not release draft documentation – particularly if draft documentation was shared for the purpose of facilitating deliberations or decision making – because drafts are not reliable sources of information regarding what actually occurred or standards that were actually applied."
4 September 2014	Dot Registry LLC	A request for a copy of the contract between Community Priority Evaluation provider Economist Intelligent Unit (EIU) and ICANN.	Declined	2, 5, & 6	Another request that attempted to preempt the Defined Conditions of Disclosure
17 September 2014	fTLD Registry Servies LLC	A request for copies of any written agreements between ICANN and Donuts, Inc. regarding agreements to toll or extend deadlines for Donuts to file either a CPE or IRP request regarding the .insurance TLD	Declined	2 & 6	The response notes that, in addition to the defined conditions of nondisclosure, the ICANN Bylaws expressly state that materials submitted as part of an IRP or CPE shall remain confidential
26 September 2014	Afilias, BRS Media Inc., & Tin Dale, LLC	A request for documents relating to the Community Priority Evaluation Process generally, as well documents pertaining to the criteria, information reviewed, and other deliberative process related to the CPE for .radio	Declined	2, 3, 5, 6, & 9
30 September 2014	Michael Palage	A request for accounting and financial information regarding applications for internationalized ccTLD strings, as well as information regarding ICANN's reporting processes, details of non-payment, and ICANN's treatment of non-payment.	Provided template email and accompanying invoice that is sent to IDN ccTLD applicants; otherwise, declined to provide additional documents	5, 6, & 11	ICANN noted that the differences in reporting of IDN application revenue were "a matter of formatting and not the result of an affirmative documented decision."
21 October 2014	Kevin Murphy	Letter from Rod Beckstrom to Maria Del Rosario Guerra dated December 1, 2009, the response to which was listed on ICANN's correspondence page.	Declined	1, 3, 5, 6, & 10	"Any other information [beyond what was already publicly available] regarding the redelegation process of the .co ccTLD, including the 1 December Letter, is not appropriate for public disclosure"
22 October 2014	Reg Levy	A request for documents relating to the Community Priority Evaluation Process generally, as well documents pertaining to the criteria, information reviewed, and other deliberative processes related to the CPE for .eco	Declined	2, 3, 5, 6, & 9	Cites the prior DIDP regarding the .radio CPE in explaining its reasons for not disclosing information.
22 October 2014	dotgay LLC	A request for documents relating to the Community Priority Evaluation Process generally, as well documents pertaining to the criteria, information reviewed, and other deliberative processes related to the CPE for .gay	Declined	2, 3, 5, 6, & 9	Again, cites the DIDP request for the .radio CPE to partially explain its rationales
18 December 2014	Centre for Internet and Society	Detailed & categorized reports of expenses relating to travel and meetings for the years 1999-2014. Full request	Declined	12	Despite declining to produce additional documents, ICANN's response takes pains to identify public information that is responsive to the request
22 December 2014	Centre for Internet and Society	Details of ICANN's income from domain names between 1999-2014. Full request	Provided documentation from 2012 forward	12	ICANN adopted a new method of financial reporting based on this DIDP request; however, earlier financial data was stored in a different system, and conversion of that data into a new form of reporting would be overly burdensome
24 December 2014	Centre for Internet and Society	Details of cyberattacks suffered by ICANN since 1999	Declined	1, 2, 6, 8, 9, & 12
26 December 2014	Centre for Internet and Society	Details of the cases that have been decided by the ICANN Ombudsman, as well as information related to the lack of reporting on the Ombudsman's page, the absence of case reporting since 2010, and other operational details.	Declined	2, 8, 9, & 12	Staff provided links to public information, including the Ombudsman's annual report to the board.
27 December 2014	Centre for Internet and Society	Information pertaining to the implementation of the NETMundial Principles	Declined	1, 2, 6, 8, 9, & 12	ICANN staff provided some context on the NETMundial principles and links to public information regarding ICANN's participation in the Internet Governance ecosystem. However, the response went on to state that it was not responsible for implementing the NETMundial Principles and that the request was outside of ICANN's operational mandate.
12 January 2015	Centre for Internet and Society	Information pertaining to the formation and operation of ICANN's Globalization Advisory Groups	Provided answers regarding the dissolution of the groups; no documents were provided	No	The IANA Functions Stewardship Transition spurred new community initiatives that were largely duplicative of the Globalization Advisory Groups. As a result, the groups were dissolved a month after they were created.
