The SECOND rule of auDA is… YOU DO NOT TALK ABOUT CAROLINE FRITSCH!!

Following up from our previous two articles; (The first rule at auDA is… You DO NOT talk about Caroline Fritsch) and (auDA Manager breaches code of conduct), I recently received a letter from a legal firm representing Caroline Fritsch.

Caroline Fritsch’s lawyers are requesting I remove the above two articles from Domainer by 4 pm on 16 March 2021.

I will not do so.

In the letter, Caroline Fritsch’s lawyer claims his purpose is to “correct numerous inaccuracies” in the articles, then attempts to explain across two pages (as if he is a domain name policy expert), why no one can register the AIF.com.au domain name (including Ned from this article).

I continue to stand by the content and series of events I wrote about in the two articles above. And let’s not forget, there’s more information about this whole AIF.com.au saga in Ned’s articles; “auDA CEO Tries to Stifle The Truth” and “auDA, This Doesn’t Pass The Pub Test“.

One good thing to come out of the lawyer’s recent letter is, it appears Caroline Fritsch has now admitted she was in the wrong, in regards to when she incorrectly stated to her contact at Defence that Ned had previously been refused consent to use the domain name. Which wasn’t true.

Caroline Fritsch’s lawyer wrote;

“Ms Fritsch accepts she should have further verified the relevant information at the time.”

This echoes what the auDA CEO said last year – see point 1 below.

Here are the reasons why I won’t be removing the requested articles by Caroline Fritsch’s lawyers;

  1. The auDA CEO accepts that Caroline Fritsch should have done “some fact checking” before replying to external communications.
  2. I stand by the content of the articles as I believe them to be a true and correct version of events that saw Ned’s AIF.com.au generic three-letter acronym domain name effectively stripped from him after he had been given permission by Defence to use it. In my honest opinion, I believe interference and the false or incorrect statement was a major catalyst that caused him to lose the domain name.
  3. There are several other “AIF” keyword businesses and trademarks registered in Australia with matching “AIF” domain names. Did auDA or Caroline Fritsch bother to ask the Defence Minister about any of these registrations in the past?
  4. Caroline Fritsch is auDA’s Policy and Strategy Manager. Chasing up domain complaints seems like a very unusual thing for her to do, considering her job title.
  5. Ned was originally approved the use of the domain name, and then Mark Bouck (Senior Compliance Officer at auDA) simply asked him to request a slight amendment from Defence (entity name). But, the lawyer goes on to state in this new letter, “The auDA Chief Operating Officer, asked Ms Fritsch to contact Defence”. This merely raises more questions… What does Bruce Tonkin (auDA COO) have to do with this and why has he been brought up all of a sudden in this legal letter? Why wasn’t the auDA Complaints Manager asked to follow this up, instead of Caroline Fritsch, the Policy and Strategy Manager?
  6. Why has the lawyer requested me to remove my two articles, but not the two articles written by Ned? (auDA CEO Tries to Stifle The Truth and auDA, This Doesn’t Pass The Pub Test)
  7. Who’s paying Caroline Fritch’s legal bills? Did Rosemary Sinclair (current auDA CEO) approve this? If so, is this the best use of Registrant’s money by the not-for-profit organisation?

What’s ironic about all this is that this matter was slowly fading away, and Ned was almost willing to move on because he had exposed the truth. But now, here we go again!

21 thoughts on “The SECOND rule of auDA is… YOU DO NOT TALK ABOUT CAROLINE FRITSCH!!

  • Avatar
    March 12, 2021 at 3:59 pm
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    Seems like the tail is wagging the dog here. Outrageous. Surprised that they didn’t let sleeping dogs lie. Now Ms Fritsch’s conduct is again under the microscope.

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  • Avatar
    March 12, 2021 at 4:18 pm
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    Please post the lawyers letter in full so we may see their claimed position.

    If they stand by their letter they can`t oppose it`s publication..or is it just an attempted harrassment and threat to silence the media and protect people who may have done the wrong thing that caused damages and losses to another in this case…and possibly more examples?

    “Shine a light on the darkness and make it go away.”

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    • Avatar
      March 13, 2021 at 7:09 am
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      How many .au domain names in australia start with AIF? There are many which it seems auDA has done nothing about!

      Why did Caroline Fritsch target and refer to the AIF.com.au registrant as a “domainer” in a negative way inferring less rights?

