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)  It's also helpful to review FAQs published by the EWG (link)

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) 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), 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), 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.

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Steve DelBianco
Executive Director
NetChoice
+1.202.420.7482