12 January 2015	Centre for Internet and Society	Information relating to ICANN's auctions, including proceeds from auctions, complete bid histories (including losing bidders), and other operational information	All information already publicly available	No
13 January 2015	Centre for Internet and Society	Requesting an organizational chart for ICANN's leadership and management, as well as staffing information, internal team composition, and other details	Responded that most of the requested information, if it existed, was already posted on the ICANN website.	No
13 January 2015	Centre for Internet and Society	Expenses incurred and staffing resources allocated to the NETMundial conference, its resulting initiatives and its statement of principles; costs associated with travel, lodging, and other expenses specific to the conference; and ICANN staff hours committed to operations related to the NETMundial initiative	Declined	2, 3, 4, 6, 9, & 12	The response pointed to publicly available information, but declined to "create or compile" new reports or documents; also noted that NETMundial's website had posted or would soon post most of the information relevant to the CIS queries
20 January 2015	Guru Acharya	Documents related to the “Continuity and Contingency Plan" (plan for transfer to a successor contractor) described in Section C.7.3 of ICANN's IANA Functions Contract with NTIA.	After initially responding that it needed to consult with the parties to the contract to get consensus on making the plan publicly available, staff provided an update that the document was published in March	Initial response cited 1, 2, 3, & 9
6 February 2015	Centre for Internet and Society	Details of contract fees paid by the RIRs from 1999-2014, including a breakdown of contributions from each.	Pointed to published financial information, declined on threshold grounds (no such docs in ICANN's possession)	No	The response noted that NRO only published breakdowns of contributions by RIR for three years from 2003-2005
11 February 2015	Kin Sun	Documents related to allegedly unauthorized transfer(s) of a domain name	Declined	3 & 5
12 March 2015	James Gannon	Disclosure of Root Zone KSK Operator Function Termination Plan specified in Section C.7.3 of the IANA Functions Contract between ICANN and the NTIA	After initially responding that it needed to consult with the parties to the contract to get consensus on making the plan publicly available, staff provided an update that the document was published in March	Initial response cited 1, 2, 3, 9, & 10	Essentially the same request as Guru Archarya, above
14 March 2015	James Gannon	Disclosure of Contingency and Continuity of Operations Plan as specified in Section C.7.2 in the IANA Functions contract between ICANN and the NTIA	Declined	1, 3, 6, 10, & 11	Response notes that disclosure of the plan "could pose a threat to the stability and security of the Internet and domain name system," because the plan includes details of response & recovery planning in the event of targeted disruption of the Internet.
7 April 2015	Paul Kane	Workflow process documents with statistics for each stage of the IANA Root Zone Management Function	After initially responding that staff would have to consult with all involved parties regarding the publication of the information, staff later updated the record to note that the information had been published	Initial response cited 1, 2, 3, 6, 8, 9, 10, & 11
27 April 2015	James Bridle	Documents relating to the delegation and operation of .io, including correspondence between ICANN and the delegated authority	Provided context but declined to produce documents on threshold and DCND grounds	1, 2, 3, 9, & 10	.io is an Open Use ccTLD that was delegated by IANA in 1997, prior to the formation of ICANN, and using IANA's standard procedure for assigning operation of ccTLDs, as described in RFC 1591
5 June 2015	Flip Petillion	Information & documents regarding the data exposure issues in the new gTLD application and GDD portals that exposed the data of .hotel applicants and others.	Provided a narrative of the data exposure incident as related through ICANN's public announcements and updates on the issue; did not produce new documents	2, 5, 6, 8, & 9
17 July 2015	Edward Morris	ICANN's contract with Westlake Governance Limited to perform the Second GNSO Organizational Review, as well as communications between ICANN and Westlake during the conduct of that review. Full request	Provided portions of the contract language	2, 3, 6, 8, 9, & 11	Morris was displeased with the work of Westlake and submitted a comment on Westlake's draft report, stating that the report should be "completely disregarded."<ref>GNSO2 Public Comment Listserv Archive - Personal Comment of Edward Morris, July 31, 2015
22 July 2015	Centre for Internet and Society	Documents relating to ICANN's effort to implement the NETmundial Initiative	Declined	1, 2, 3, 6, 8, 9, & 12	Request was duplicative of CIS' earlier request for information about ICANN's implementation of NETMundial principles
22 July 2015	Centre for Internet and Society	"Raw data" for ICANN's revenue, budget, and financial information for 2009-2011	Declined	12	Again, the request was a different flavor of a prior request for financial information and was rejected on the same grounds
27 July 2015	Kevin Murphy	Unredacted documents, filings, and exhibits in the Independent Review Process DotConnectAfrica Trust v. ICANN	Pointed to public record, noted that recently updated documents were substantially less redacted, and agreed to consult with the parties to see if further redactions were possible (no result). Did not produce new documents.	1, 2, 5, & 9
1 September 2015	Centre for Internet and Society	Two separate requests regarding Contractual Compliance audits for registries and registrars - ICANN issued one response for both. Registry audit request. Registrar audit request.	Provided some additional documentation & information	2, 3, 5, & 6 (Registry audit DIDP); 3, 5, & 6 (Registrar audit DIDP)
1 September 2015	Centre for Internet and Society	Documentary information regarding steps or enforcement actions taken by Contractual Compliance in response to its audits of registries, and specifically any communications between Contractual Compliance and Verisign. Full request.	Provided public information and context, but declined to produce additional documents	3, 5, & 6
1 September 2015	Centre for Internet and Society	Document related to the "process of regulating" registrars' obligations under the Registrar Accreditation Agreement to maintain a contact for abuse reporting, and investigate and respond to reports of such abuse. Specifically asked for "reports of illegal activity submitted to registrars" and "records relating to the actions taken by registrars that have been submitted to ICANN" during 2014 & 2015.	Declined	2, 3, & 5	The vast majority of records requested were in the custody of each registrar, not ICANN. Those in ICANN's possession were subject to the DCND
1 September 2015	Centre for Internet and Society	The names of those working in Contractual Compliance, a "copy of the document that calls for appointments to the post of the contractual compliance auditor," and the contract between ICANN and that auditor.	Posted public RFP information for the call for a compliance auditor; compliance staff was already public; contract with KMPG (the selected audit partner) will not be disclosed	2, 3, 5, & 6
1 September 2015	Centre for Internet and Society	A document detailing the contents of ICANN's intranet	Declined	1, 2, 3, 5, 6, 8, 9, 11, & 12	In addition to the broad number of reasons why such a request was impossible to fulfill, no such document existed.
