Draft Letter To NotaryCam Regarding Foreign Signers, Virginia Identity Methods, Pricing, Recipient Routing, And David Kressel History

# Draft Letter To NotaryCam Regarding Foreign Signers, Virginia Identity Methods, Pricing, Recipient Routing, And David Kressel History

Status: working draft  
Date drafted: 2026-05-17  
Prepared for: Greg Lirette / Notary Geek / GoodWare LLC  
Purpose: deep NotaryCam outreach letter; not yet public copy

## Draft Letter

Greg Lirette  
GoodWare LLC / Notary Geek  
Clearwater, Florida  
G@notary.cx

May 17, 2026

NotaryCam, Inc.

Re: Request for clarification regarding foreign-signer workflows, Virginia identity methods, no-SSN pricing, Florida RON filing history, and recipient-directed NotaryCam requirements

To NotaryCam:

I am writing because NotaryCam is different from a tools-only RON technology vendor. NotaryCam has operated as a direct-to-consumer and recipient-recognized online notarization service. Customers, foreign signers, title companies, mailbox providers, underwriters, agencies, and other recipients have treated NotaryCam as a destination, not merely as background software selected by an independent notary.

That makes the legal identity-method question especially important.

When a customer is sent to NotaryCam, pays NotaryCam, uses a NotaryCam notary network, or pays a foreign-signer, non-U.S.-passport, or no-SSN surcharge, the customer is not merely buying a generic video tool. The customer is relying on NotaryCam's public-facing service representation that the workflow is suitable for the document route being sold.

I am asking NotaryCam to clarify the state-law identity methods, transaction records, and public representations connected to those workflows.

## 1. Foreign-signer, non-U.S.-passport, and no-SSN workflows were not theoretical.

Notary Geek has preserved public NotaryCam pricing-page text showing that international, non-U.S.-passport, and no-SSN workflows were marketed and monetized.

The preserved pricing text includes:

- real-estate closing pricing using the NotaryCam notary network;
- a listed international surcharge;
- a listed signer-without-SSN add-on;
- non-real-estate "Notarize Now" pricing;
- "145 countries";
- "24/7 notary network";
- a listed international signer price;
- compliance-oriented public language elsewhere in the same environment.

I am not saying that public pricing language alone proves a legal violation. It does not.

But it does prove that the foreign-signer / non-U.S.-passport / no-SSN issue was not abstract. NotaryCam publicly offered and priced workflows for international signers and signers without SSN. In Greg Lirette's view, the sharper concern is that NotaryCam charged extra for the non-U.S.-passport or foreign-signer lane while using Virginia notaries in a way that, if the signer was unknown and no lawful Virginia identity method existed, NotaryCam had no legal authority to support through ordinary KBA, selfie, liveness, or face-match workflows.

That makes the underlying question unavoidable:

> For each state and date, what exact legal identity method did NotaryCam expect the notary to rely on for those signers?

## 2. Virginia is the central identity-method problem.

Virginia's older remote/electronic-notary identity framework has been widely misunderstood.

The word "biometrics" has often been treated in the RON industry as if it means ordinary selfie capture, liveness detection, or face matching against an ID photo. That is not the careful reading of Virginia's older statutory language. The key Virginia phrase involved a valid digital certificate accessed by biometric data, or a PIV/PIV-I-style credential. That is a signer-side certificate or credential lane, not a generic platform "biometrics passed" label.

Virginia added knowledge-based authentication as an express listed method effective July 1, 2024. That change matters, but it does not retroactively prove that pre-July-1-2024 Virginia unknown-signer sessions using KBA were compliant. It also does not make current no-KBA foreign-passport plus selfie workflows into Virginia's certificate/PIV biometric lane.

This issue is even simpler when reduced to the claim NotaryCam actually appears to make in the market. If NotaryCam is only claiming ordinary commercial identity proofing, credential analysis, selfie capture, liveness detection, passport-to-face comparison, or an identity-vendor result, then NotaryCam is not claiming Virginia's statutory certificate/PIV biometric method. If NotaryCam claims it did support that Virginia method, the answer should identify the signer-side certificate or PIV/PIV-I evidence, not a platform face-match result.

