This paper assesses the relationship between public participation and accountability in ICANN. It explains how ICANN has responded to accountability concerns by creating new opportunities for public comment, review, and participation. Is public participation an adequate means of making this global Internet governance organization accountable to the public? ICANN is fundamentally a private corporation. Private corporations are held accountable in three ways: 1) directly through their membership or shareholders, 2) through competition, which gives the public the opportunity to avoid their products or services, and 3) through external regulation or supervision by judicial or public authorities. None of these forms of accountability apply to ICANN. Instead, the public is given a wide range of opportunities to participate in ICANN’s processes and to voice their opinions. This paper questions whether participation is an adequate substitute for accountability. It analyzes three distinct reforms in ICANN’s history to show how participation can displace accountability rather than improve it.