      Why is she still anti domainer, anti monetisation, anti ppc, anti people investing in portfolios of .au etc? Who does she think funds auDA? Paying .au Registrants do before she ever got on the auDA Gravy Train.

      auDA and policy for years promoted at great expense using registrant funds advertising and marketing such as this to separate extensions and also this allows sometimes the same name in various extensions.

      If Government wants AIF.ASN.AU or .org.au or .gov.au they can.

      .com.au
      .net.au
      .id.au
      .edu.au
      .org.au
      .gov.au
      .asn.au

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  • Avatar
    March 12, 2021 at 7:12 pm
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    So this mysterious “trusted third party” is possibly Bruce Tonkin?

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  • Avatar
    March 13, 2021 at 6:50 am
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    Good idea Casper. Selective quoting is usually misleading unfortunately. Below is my letter in full…

    Dear Mr Kaay

    Domainer.com.au articles

    We write to you on behalf of Caroline Fritsch personally in relation to the following articles currently published on the Domainer.com.au website:

    • auDA Manager breaches code of conduct – https://domainer.com.au/auda-conduct/
    • The first rule at auDA is… You DO NOT talk about Caroline Fritsch. – https://domainer.com.au/do-not-talk-about-caroline-fritsch/.

    The purpose of this letter is to correct numerous inaccuracies in those articles, as follows:

    Relevant background

    1. On 9 December 2019 Ned O’Meara applied to the Defence Minister for consent to register the domain name AIF.com.au.

    2. “AIF” is an acronym for “Australian Imperial Forces”. It is an offence to use those letters in connection with a business without the Defence Minister’s consent.[1]

    3. In considering Mr O’Meara’s application, the relevant legislation states that the Minister must have regard to (at a minimum)[2]:

    (a) The relevant trade / business of the applicant;
    (b) Whether the applicant has previously been given consent to use prohibited words; and
    (c) The period for which consent is sought.

    4. The explanatory statement accompanying the legislation explains that, in most cases, Ministerial consent is granted because the proposed use of the words is unrelated to the Defence Force and purely descriptive of the activities to be undertaken by the applicant.[3]

    5. In light of auDA’s role, including its endorsement by the Commonwealth Government to ensure the .au country code is a safe, accessible and trusted Australian public asset for all internet users[4], Defence and other Government departments regularly seek auDA’s guidance in respect of applications to register .au domain names, and particularly where a Ministerial response is required.

    6. In this case, auDA’s guidance was not sought by Defence before an authorisation was issued to Mr O’Meara on 17 December 2019, which relevantly authorised “Australian Insurance and Finance” to use the domain name AIF.com.au for an “indefinite period.”

    7. The authorisation was subsequently presented to auDA by Mr O’Meara in support of his application. However, it was apparent from its terms that the authorisation had been granted based on information that did not properly address the requirements of the legislation. The auDA Chief Operating Officer, asked Ms Fritsch to contact Defence, and so Ms Fritsch wrote to Defence to address those matters. This was entirely appropriate in circumstances where the authorisation had not been granted to a legal person capable of holding a domain licence, and the legislation also required the Minister to have regard to the following matters:

    (a) The trade / business of the applicant, being Domain Syndicates Pty Ltd, not “Australian Insurance and Finance”. For this reason Ms Fritsch advised that Domain Syndicates was a domain investment company that specialised in the resale of domain names and click thru advertising.

    (b) Whether the applicant had previously been given consent to use prohibited words. For this reason Ms Fritsch advised that the Minister had previously refused Domain Syndicates Pty Ltd and Ned O’Meara’s requests to use other prohibited words and acronyms for domain investment/monetisation purposes. However, Ms Fritsch later discovered it was another Government authority (Australian Hearing Services), not Defence, that had previously refused consent for Domain Syndicates Pty Ltd to use a protected name. Ms Fritsch accepts she should have further verified the relevant information at the time.

    (c) The period for which consent is sought. For this reason Ms Fritsch advised that instead of granting the authorisation for an “indefinite period”, Defence may simply state that the person may continue to use the word or acronym for the period of time that they provide the specified services or products or purposes for which the authorisation was provided.

