Are you asking for my views on 3.18 of the RAA? I think I am on record on that one. I have no problem with the RAA requiring registrars to get registrants to agree to comply with all applicable laws, including trademark and consumer protection laws. I have no problem with the RAA requiring registrars to get registrants to agree to abide by the outcome of a UDRP or a rapid suspension process. I believe that requiring registrars to maintain an abuse point of contact and to respond to reports appropriately is reasonably within the picket fence. I don¹t believe that registrars can reasonably or appropriately be required to make legal determinations about whether some registrant behavior constitutes a violation of law in they myriad jurisdictions in which they do business. Although I can conceive of ways that ICANN might attempt to enforce 3.18 that are inconsistent with the intent of the provision and exceed the scope of ICANN¹s Mission, I am not aware that ICANN has engaged in any effort to do so. At the same time, I do believe registries and registrars should be free to establish the terms and conditions under which they will do business with registrants, including the right to not accept and/or to terminate registrations that violate their terms and conditions. J. Beckwith Burr Neustar, Inc. / Deputy General Counsel & Chief Privacy Officer 1775 Pennsylvania Avenue NW, Washington D.C. 20006 Office: +1.202.533.2932 Mobile: +1.202.352.6367 / neustar.biz <http://www.neustar.biz> On 1/20/16, 8:50 AM, "Mueller, Milton L" <milton@gatech.edu> wrote:
Becky: I noticed that you did not respond to this point:
If a registry ends up running ANY tld in a way that facilitates or contributes to trademark violations and fraud, there are all kinds of existing regulations and laws to respond to that. You don't need to use registry contracts to enforce sectoral regulations on a tld string.
Care to give it a try?
--MM