10 September 2015	Mark Seiden	Documents recording security incidents reported to ICANN during 2013, 2014, 2015 to date under section 3.20 (iii) of the Registry Accreditation Agreement	Declined	5 & 6	Response noted that Seiden's work on the SSAC was the reason for the request and expressed hope that the SSAC's efforts to arrange anonymized reports re: security information would meet with success
10 September 2015	Asia Green IT System Ltd.	Documents related to the New gTLD Program Committee's decision to reject Asia Green's applications for .halal and .islam, based on GAC advice, community objections, and other context. Full request.	Provided a single letter written by Steve Crocker, which had inadvertently not been published on ICANN's correspondence page. Otherwise denied.	1, 2, 3, 8, & 9	Response pointed to copious amounts of publicly available information on the NGPC's deliberations, communications with the GAC and other objections, and other relevant documents.
18 September 2015	American Institute of Certified Public Accountants	Information related to the determination that the Institute did not prevail in its Community Priority Evaluation for .cpa. Full request.	Provided the email that approved the initiation of the CPE, but otherwise declined to produce documents	2, 3, 5, 6, & 9
18 September 2015	CPA Australia	Information related to the determination that CPA Australia did not prevail in its Community Priority Evaluation for .cpa. Full request.	Provided an email approving initiation of CPE process, otherwise declined to produce documents	2, 3, 6, & 9	Very similar request as the Am. Inst. of CPAs
21 September 2015	Don Moody, on behalf of Donuts, Inc. and its subsidiary Foggy Sunset, LLC	Information related to the determination approving Asia Spa & Wellness Promotion Council's Community Priority Evaluation for .spa. Full request.	Provided the email that initiated the CPE process, as well as the one public comment on the Community Evaluation forum that was received in relation to the .spa CPE; otherwise declined to produce documents	2, 3, 5, 6, & 9	Response noted that the DIDP request identified most of the publicly available information regarding the CPE.
22 October 2015	Bart Lieben on behalf of dotgay LLC	Information regarding the determination that dotgay LLC did not prevail in its second Community Priority Evaluation for .gay. Full request.	Provided email exchanges between ICANN staff and the third party CPE evaluator regarding the completeness of the record at the initiation of the second CPE; otherwise declined to produce documents	2, 3, 8, 9, & 12
17 November 2015	Jeffrey Smith on behalf of Commercial Connect, LLC	Documentation related to deliberations and decisions for .shop string contention set. Full request.	Provided the notice emails sent to Commercial Connect related to the .shop string contention process; otherwise pointed to public information and declined to disclose other documents	2, 3, 5, 8 & 9
30 November 2015	The Centre for Internet and Society	All documents submitted to the NTIA regarding the IANA Functions Stewardship Transition, and particularly the extension of the IANA Functions contract beyond the initial transition deadline. Full request	Declined		The response noted that the DIDP request was very broad; however, as there were no documents in ICANN's possession responsive to the request, DCND 12 was not "officially" cited
30 November 2015	The Centre for Internet and Society	Documents regarding the presumptive renewal clauses of Registrar Accreditation Agreements, including any documents defining the rationale for including such a clause, and specifically documents related to the renewal of .com & .net with Verisign and .org with Public Interest Registry. Full request.	Pointed to published documents; otherwise declined to deliver more.	1, 2, 3, 8, & 9
30 November 2015	The Centre for Internet and Society	Documents regarding the relationship between ICANN and the RIRs, including any contracts or agreements between them and financial information related to RIR payments to ICANN. Full request	Declined	1, 2, 3, 9, & 12	Response noted that many of the links to published materials had been provided in response to an earlier DIDP from CIS.
1 December 2015	Mike Rodenbaugh, Asia Green IT Systems	Documents regarding Asia Green's application for the .PERSIANGULF gTLD, and the Independent Review Process (IRP) filed by the Gulf Cooperation Council relating to the .PERSIANGULF string. Specifically, correspondence regarding the IRP, and any documents or records of the June 2014 meeting between ICANN and the Gulf Cooperation Council.	Provided the email notice to Asia Green regarding its change in application status to "on hold" - otherwise declined	1, 2, 3, 5, 6, 8, & 9
11 February 2016	Registrar Stakeholder Group Executive Committee	Requested details of the travel support provided by ICANN with relation to the NCPH Intersessional meetings in 2015 and 2016	Provided the requested information	12	Response did not seek to gather cost & budget information for ICANN staff - the money for staff travel did not come from community support funds and would be burdensome to collate.
23 April 2016	Centre for Internet and Society	Reports submitted by the Board Governance Committee to the full board, as required by the ICANN Bylaws	Pointed to published reports
23 April 2016	Centre for Internet and Society	Requesting "diversity analysis" documents of Public Comments, similar to the IANA Stewardship Transition Coordination Group's analysis of public comments related to its work on the IANA Transition	Declined		ICANN does not perform such analysis, thus no documents existed
23 April 2016	Centre for Internet and Society	Requesting information related to ICANN's Contractual Compliance audits of registrars and registries, as referenced in Fadi Chehade's welcome speech at ICANN 51	Pointed to published materials, otherwise declined	2, 5, & 6	Again, the response noted that this request was essentially a duplicate of a previous DIDP request from CIS.
