ICANN, by lifting the price restriction, was likely “in” on this deal.
When a nonprofit does something to greatly enrich a former CEO, that’s likely self dealing and illegal in the IRS’ eyes. The CA attorney general should also take action (ICANN is CA based).
Please see my other comment on this thread. It is likely this “sale” could be considered illegal.
Here is the information for ICANN which can be used for the above form as well:
https://www.icann.org/en/system/files/files/fy18-irs-tax-for...
Remember that the founder of this PE firm was at ICANN, so this transaction is self-dealing on ICANN’s end as well.