Holly's outline comes closest to what I think is supportable from an ALAC that is thinking globally. On the balance of reason, fact and evidence, I would advise support for Holly's statement.

The winning hand here is how perfectly nuanced one can be. So don't forget it is not a set piece.  Because when the usual regimes of evasions and sophistry - like extant Handling WHOIS Conflict With National Laws characterisations - are developed around it even crocodiles will be happy.

[BTW, the above is one reason why a single ICANN WHOIS policy is neither strategically or operationally ideal.]

-Carlton


==============================
Carlton A Samuels
Mobile: 876-818-1799
Strategy, Planning, Governance, Assessment & Turnaround

=============================

On Tue, Jan 30, 2018 at 3:40 PM, Holly Raiche <h.raiche@internode.on.net> wrote:
Thanks Alan

And because we did not manage to agree on a model, I have also submitted a statement (attached) that largely repeats what I put on the list.  And for those who supported other models, I would urge you to also make submissions on the models (I note both Christopher and Seun supported Model 3 - now you need to say so directly to ICANN Org 

Holly

 


On 31 Jan 2018, at 5:33 am, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:

Regarding our deliberations on GDPR models - https://community.icann.org/x/HQa8B

The message below says that they are not formally extending the deadline, but will consider new input - presuming it comes in relatively quickly.

At this point, as far as I can see, I have been the only At-Large person to submit a personal comment, and no RALO or At-Large comments have been submitted.

Alan

From: GDPR Questions <gdpr-questions@icann.org>
To: Evin Erdogdu <evin.erdogdu@icann.org>
CC: Alan Greenberg <alan.greenberg@mcgill.ca>, Ariel Liang
         <ariel.liang@icann.org>
Subject: Re: TODAY/URGENT: At-Large Extension Request for GDPR Model Comments
Date: Tue, 30 Jan 2018 18:00:07 +0000
user-agent: Microsoft-MacOutlook/f.28.0.171108

Thank you for the notes requesting an extension. As you may be aware, we are receiving significant input from a wide range of stakeholders over the past days, a full list can be found at: https://www.icann.org/resources/pages/gdpr-legal-analysis-2017-11-17-en and we are updating this continuously.
 
Unfortunately, we are unable to provide an extension. We would encourage you to provide any additional input as soon as possible, and would welcome to hear from you how you’d like to proceed as feedback is important.
 
 
From: Evin Erdogdu <evin.erdogdu@icann.org>
Date: Monday, January 29, 2018 at 21:31
To: GDPR Questions <gdpr-questions@icann.org>, "gdpr@icann.org" <gdpr@icann.org>
Cc: Alan Greenberg <alan.greenberg@mcgill.ca>, Ariel Liang <ariel.liang@icann.org>
Subject: Re: TODAY/URGENT: At-Large Extension Request for GDPR Model Comments
 
Dear GDPR Staff,
 
Has the comment period been formally extended? Please advise.
 
Kind Regards,
Evin
 
From: GDPR Questions <gdpr-questions@icann.org>
Date: Saturday, January 27, 2018 at 1:45 AM
To: Evin Erdogdu <evin.erdogdu@icann.org>, "gdpr@icann.org" <gdpr@icann.org>
Cc: Alan Greenberg <alan.greenberg@mcgill.ca>, Ariel Liang <ariel.liang@icann.org>
Subject: Re: TODAY/URGENT: At-Large Extension Request for GDPR Model Comments
 
Dear Alan, we acknowledge receipt of your request and it will be published.
 
 
From: Evin Erdogdu <evin.erdogdu@icann.org>
Date: Friday, January 26, 2018 at 15:15
To: "gdpr@icann.org" <gdpr@icann.org>
Cc: Alan Greenberg <alan.greenberg@mcgill.ca>, Ariel Liang <ariel.liang@icann.org>
Subject: TODAY/URGENT: At-Large Extension Request for GDPR Model Comments
 
Dear Staff,

In light of the importance of the GDPR issue and the ongoing discussion within At-Large and elsewhere in ICANN, Alan Greenberg, ALAC Chair requests an extension of no less than 10 days for submission of comments.

Please confirm this extension request has been received.
 
Kind Regards,
 
Evin Ashley ErdoÄŸdu
AC/SO and Policy Support
Internet Corporation for Assigned Names and Numbers (ICANN)
 
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