    8. Ms Fritsch does not have access to Mr O’Meara’s original application, but understands it gave the impression the authorisation was to enable the entity “Australian Insurance and Finance” to provide corresponding insurance and finance services. Consistent with the explanatory statement above, Ministerial consent is ordinarily granted where a proposed use of otherwise prohibited words is “purely descriptive of the activities to be undertaken by the applicant.” In other words, an application for “AIF” by an entity named “Australian Insurance and Finance” to provide Australian insurance and finance services is very different to an application by a domain investor named “Domain Syndicates Pty Ltd” for the purpose of reselling the “AIF” domain name. We note the http://www.domainsydicates.com.au website explains that “Domain Syndicates is the holder of a large range of premium domain names”.[5]

    9. Ms Fritsch understands that Defence subsequently advised Mr O’Meara that it would not consent to the use of “AIF.com.au” by the applicant, Domain Syndicates Pty Ltd, having regard to its business as a domain investor and that the domain may have been registered for the purpose of resale.

    Domainer.com.au articles

    10. In light of the above matters, the articles on your website are extremely overblown, not to mention defamatory of Ms Fritsch.

    11. In short, Ms Fritsch’s role in this matter was limited to contacting Defence (at the auDA COO’s request) and providing relevant guidance on the application having regard to the requirements of the legislation, consistent with her role as an auDA employee and auDA’s usual practice. She was not, as your articles suggest, on some personal crusade against domain investors or to prevent Mr O’Meara from conducting business. Ms Fritsch is not “anti-domain investor”. To the contrary, Ms Fritsch authored an April 2019 Management Report on auDA policies which called for domain investors to be treated in the same way as other market participants, and recommended removing the prohibition on registering domains purely for the purpose of resale. Ms Fritsch also resigned from the Policy Review Panel in May 2018 before the Panel released its recommendations regarding domain monetisation.

    12. Your articles also incorrectly suggest that the issue with Mr O’Meara’s original application and subsequent approval was simply that it was “not addressed to the correct entity” and required only a “slight adjustment to be sorted out.” To the contrary, there was a fundamental difference in the business and nature of services represented by the applicant, being an essential consideration for the Minister in providing consent under the legislation. It was not merely an administrative matter.

    13. Otherwise, the general tenor of your articles is that Ms Fritsch went out of her way to deliberately mislead a government department in order to “strip a domain name from a successful and rule-abiding domain investor”, and in the process breached auDA’s Code of Conduct. This is similarly overblown and defamatory in a number of respects:

    (a) First, as explained above, Ms Fritsch was simply providing relevant information and guidance to a government department regarding the requirements of the legislation, which is entirely consistent with auDA’s role.

    (b) Secondly, although Ms Fritsch accepts that the information regarding the Minister’s previous refusal should have been verified, this was an innocent error. In any event, this information was not pertinent to Defence’s subsequent decision to refuse the application, which was based on the proposed use of the domain name.

    (c) Thirdly, and simply, Ms Fritsch did not breach auDA’s Code of Conduct, contrary to the prominent headline of your article.

    14. In addition to the above matters, Ms Fritsch understands that (unlike other Domainer articles) you have inserted extensive metadata into the articles the subject of this letter to ensure they rank highly on search engines, such as google and duckduckgo searches. LinkedIn also suspended Ms Fritsch’s LinkedIn account for safety reasons, given the email trolling which followed the publication of your articles. The articles continue to cause entirely unjustified damage to Ms Fritsch’s professional reputation.

    Next steps

    15. Ms Fritsch would prefer to resolve this matter with you quickly and sensibly. To that end, having regard to the matters in this letter, we request that you remove the articles by 4 pm on 16 March 2021.

    16. Ms Fritsch otherwise reserves her rights.

    Yours faithfully

    David Robbins

    KHQ Lawyers

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    • Avatar
      March 13, 2021 at 10:58 am
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      Welcome to Domainer, David!

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    • Neddy
      March 13, 2021 at 12:42 pm
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      Dear Mr Robbins,

      I appreciate that you have made your letter to Robert Kaay public.

      I am the person who made the original application to the Minister of Defence on behalf of Domain Syndicates Pty Ltd; and who subsequently had to take the Minister to the AAT to establish the truth of what exactly had transpired in this matter. I stand by what I wrote in the two articles referred to in this current article.

      The CEO of your client’s employer (auDA) fought tooth and nail to keep the full extent of the truth from being exposed publicly. This included the identity of the person who had first contacted Defence (your client). But that horse had already bolted.