Notary Geek's position is direct: there is no known ordinary Remote Online Notarization service provider that a Virginia electronic notary could use, through a public or ordinary notary workflow, to satisfy Virginia's signer-side valid-digital-certificate / PIV biometric lane. It is possible that specialized government, defense, enterprise, or private-sector systems exist somewhere. That possibility does not help an ordinary NotaryCam customer, foreign signer, no-SSN signer, title file, mailbox customer, or apostille-bound document unless NotaryCam can show that the specific transaction actually used that lane.

For NotaryCam, the questions are direct:

1. Did NotaryCam route unknown on-demand signers through Virginia electronic notaries before July 1, 2024?

2. Did NotaryCam route foreign signers, non-U.S.-passport signers, or signers without SSN through Virginia electronic notaries before July 1, 2024?

3. If yes, what statutory identity method did NotaryCam expect the Virginia notary to use?

4. Did NotaryCam rely on KBA for unknown Virginia signers before July 1, 2024?

5. Did NotaryCam rely on ordinary selfie/liveness/face-match biometrics for Virginia signers before or after July 1, 2024?

6. Did NotaryCam ever support the Virginia signer-side valid-digital-certificate / PIV biometric lane for ordinary unknown or foreign signers?

7. If yes, what signer certificate, issuer, trust path, biometric access event, and transaction audit record proves it?

8. If no, did NotaryCam disclose to customers, notaries, title companies, mailbox providers, or recipients that Virginia's certificate/PIV biometric lane was not being used?

9. Did NotaryCam ever charge an international, foreign-signer, non-U.S.-passport, or no-SSN upcharge for a session routed to a Virginia notary where the signer was unknown to the notary and the session did not use a lawful Virginia identity method?

10. If NotaryCam's position is that those sessions were lawful, identify the exact statutory method and retained record that proves it.

## 3. The David Kressel record matters.

Greg Lirette raised this issue directly with David Kressel in a retained LinkedIn exchange.

The reason that matters is not simply that Kressel was a random NotaryCam contact. Public profile information supplied by Greg identifies Kressel as former COO of NotaryCam from November 2014 to May 2023, with title/escrow, eSigning, eNotary, identity-proofing, financial, startup, and commercialization background. A Florida Department of State RON service-provider record supplied by Greg shows the NOTARYCAM, INC. 2022 filing was signed off by DAVID KRESSEL, filing date February 25, 2022.

Greg has referred to Kressel as the "money guy" in the sense of startup funding, business positioning, and commercialization. That matters because this is not only a notary-operations issue. It is also a question of how the service was funded, positioned, sold, priced, and routed through recipient ecosystems.

In the retained LinkedIn exchange, Greg raised the Virginia smart-card / PKI / digital-certificate interpretation. Kressel did not identify a concrete notary-company implementation of the Virginia signer-held digital-certificate path. He indicated that he did not think anyone was using that option and suggested contacting the Virginia Secretary of the Commonwealth. Kressel mapped the biometric wording to validation of an ID issued as part of a trust relationship, such as a driver license or passport. Notary Geek's position is that this mapping is wrong because Virginia's text and related technical materials point to a signer-held digital certificate / PIV-style identity method, not ordinary DL/passport validation or platform selfie biometrics.

Notary Geek also treats Kressel's phrase "the people reading the statutes" as important. The people reading the Virginia notary statute should be the commissioned Virginia notaries performing the act. A market structure where the NNA, a platform, title, an underwriter, or a vendor effectively reads the law for the notary is not a substitute for the notary identifying the statutory satisfactory-evidence method used in the transaction.

I am not treating that exchange as a corporate admission by NotaryCam. I am treating it as notice and context: Greg raised the technical/legal issue with a former NotaryCam executive tied to NotaryCam's business and Florida filing history before the issue went wide publicly. The response did not identify a NotaryCam implementation of the Virginia certificate/PIV biometric route.

That makes NotaryCam's formal answer important.

## 4. Direct-to-consumer routing creates reliance.

NotaryCam has been used in workflows where the customer is not choosing among many legal theories. The customer may be told by a mailbox provider, international service, agency, title participant, employer, platform, or recipient that NotaryCam is required or preferred.