23 April 2016	Centre for Internet and Society	Requesting details of ICANN's internal sexual harassment policies and training	Provided ICANN's policy, could not provide details on the training	5	ICANN's agreement with its training provider included restrictions on sharing proprietary information
23 April 2016	Centre for Internet and Society	Requesting "accurate" statistics regarding staff responses to DIDP requests. Full request.	Reported that ICANN was conducting a statistical analysis of the DIDP program and would post results on its website. Otherwise declined.	2, 6, & 8	"With respect to the research summary that you provided in your DIDP Request and that you presented at the Non-Commercial Users Constituency (NCUC) Session, held on 8 March 2016 at ICANN55 (referenced in your Request), while it is not within the parameters of a DIDP request or response for ICANN to review your research “for accuracy” as you request in your presentation, ICANN does note several discrepancies with the information and/or characterizations provided in your summary. In several instances, your characterizations of 'no' or 'partly' disclosed are either mistaken, do not acknowledge the information and documents identified as publicly posted, do not take into consideration the nature of the requests and the existence (or lack thereof) of responsive documents, and/or do not consider the balancing required between the public benefit and the potential harm of requested disclosures."
26 April 2016	Centre for Internet and Society	Requesting information related to the Applicant Support Program that was part of the New gTLD Program	[https://www.icann.org/en/system/files/files/didp-20160426-1-cis-response-25may16-en.pdf Pointed to published information and statistics.		All information responsive to the request was already publicly available.
29 April 2016	DotMusic Limited	Extensive request for documents and other information to DotMusic's failed Community Priority Evaluation (CPE) for .music. Full request.	Provided email correspondence between ICANN staff and the CPE provider; otherwise declined to disclose documents	2, 3, 5, 6, & 9	As with other DIDP requests relating to CPEs, this one did not succeed beyond a single transactional email chain between ICANN and the CPE provider.
2 May 2016	Centre for Internet and Society	Information regarding ICANN's "Root Zone Management" agreement with Verisign	Clarified that there was no such agreement and provided context around Verisign's role in root zone maintenance and how the IANA Transition changed the picture.	No
9 May 2016	GCCIX, WLL	Information related to the evaluation of GCCIX's application for .gcc, objections from the GAC and the Cooperation Council for Arab States of the Gulf, and other records of deliberations and discussions of the same. Full request included in response.	Declined	1, 2, 3, & 6	Response cited published records related to the inquiries.
5 August 2016	Donuts, Inc.	The agreement between ICANN and Internetstiftelsen I Sverige for pre-delegation testing services	Declined; however, ICANN published a summary of PDT testing vendor selection and service agreements on the New gTLD Program micro-site.	5, 6, & 11
29 August 2016	Michael Palage	"Any documents in ICANN's possession" on the topics of "malware, spam, bots, cybersquatting, malicious/illegal activity, etc., in connection with the domain name system...over the past three years"	Pointed to published documents; declined to produce more	1, 2, 3, 6, 9, & 12	Response attempted to guide Palage to both documents and "likely sources" of documents, such as the SSAC
22 September 2016	Dot Registry LLC	Request for ICANN Board meeting attendance, minutes, and preparatory materials for the meetings in August and September 2016; and other documents related to the Community Priority Evaluation review Full request.	Responded that all documentation regarding the meetings, as well as the CPE Review, were publicly available. Declined to produce additional documents.	2, 8, & 9
25 September 2016	Michael Palage	"All related documents" from the Special Meeting of the Board on Feb. 8, 2005, and any correspondence to third parties resulting from the actions taken at that meeting. (The meeting approved resolutions related to the Verisign Site Finder settlement)	Declined	2, 6, 8, & 9	The response noted that "the Requester was a member of the ICANN Board at the time of the 8 February 2005 Board Meeting" and pointed to an extensive public record of the settlement: "Subsequent to the 8 February 2005 Board meeting, a vast amount of information, communications, and documents have been publicly posted on ICANN's website regarding the litigation between Verisign and ICANN, including the proposed and revised settlement agreement, the public comments on the settlement agreement and proposed .com Registry Agreement, ICANN press releases, as well as correspondence."
17 October 2016	Dot Registry LLC	Identity of the "working group" that was scheduled to meet at ICANN 57 regarding the .web and .inc gTLDs, agenda for that meeting, and rationale for holding the meeting without applicants for those strings. Full request.	Clarified that the meeting was a workshop session for the ICANN Board, not a "working group" meeting. Declined to produce agenda b/c of DCND.	2 & 8
24 October 2016	Centre for Internet and Society	Documentation of ICANN's compliance with lobbying laws	Pointed to public records of ICANN's lobbying activities; declined to produce other documents.	No
24 October 2016	Centre for Internet and Society	Details of FY 2015 costs associated with the IANA Transition. Full request.	Answered questions but did not produce documents	2, 5, 6, & 8	Response cited the process exemption that ICANN was not required to "create or compile" documents
24 October 2016	Centre for Internet and Society	Copies of "all speeches and statements made by Goran Marby since his appointment as ICANN President and CEO in February 2016."	Provided links to recordings and transcripts for ICANN events; attempted to link to proceedings or records of non-ICANN events	No	"To the extent your Request includes speeches and/or statements that were made by Mr. Marby outside of ICANN operated or hosted sessions, ICANN does not have possession, custody or control of those transcripts or recordings."