      I appreciate that you are a lawyer who has taken instructions from a client, and as often happens, you may not yet be in full possession of all the facts. You illustrate this at (8) in your letter above.

      “Ms Fritsch does not have access to Mr O’Meara’s original application, but understands it gave the impression the authorisation was to enable the entity “Australian Insurance and Finance” to provide corresponding insurance and finance services.”

      This interpretation is simply incorrect, and to prove it, you can view the original application to The Minister of Defence here.

      Your client then made a false and misleading statement to their contact in Defence long after the approval was given.

      This caused a change in the decision (which took months to be notified of). When I ultimately found out the truth, I sought an apology and a correction from the auDA CEO. Neither was forthcoming.

      Request

      Could you please seek consent from your client to publish (in full) her email to the Army Brand Manager (Susie Leydon) dated 7th February 2020? As well as the subsequent emails between them. If you do so, this will go a long way to negating many of the points you currently raise.

      Conclusion

      auDA is a membership organisation, and our domain registrations help pay the wages. They also preach the mantra of transparency and accountability, yet some could reasonably argue that they don’t practise what they preach.

      If your client (presumably funded by her employer) does decide to proceed with defamation proceedings against Robert Kaay, please join me in such proceedings. We can well and truly satisfy “truth or justification” and “fair comment or honest opinion” as a defence. I have a raft of documents that can and will be used in a Court of Law.

      On the other hand, I think your client would be better to let “sleeping dogs lie”. She acknowledges that a mistake was made.

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    • Avatar
      March 13, 2021 at 12:52 pm
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      Who paid you for your time and letter
      ? They wasted their or should I say other people’s money.

      Did Caroline Fritsch pay you out of her own pocket or did the chaotic “not fit for purpose” “not for profit” auDA using .au registrant funds again wastefully?

      For transparency how much have you billed so far?

      Who exactly engaged you
      ?

      Are you billing to read and post here also?

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    • Scott.L
      March 13, 2021 at 3:12 pm
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      I guess the same logic applies to PMF.com.au (PMF) Permanent Milliatry Force.

      Interesting to note that PMF.com.au is not currently policy compliant and im almost certain the current registrant did not get ministerial approval for its use.

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    • Avatar
      March 13, 2021 at 4:12 pm
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      Reserves her rights to do what? … Hide behind some auDA harrssment type targeting of domain investors with secrecy and now lawyers to admit she seriously erred in her capacity and may have misled a few Government Departments?

      So David Lawyer will you be bringing the other AIF Business names and domain names to the Defence department’s attention or Caroline for auDA Policy delete and why not? Is Caroline just continuing her bias to target domainers and portfolio owners we can all guess yes.

      Bruce Tonkin if you are involved join in and come clean also as the now named auDA COO involved too.

      auDA 3.0 should have put in a new COO and unbiased auDA policy team. The problems obviously remain behind the scenes targeting domainers, portfolio owners, monetization and reselling names.

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    • Avatar
      March 14, 2021 at 7:15 am
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      David Robbins,

      Are you selectively misquoting to mislead readers here of the full facts and obvious losses and damages done to the rightful Registrant auDA confiscated the AIF.COM.AU name from?

      Who exactly has been paying you? auDA or Caroline Fritsch personally?

      If she has paid is auDA then paying her back in any way….?

      Are you being paid to read and post on here or are you doing it to improve your own knowledge and understanding from domain name industry experts?

      auDA Transparency and Accountability has not improved under a new auDA CEO and new auDA Board just spent more $millions in continued cover ups and ongoing threat tactics usually with lawyers or targeted victim portfolio owner auDA compliance team audits against people who stand up and speak out.

      The Government needs to do a further more serious open review of auD, the auDA Compliance team and call for public submissions.

      The auDA and major Registrar Phishing scams of .au domain name registrants recently show serious issues of auDA policy, WHOIS and technical vulnerabilities. This creates consumer risk, namespace instability and Australian National Infrastructure direct damage.

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    • Avatar
      March 14, 2021 at 1:04 pm
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      David,

      The auDA behaviour and decisions often detrimentally affects many. They incur loss of chance, loss of investments and in some cases possible borderline slandering, victimisation and targeting.

      It seems that some who remain at auDA are biased and will never change even when proven wrong time and time again including by the auDRP, Government or courts.