That creates a reliance chain:

- recipient or provider tells the customer to use NotaryCam;
- customer pays NotaryCam or follows NotaryCam routing;
- NotaryCam routes to a notary state and identity workflow;
- the notary completes the act;
- the customer uses the document for a mailbox, company, title, apostille, agency, bank, estate, real-estate, or international purpose.

If the state-law identity method is wrong, the harm does not stay inside the platform. It moves downstream into real documents and real relying parties.

That is especially serious for foreign signers, non-U.S.-passport signers, and no-SSN signers because they are exactly the customers most likely to be routed away from ordinary KBA workflows while still being charged for the difficulty of the identity problem.

## 5. Florida filing history and secure-repository context should be clarified.

Greg has supplied a Florida Department of State RON service-provider record showing:

- Service Provider Name: NOTARYCAM, INC.
- 2022 filing signed off by: DAVID KRESSEL
- Filing Date: 2/25/2022
- No secure repository entry visible in the supplied text.

That record does not prove every NotaryCam transaction was compliant. It also does not prove noncompliance. It is a filing record and context point. Because the Florida RON service-provider filing is a self-certification posture, the signature/sign-off matters as represented-compliance evidence: the filer is representing to the Florida Department of State that the provider's technology, processes, services, software, data storage, or related services satisfy Florida online-notary law and rules.

Please clarify:

- whether NotaryCam filed annually as a Florida RON service provider for each relevant period;
- what secure repository or repositories retained audio-video recordings for Florida online notarizations;
- whether any repository duty was delegated under Florida law;
- what NotaryCam represented to Florida, customers, title companies, notaries, or recipients about its Florida compliance;
- whether NotaryCam treated Florida filing as proof of full workflow compliance or only as self-certification and required-information filing.

## 6. Requested action.

I am asking NotaryCam to provide a substantive answer to the following:

1. Identify every state NotaryCam used for foreign-signer, non-U.S.-passport, and no-SSN workflows during the relevant period.

2. Identify whether Virginia notaries were used for foreign-signer, non-U.S.-passport, or no-SSN workflows before July 1, 2024.

3. Identify the statutory identity method used for unknown Virginia signers before July 1, 2024.

4. Identify whether NotaryCam used KBA for Virginia unknown signers before July 1, 2024.

5. Identify whether NotaryCam used ordinary selfie/liveness/face-match biometrics as a claimed Virginia identity method.

6. Identify whether NotaryCam ever supported signer-held X.509, PIV, PIV-I, CAC, TWIC, or comparable signer-side certificates for Virginia identity proofing.

7. Identify what records NotaryCam retained showing the identity method used in each transaction.

8. Identify whether notaries were instructed that they, not NotaryCam, were responsible for determining whether the identity method satisfied their state law.

9. Identify what disclosures, if any, were given to foreign signers, no-SSN signers, title companies, mailbox providers, agencies, or recipients about the notary state and identity method.

10. Identify all international, foreign-signer, non-U.S.-passport, or no-SSN upcharges collected for sessions routed to Virginia notaries, grouped by date range, signer identity method, and notary identity-method record.

11. Identify whether any public pricing, workflow, help-center, recipient, or compliance pages need correction.

I am not asking for a customer-support answer. This needs review by someone responsible for legal, compliance, product, notary-network operations, records retention, and public representations.

Please preserve this correspondence and route it to the appropriate teams.

Respectfully,

Greg Lirette  
GoodWare LLC / Notary Geek  
G@notary.cx

## Short-Link Source Appendix

Primary source packet for this letter:

https://notary.cx/notarycam-letter

NotaryCam pricing / foreign-signer source packet:

https://notary.cx/notarycam-pricing

David Kressel / NotaryCam context packet:

https://notary.cx/kressel

Virginia Code section 47.1-2:

https://notary.cx/va-471-2

Notary Geek Virginia biometrics correction:

https://notary.cx/va-bio

Notary Geek Virginia KBA investigation:

https://notary.cx/va-kba

Florida RON service-provider record packet:

https://notary.cx/fl-ron-records

USPS / CMRA / Form 1583 source packet:

https://notary.cx/usps-1583

Underlying public source URLs and preserved evidence files are maintained by Notary Geek and can be provided in full.