24 October 2016	Centre for Internet and Society	Breakdown and rationale for staff & board travel allocations to travel "economy, business, & first class"	Provided links to travel policy; Declined to get into specifics or produce additional documents	4
24 October 2016	Centre for Internet and Society	Count of accredited registrars for specific time periods in ICANN's operational history: testbed; 1999-2001; 2001-2009; and 2009-date of request	Pointed to what information was already publicly available; declined to compile data	No	Another good example of a DIDP request that asks for nonexistent documents, where ICANN is not obligated to compile information responsive to the request
24 October 2016	Centre for Internet and Society	Correspondence between ICANN and (1) the World Economic Forum and (2) CGI.Br related to NETMundial and the NETMundial Initiative	Pointed to external resources, declined to produce new documents	12 (implied)	"As noted in response to DIDP Request No. 20141228-1-NETmundial, ICANN is one of just many participants in the Internet governance realm, and ICANN is not the home for implementation of the NETmundial Principles or the evolution of multistakeholder participation in Internet governance...To the extent that this Request is seeking communications between representatives of WEF or CGI.Br and ICANN relating to the NETmundial Initiative this request is quite broad and seeks information that is not easily identified, and is ultimately of a low value to produce."
24 October 2016	Centre for Internet and Society	Correspondence between the Namibian Network Information Centre (NNIC) and ICANN; agreements between those entities that "give administrative control" of .na to NNIC; and "outputs and presentations to the board" by the ccNSO Technology working group during the tenure of Dr. Eberhard Lisse as chair of that group. Full request.	Declined to respond to the first item beyond already-published correspondence. ICANN was not in existence when .na was delegated and was not in possession of anything responsive to the second item. There were also no documents responsive to the third item (presentations of the ccNSO technology working group)	10
24 October 2016	Centre for Internet and Society	Documents showing why ICANN only possesses specified breakdowns of Regional Internet Registry contribution to ICANN for three fiscal years (2003-2005); requesting that ICANN square its reporting of FY 2003 contributions with the specific breakdown of RIR contributions.	Acknowledged and corrected the FY 2003 discrepancy; no documents existed re: the first item	No	"Because the RIRs do not contribute to ICANN on an individual basis (with the exception of FY03 through FY05) ICANN does not have the breakdown that is sought through the Request. ICANN does not have, nor does ICANN seek any information from the NRO or the individual RIRs as to how individual RIRs may have contributed towards the ICANN contribution. ICANN does not have any input as to whether the RIRs contribute collectively or through individual contributions. As such, ICANN does not have any documents responsive to this item."
24 October 2016	Centre for Internet and Society	ICANN's process for verifying the identity of bidders in auctions under the New gTLD Program; specifically, steps taken and documents received in the process of verifying the identity of Nu Dot Co.	Pointed to public information; did not disclose additional documents	8	Information pertaining to Nu Dot Co.'s identity was related to Ruby Glen v. ICANN
24 October 2016	Centre for Internet and Society	Documents showing (1) the board's decisions on the use of proceeds from ICANN's gTLD auctions, and (2) any presentations or proposals from working groups regarding the expenditure" of auction proceeds	[https://www.icann.org/en/system/files/files/didp-20161024-10-cis-response-23nov16-en.pdf pointed to public information and the Cross Community Working Group on New Generic Top-Level Domains Auction Proceeds workspace	No	In response to both items, ICANN noted that there were as yet no documents responsive to the requests
25 January 2017	Ben Sobel	Information related to (1) the initial delegation of the .pr ccTLD to the University of Puerto Rico, and (2) documents, correspondence, and other records related to redelegation requests and decisions for .ag, .bb, .bz, .bs, .dm, .do, .gd, .gy, .jm, .kn, .lc, .sr, .tt, and .vc during the time that those ccTLDs were managed by the University of Puerto Rico.	Pointed to published IANA reports and board meeting minutes related to some redelegation requests that were responsive to the query; noted several cases where delegation pre-dated ICANN. Request for "correspondence" denied.	1, 2, 3, & 10
14 February 2017	Michael Palage	"Documents, initiatives and research dealing with the blockchain and distributed ledger technology (DLT) in connection with the DNS and other unique identifiers schemes/frameworks"	Declined	2, 9, & 10
5 May 2017	Arif Ali on behalf of DotMusic Limited	Documents related to the Community Priority Evaluation process review, including documents provided by the reviewing third party to ICANN. Full request.	Pointed to public information; denied request for documents from reviewer to ICANN on DCND grounds.	2, 3, 8, & 9
6 May 2017	Avri Doria	Documents related to ICANN & the ICANN Board responses to SSAC 045, which identified potential risks associated with the New gTLD Program in situations where previously invalid TLD strings were awarded to a registry during the applications process. Full request.	Provided public documents, history, and context but declined to disclose additional documents.	2, 8, 9, & 10	SSAC 045 finds in part: "ICANN should make applicants for new TLDs aware of the following: Any new TLD registry operator may experience unanticipated queries and some TLDs may experience a non-trivial load of unanticipated queries if the label it chooses corresponds to TLDs that have historically seen queries. Studies illustrate that the amount of inherited query traffic could be considerable, i.e., on the order of millions of queries per day, should the applicant’s chosen string be one that appears frequently at the root. While millions of queries per day is manageable from an operational perspective, it is prudent for ICANN to make applicants aware of the potential for inherited traffic so they are prepared to manage the volume, and will thus minimize the possibility of operational difficulties that would pose a stability or availability problem for their registrants and users.