      The longer they remain the continuing damage and chaos they do the namespace and peoples confidence in auDA’s management of it.

      “Web agency not fit-for-purpose, government review finds”
      https://www.smh.com.au/technology/web-agency-not-fit-for-purpose-government-review-finds-20180417-p4za3u.html

      https://www.computerworld.com/article/3464643/govt-review-auda-needs-to-fix-its-problems-or-else.html
      “In the event that auDA fails to demonstrate progress in achieving the necessary reforms, I will instruct my Department to undertake a public expression of interest process in the future to identify other entities that could administer .au, consistent with the ToE,” Senator Fifield wrote.
      “In the event that auDA fails to demonstrate progress in achieving the necessary reforms, I will instruct my Department to undertake a public expression of interest process in the future to identify other entities that could administer .au, consistent with the ToE,” Fifield wrote.
      https://www.communications.gov.au/have-your-say/review-australias-au-domain-management

      In this AIF.com.au matter the party’s representative Ned seems to have posted relevant information and a request to you it would be good for you to address here as many people are reading these auDA issues which have been ongoing for some time and may have a much wider detrimental affect on others also.

      Will you be posting the requested information online he refers to quoted here below?

      “Ms Fritsch does not have access to Mr O’Meara’s original application, but understands it gave the impression the authorisation was to enable the entity “Australian Insurance and Finance” to provide corresponding insurance and finance services.”

      This interpretation is simply incorrect, and to prove it, you can view the original application to The Minister of Defence here.

      Your client then made a false and misleading statement to their contact in Defence long after the approval was given.

      This caused a change in the decision (which took months to be notified of). When I ultimately found out the truth, I sought an apology and a correction from the auDA CEO. Neither was forthcoming.

      Request

      Could you please seek consent from your client to publish (in full) her email to the Army Brand Manager (Susie Leydon) dated 7th February 2020? As well as the subsequent emails between them. If you do so, this will go a long way to negating many of the points you currently raise.”
      ______

      Some of your stated opinions seem to be at odds with reality, fact and are misleading to readers as to the full background of the AIF.com.au saga.

      The acronym “AIF” is used by many Australian entities in their business names, trademarks and Australian .au domain names.

      auDA seems to have targeted the previous legitimate registrant by referring to the business as one which just is a domainer or domain reseller. who might want to sell the AIF.com.au name so they should not be allowed to have it etc.

      This wrongly infers their rights are less than others and also highlights many ongoing concerns of bias inside auDA which has remained even after the past auDA 2.0 CEO and Board was removed.

      “auDA Management Rejects Wrongful Attempts to Prohibit Domain Name Investment in Australia”
      https://www.internetcommerce.org/auda-management-rejects-wrongful-attempts-to-prohibit-domain-name-investment-in-australia/
      https://www.internetcommerce.org/ica-recommendations-to-the-auda-board-reform-of-existing-policies-implementation-of-direct-registration/
      https://www.internetcommerce.org/wp-content/uploads/2019/04/ICA-Letter-re-Policy-Review-April-9-2019.pdf

      Background “Are auDA staff trying to influence the auDA PRP with crazy ideas?”-

      https://www.dntrade.com.au/threads/are-auda-staff-trying-to-influence-the-auda-prp-with-crazy-ideas.11856/
      ____________________
      Australian Insulation Foundation – Welcome to “AIF”
      http://www.aifwa.org.au/

      AIF ELECTRICAL https://www.aifelectrical.com.au/
      https://aiff.net.au/
      https://www.aifsconference2020.com.au/
      etc

      You would do well to read up a little more.

      “Registrar sues auDA for deleting domain name” https://www.internetcommerce.org/registrar_sues_auda_for_deleting_domain_name/

      “auDA’s wrong policy decisions overturned again”
      https://www.gadens.com/news-gadens-acts-domain-name-owner-inaugural-application-auda/
      https://www.smartcompany.com.au/technology/complaint-threatened-to-axe-stewart-media-website/
      “i spoke up against direct au and auda tried to take away my business”
      https://stewartmedia.com.au/i-spoke-up-against-direct-au-and-auda-tried-to-take-away-my-business/
      https://www.smartcompany.com.au/technology/seo/businesses-warned-fight-au-web-addresses-experts-warn-domain-changes-hurt-smes/

      “Websites confiscated: Businesses ‘losing everything’ as regulator cracks down on prohibited domains”
      https://www.smartcompany.com.au/technology/websites-confiscated-auda-prohibited-domains/

      “Generic Domain Name Owned for 22 Years Ripped Away”
      https://domainer.com.au/generic-domain-name-ripped-away-after-22-years/

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    • Avatar
      March 15, 2021 at 6:05 pm
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      Classic “Streisand Effect”. Well played. NOT.

