From @rvagg in #fil-implementers (thread)

109 needs a basic extension of DDO to test it [in lotus]... and there's already DDO stuff in lotus to extend so it shouldn't be too hard.

From @rvagg in #13304 (comment)

DDO tests can go in direct_data_onboard_test.go or direct_data_onboard_verified_test.go, just extending what we have there with some fevm-copypasta code to get a contract in.

Related Items

https://github.com/filecoin-project/FIPs/blob/master/FIPS/fip-0109.md
filecoin-project/builtin-actors#1689
filecoin-project/FIPs#1188 (where can point to this work)