18 May 2017	Arif Ali on behalf of dotgay LLC	Documents related to the Community Priority Evaluation process review, including documents provided by the reviewing third party to ICANN. Full request.	Pointed to public information, otherwise declined.	2, 3, 8, & 9	Response noted the similarity of Ali's two requests for similar information on behalf of two separate clients and made reference to the earlier response re: DotMusic Limited
8 June 2017	Shaul Jolles on behalf of Dot Registry, LLC	"Any and all" documents related to Dot Registry's community applications for .inc, .llc, and .llp that were used, produced, or contained in the Community Priority Evaluation process review. Full request.	Pointed to public information	No	"With the exception of the correspondence between ICANN organization and the CPE provider regarding the evaluations, all materials provided to the evaluator are publicly available. Regarding the correspondence between ICANN organization and the CPE provider regarding the evaluations, including any document and draft CPE reports that were exchanged concerning the evaluation of Dot Registry’s applications for .inc, .llp, and .llc, these documents were provided to Dot Registry in the IRP pursuant to the Panel’s order regarding document production."
10 June 2017	Arif Ali on behalf of DotMusic Limited and dotgay LLC	Documents relating to the selection of and process employed by the third-party reviewer of the Community Priority Evaluation process (items 1 and 3); list of ICANN staff, board members, agents, etc. that were interviewed as part of the CPE process review (item 2); and confirmation that "ICANN will disclose FTI's final report to the CPE applicants...immediately after FTI completes its review." (item 4) Full request.	Responded that: Items 1 & 3 were asked and answered in Ali's prior DIDP requests; items 2 & 4 are "not appropriate DIDP request[s]," and in any event are subject to DCNDs.	2, 3, & 8
13 June 2017	Vidushi Marda on behalf of the Centre for Internet and Society	Requesting "detailed reports with historical data on income and revenue contributions from domain names, for FY15 and FY16, in the manner in which FY13 and FY14 were published;" and requesting a status update regarding a similar planned report for FY 2012	Responded with estimated timeframes until the publication of those reports	No
14 June 2017	Flip Petillion on behalf of Travel Reservations SRL, Spring McCook, LLC, Minds + Machines Group Limited, Famous Four Media Limited, dot Hotel Limited, Radix FZC, dot Hotel Inc., and Fegistry, LLC	Documents related to the selection of FTI as the third-party reviewer for the Community Priority Evaluation process review, and information pertaining to FTI's process, documents submitted to FTI, and any other details.	Responded with links to public information, referred to prior response to Petillion regarding the DCNDs that prevented disclosure of any other documents.	2, 3, 5, 6, & 9
27 July 2017	Karl Kronenberger	"All documents supporting or related to" Cyrus Namazi's comment at a cross-community presentation at ICANN 59 regarding the predicted loss of approximately 750 accredited registrars during FY 2018. Full request.	Pointed to public information, declined to disclose additional documents	2, 3, 5, & 9
10 January 2018	Arif Ali on behalf of DotMusic Limited	Laundry list of documents related to the Community Priority Evaluation process review. Full request	Declined	2, 3, 4, 5, 6, 8, & 9
15 January 2018	Arif Ali on behalf of dotgay LLC	Similar laundry list request for documents related to the Community Priority Evaluation process review. Full request.	Similarly denied	2, 3, 4, 5, 6, 8, & 9
1 February 2018	Michael Karanicolas	(1) criteria for selection of "Regional Newcomer" fellows for ICANN 62; (2) the budget allocated for those fellows; and (3) the total number of regional newcomers selected	Responded with details, history, and links to public information; request spurred ICANN to produce additional documentation for the program; ICANN declined to release emails that were responsive because of DCNDs	2, 3, & 9
23 February 2018	Arif Ali on behalf of Afilias	Update on the .web contention set, including: documents of any steps taken regarding Nu Dot Co.'s change of ownership or control in violation of the Applicant Guidebook; documents of any steps taken to analyze competition issues arising from the delegation of .web to Verisign. And, information & documents related to all applications for .web, communications between applicants and ICANN, and other documents. Full request	Initially declined to produce documents on threshold grounds (no such documents in ICANN's possession) and DCND grounds. Subsequently responded to say that all other parties except responded to ICANN's queries affirming that they wanted their application materials to remain confidential.	1, 2, 3, 4, 5, 6, 8, 9, 11, & 12
25 March 2018	Jonathan Matkowsky on behalf of RiskIQ, Inc.	All documents "referring or relating to enforcement forbearance from GDPR." Full request	Pointed to public information, declined to produce more	1, 2, 3, 6, 8, & 9
26 March 2018	Akriti Bopanna on behalf of the Centre for Internet & Society	Fiscal Year 2017 reporting (similar to prior requests for detailed financial information)	Initially responded that the information would be posted once complete. Followed up with a copy of the report and a link to the report on ICANN's website	No
23 April 2018	Arif Ali on behalf of Afilias	"Amended" several items from the February 2018 DIDP request, and proposed that other items from that request be produced under the terms of a confidentiality agreement. Full request.	Declined again - the "confidentiality agreement" because it defeated the point of DIDP requests and the "amended" requests for DCND reasons similar to ICANN's response to the February request.	1, 2, 3, 4, 5, 6, 8, 9, & 11	"As explained in ICANN organization’s 27 April 2018 response email to you, the concept of a confidentiality agreement for the disclosure of documents through the DIDP runs afoul of the DIDP itself, which is to make public documents concerning ICANN organization’s operations unless there is a compelling reason for confidentiality...The DIDP is not a mechanism for one to make information requests or requests to obtain litigation-style discovery. As further indicated in ICANN’s 27 April 2018 response email, ICANN’s DIDP Response 20180223-1 indicated that Item Nos. 5 and 6(a)-(b) were overbroad and vague and that Requestor could further clarify or narrow the scope of those Items if it wished to do so. Afilias’ 23 April 2018 letter, however, goes far beyond those parameters and, in many instances, broadens and/or fundamentally changes the requests contained in DIDP Request 20180223-1. As such, and as indicated in ICANN’s 27 April 2018 email, ICANN organization will treat these “amended” requests as a new DIDP Request, with an effective submission date of 23 April 2018, and ICANN organization will respond through and in accordance with the DIDP Process."