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  • Avatar
    March 13, 2021 at 11:04 am
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    If what David Robbins (Caroline Fritsch’s Lawyer) has said is correct about owning “AIF” in his first 6 points above, I wonder what’s going to happen to these businesses very shortly?

    david robbins khq lawyer

    caroline fritsch auda

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  • Avatar
    March 13, 2021 at 3:32 pm
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    Word from inside sources is that Caroline Fritsch has put a lot of pressure on the CEO to defend her reputation. Apparently it is now a health and safety issue.

    I’ve read all the articles, and imo Ned was shafted by an over zealous employee who has now admitted to getting it wrong and stuffing things up. Why do they not simply apologise rather than doubling down?

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  • Avatar
    March 13, 2021 at 5:01 pm
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    he says Llinkedin suspended her account for safety reasons. haha yeah right

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  • Avatar
    March 13, 2021 at 5:04 pm
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    If auDA is paying the legal fees then it would have to be with the knowledge of the board of directors. Seems like deja vu to me, and I don’t recall that ending well for auDA.

    auDA is back to it’s old secretive ways. The difference is that the board is not accountable to the australian community only to itself and the overpaid nominations committee who enable the board in all it’s decisions.

    Time for another government review.

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    • Avatar
      March 13, 2021 at 5:35 pm
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      Over 200 State and Federal Government MPs personal name domain names have not met auDA policy for years under auDA Caroline Fritsch, the auDA ex CEO Blair Cameron Boardman and now CEO Rosemary Sinclair and auDA COO Bruce Tonkin have known it for years.

      Why target domain name investors, monetization pages content, paying legit .au portfolio owners and others who speak up and then not follow the same auDA crazy rules for these 200+ politicians from both Labor and Liberal?

      Here are a few .au domain name Registrations that are NOT auDA policy compliant and never have been at registration or their many years of paid renewals auDA has profited from when perhaps they shouldn’t have?

      ScottMorrison.com.au
      TonyBurke.com.au
      MichelleRowland.com.au
      PaulFletcher.com.au
      + 200 more

      Keep an eye on the WHOIS of each and magically will auDA help fix them all to be ok like it happened for Binge.com.au when a big company was involved auDA bent tge rules for it seems compared to the auDA often targeted domainer smaller businesses?

      Will auDA Policy Delete these MP Policy breaching .com.au names?

      auDA why don’t you audit all 500 plus State and Federal MPs personal name .com.au domains and show everyone you equally target them and apply the same rules?

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    • Neddy
      March 14, 2021 at 6:55 am
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      Ah yes Nobby, you and I have seen this happen all before. Story to follow soon on many of the points you raise.

      But as to the current “take-down letter”, for those not in the know, back in early August 2017, as the then publisher of Domainer, I received a Concerns Notice (8 pages in length) under Section 14 of the Defamation Act (2005) VIC. It was issued by Mills Oakley on behalf of their client Dr Michaella Richards (then a Director at auDA).

      For the record, David Goldstein of The Goldstein Report also received one.

      When I questioned the then CEO of auDA as to whether they were funding this, the reply was an emphatic no. However, that was semantics – as it turned out, they had given her a one off capped payment (I think it was $5000) to use towards any legal fees.

      Needless to say, we got some friendly and free legal advice from a highly regarded Melbourne based lawyer, and responded accordingly. The matter was mysteriously and suddenly dropped, and Dr Richards resigned from auDA shortly thereafter.

      I don’t like to be bullied – and I know Robert certainly doesn’t.

      N.B. The current letter from Mr Robbins on behalf of Caroline Fritsch is not a “Concerns Notice”.

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  • Avatar
    March 15, 2021 at 3:02 pm
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    Question for David Robbins,

    Is Ms Fritsch receiving auDA support in relation to this legal matter?

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    • Neddy
      March 16, 2021 at 9:50 am
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      I’m prepared to wager you won’t get an answer to that question Paul.

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