As a follow-up to Thursday's BC call, here's a new draft for member review. First thing I did was re-read the EWG report on which we are commenting. (link<http://www.icann.org/en/groups/other/gtld-directory-services/initial-report-...>) It's also helpful to review FAQs published by the EWG (link<http://www.icann.org/en/groups/other/gtld-directory-services/faqs>) Second thing I did was review prior BC positions on this, starting with our Jul-2011 "Response to WHOIS Policy Review Team Discussion Paper" (link<http://www.bizconst.org/Positions-Statements/BC_on_WHOIS_Review_Questions.pd...>) where the BC said: "ICANN should also consider mechanisms to create and maintain a centralized WHOIS database." Also see Jun-2012 BC comment on WHOIS Affirmation Review (link<http://www.bizconst.org/Positions-Statements/BC%20on%20WHOIS%20RT%20Final%20...>), where we endorsed privacy/proxy obligations: • Adopting agreed standardized relay and reveal processes and timeframes • Conducting periodic due diligence checks on customer contact information; • Providing clear and unambiguous guidance on the rights and responsibilities of registered name holders, and how those should be managed in the Privacy / Proxy environment. And see our May-2013 comments on the new RAA (link<http://www.bizconst.org/Positions-Statements/BC%20Comment%20on%20final%20201...>), where we proposed Relay and Reveal obligations and timelines for privacy/proxy services. Then I started with our 9-Aug draft comments and added discussion from 29-Aug BC member call. Attached is my 2-Sep draft, plus a redline comparing with the previous draft distributed (9-Aug). Please REPLY ALL with objections or comments before Thursday 5-Sep so we can meet the EWG deadline of 6-Sep. Looking forward to an informed and respectful discussions, so we can get our thoughts to the EWG while they are working on their final report for October publication. -- Steve DelBianco Executive Director NetChoice http://www.NetChoice.org and http://blog.netchoice.org +1.202.420.7482