25 May 2018	Paul Kurian on behalf of the Centre for Internet and Society	Salary information for ICANN staff, including regional and gender-specific averages, and ICANN's compensation strategies.	Pointed to public information, declined to produce more documents on DCND grounds	2, 4, 6, 8, & 9
10 June 2018	George Kirikos	Kirikos filed an appeal under GNSO Working Group Guidelines relating to the IGO/INGO Access to Curative Rights PDP His DIDP request sought recordings or transcripts of conversations specific to that appeal.	Pointed to public information, declined to produce more on threshold grounds and DCND grounds.	2, 3, & 9
16 July 2018	Akash Sriram on behalf of the Centre for Internet & Society	Breakdowns of ICANN employees by race and nationality	Declined because documents on citizenship did not exist, and because a racial breakdown would involve disclosing documents that were restricted under the DCNDs.	1, 4, & 9
12 November 2018	Akriti Bopanna on behalf of the Centre for Internet & Society	Documents related to ICANN's Fellowship Program, and specifically: instances where ICANN awarded a fellowship to an individual more than the maximum limit of 3 times; the decision process for awarding a fellowship beyond the maximum; and safeguards to ensure that the maximum is not exceeded	Responded that the 3x limit on participation was not established until 2018, and would first be in effect for fellowship applications for ICANN 65. As such, no documents existed responsive to prior procedures.	2, 3, & 4	"As a preliminary matter, the DIDP is a mechanism for the disclosure of documentary information about ICANN org’s operations that are appropriate for disclosure but has not be already been published. This Request seeks the disclosure of information, not documents, and is not an appropriate DIDP request. Nevertheless, ICANN org has responded to your requested items below."
21 December 2018	Arif Ali on behalf of Afilias	Correspondence and communication between Verisign and ICANN regarding: the .web contention set, Afilias' CEP and IRP regarding the same; and internal and external communications regarding the IRP Implementation Oversight Team's drafting and adoption of Section 7 of the Interim Procedures for IRPs. Full request.	Declined to produce Verisign communications for the same reasons as prior requests; pointed to public listserv archives regarding ITP-IOT communications; and pointed to board briefing materials re: the adoption of the interim supplemental procedures. Subsequent updates alerted Afilias to additions to "off-list" communication between IOT members	2, 3, 5, 6, 8, & 12	Afilias contended in their DIDP request that Verisign had undue influence on the creation and adoption of the Section 7 rules, to the detriment of Afilias and the Internet community as a whole.
6 January 2019	William Donovan	Information related to the Universal Acceptance Steering Group Full request.	Pointed to public documents; most items of the request were for information rather than documents, and some were accusatory.		"Items 9 through 12 are not asking for documentary information, and instead, are seeking the disclosure of information based upon purported presumptions of misconduct on the part of UASG. Thus, these are not proper DIDP requests."
25 March 2019	Akriti Bopanna on behalf of the Centre for Internet & Society	Inquiring about the disposition of proceeds from ICANN's auctions of last resort	Pointed to public information - no new documents were presented	No
1 April 2019	Arif Ali on behalf of Afilias	Further requests for correspondence & records of IRP-IOT proceedings	Responded that some items were asked and answered in the response to the December 2018 DIDP request; in other cases, documents did not exist or were subject to DCND	3 & 8
2 April 2019	Ivan Castaño on behalf of the Government of Colombia	Requesting documents related to Specifications 11 and 13 of the Registry Agreement adopted as part of the New gTLD Program.	Responded that no documents existed re: amendments to Specification 13, and that registry operator requests to amend Specification 11 commitments were subject to DCND	3, 5, 6, & 8	The request was in relation to Amazon's application for .amazon, and gaining an understanding of Public Interest Commitments and other aspects of the Registry Agreement
5 July 2019	Akriti Bopanna on behalf of the Centre for Internet & Society	Requesting budget information for policy development, and specifically "detailed breakdown[s] for the budgets for every Advisory Council as well as Supporting Organizations for the previous fiscal year"	Pointed to public information; no other documents existed that were responsive to the request	No	Staff noted that such information might be valuable to produce and would consider it in the future.
3 October 2019	Michael Palage	Requesting documents and information regarding ICANN's 2016 amended and restated Articles of Incorporation, and their compliance with California statutes regarding public benefit corporations. Full request.	Response noted that Palage's questions were related to public benefit corporations (as opposed to nonprofit public benefit corporations) and that ICANN was not required to comply with the laws referenced in Palage's request. As such, the documents that are required by the statute were not created and did not exist. Pointed to public information regarding other requests.	No	California adopted a "benefit corporation" statute as part of a trend of states permitting for-profit companies to base their decisions on social, environmental, and ethical concerns, as opposed to being solely guided by increasing shareholder value. "As discussed in response to Question No. 1, ICANN org is organized as a Non-For-Profit Public Benefit Corporation, which is a separate and distinct corporate form from a Public Benefit Corporation. The two types of entities are governed by different statutory requirements."
13 December 2019	Amy Ward, Mitch Stoltz, and Jacob Malthouse	Documentary information regarding the proposed transfer of .org registry operations to Ethos Capital. Full request	Provided history & context, declined to produce additional documents	3, 5, 6, 8, 9, & 12
8 January 2020	Flip Petillion on behalf of Namecheap Inc.	Omnibus request for anything and everything related to "reassignment, renewal and amendments of the .ORG, .BIZ, and/or .INFO Registry Agreements;" "economic studies, impact studies, and other studies ICANN has commissioned, examined and/or performed with respect to competition and/or pricing of TLDs (in particular original gTLDs (.COM, .NET, .ORG) and gTLDs that were delegated pursuant to ICANN Resolution 00.89 of 16 November 2000 (e.g., .BIZ, .INFO)), and with respect to vertical integration between registries and registrars;" and "all documents directly and indirectly relating to the change of control of Public Interest Registry." [	Objected to breadth and scope of the request, and declined to produce documents.	1, 2, 3, 5, 6, 8, 9, 10, & 12	The response took pains to provide links to publicly available information.
14 February 2020	Flip Petillion on behalf of Namecheap Inc.	ICANN's responses to an inquiry from California's Attorney General's Office regarding the proposed transfer of .org from Public Interest Registry to Ethos Capital, and ICANN's communications to PIR and other third parties in relation to the Attorney General's investigation	Declined to produce nonpublic documents; pointed to many public documents	1, 3, 5, & 6
19 February 2020	Michael Palage	Documents related to the ICANN Board's decision to cancel the in-person component of ICANN 67, originally scheduled to be held in Cancun. Full request.	Provided some narrative responses but did not disclose documents	1, 2, 3, & 6
10 June 2020	Ephraim Percy Kenyanito on behalf of ARTICLE19	Documents and information regarding the implementation of CCWG-Accountability Work Stream 2 recommendations related to improving the office of the ICANN Ombudsman. Full request.	Declined for threshold and DCND reasons	4 & 7	A rare appearance of the DCND regarding "Information that, if disclosed, would or would be likely to endanger the life, health, or safety of any individual or materially prejudice the administration of justice."
10 June 2020	Ephraim Percy Kenyanito on behalf of ARTICLE19	A broader request regarding the implementation of board-approved CCWG-Accountability Work Stream 2 recommendations.	Declined for threshold and DCND reasons	1, 2, 3, 5, 6, & 9
20 October 2020	John Baird	A copy of ICANN's "Contractor Consulting Agreement"	No single agreement because each vendor agreement is negotiated; declined to produce documents	4, 5, 6, & 11	"To date, ICANN org has not had a practice of publishing its Contractor Consulting Agreements or other vendor agreements as they often include personal information of the contracted party, pricing and terms related to a service, confidential business information of the contracted party and other confidential information..."
4 February 2021	Edgar Lavarello and Mike Rodenbaugh on behalf of Dot Hotel Limited and Domain Ventures Partners PCC Limited	Documents related to ICANN's approval of a change of control request from the registry operators owned and controlled by Afilias, Inc.	Declined for threshold and DCND reasons	2, 3, 5, 6, 8, 9, & 11
28 June 2021	Mike Rodenbaugh on behalf of GCCIX WLL	Documents and information related to the "IGO Work Track" (part of the PDP Review of All Rights Protection Mechanisms in All gTLDs) referenced in the GAC Communique from ICANN 71	Responded with history, context, and links to the Working Group wiki space	1, 3, & 9
10 December 2021	J-P Voillequé on behalf of ICANNWiki	Documents, public comment, correspondence, and proceedings related to 2007 changes to Contractual Compliance procedures, including initiating compliance audits for registries and registrars.	Pointed to public information; did not produce documents for threshold reasons.	No	The request also resulted in the restoration of transcripts from ICANN 28, which were previously not available

At-Large Advisory Committee. Considers and provides advice on the activities of ICANN related to the interests of individual Internet users (ICANN Bylaws). Not to be confused with the Non-Commercial Stakeholder Group.

Business Constituency

Top-Level Domain

Internationalized Domain Name

Governmental Advisory Committee. Considers and provides advice on the activities of ICANN as they relate to concerns of governments, particularly matters where there may be an interaction between ICANN's policies and various laws and international agreements or where they may affect public policy issues (ICANN Bylaws).

Internet Assigned Numbers Authority

Security and Stability Advisory Committee. Advises the ICANN community and Board on matters relating to the security and integrity of the Internet's naming and address allocation systems (ICANN Bylaws).

Non-Commercial Stakeholder Group. Represents the full range of non-commercial entities of the Internet (ICANN Bylaws). Not to be confused with the At-Large Advisory Committee.

Country code top-level domain

Independent Review Process

Country Code Names Supporting Organization. Develops and recommends to the Board global policies relating to country-code top-level domains (ICANN Bylaws).

Number Resource Organization

General Data Protection Regulation

Universal Acceptance Steering Group