April 2015 - Ccwg-accountability4

CCWG Stress Tests v10.3 as of Wed 29-Apr
by Steve DelBianco April 29, 2015

April 29, 2015

Thanks to the Stress Test team for discussion on today’s call. As promised, here is v10.3 of Applying Stress Tests. I made the in-line edits we covered on the call. And I added two placeholder paragraphs for your consideration: [placeholder for Do-It-Yourself paragraph: Public comment participants may conceive of other contingencies and risks beyond the 26 stress tests identified in this section. In that case, we encourage commenters to apply their own stress test analysis. To do so, a commenter can examine ICANN’s present accountability mechanisms to determine whether they adequately address the contingency. Then, the commenter can examine the proposed accountability enhancements in this document, and assess whether they give the community adequate means to challenge board decisions and to hold the board accountable for its actions. For example, the stress test team evaluated contingencies that could generally be described as external events (cyber attack, financial crisis, etc.). We discovered that while some risk mitigation was possible, it became clear that no accountability framework could entirely eliminate the risk of such events nor thoroughly alleviate their impact. Instead, it was critical to explore the ability of the community to hold ICANN board and management accountable for their preparation and reaction to the external events. The proposed accountability measures do provide adequate means to do so. [placeholder for management summary paragraph requested by Mathieu: The stress test exercise demonstrates that WS1 recommendations do enhance the community’s ability to hold ICANN board and management accountable, relative to present accountability measures. It is also clear that the CWG proposals are complementary to CCWG measures. One stress test regarding appeals of ccTLD revocations and assignments (ST 21) has not been adequately addressed in either the CWG or CCWG proposals, awaing policy development from the ccNSO. We understand that staff will attempt to include v10.3 in the draft to be circulated for the full CCWG call at 5:00 UTC on Thursday. From: Steve DelBianco Date: Tuesday, April 28, 2015 at 10:26 PM To: "ccwg-accountability4(a)icann.org<mailto:ccwg-accountability4@icann.org>" Cc: Cheryl Langdon-Orr, ACCT-Staff, Mathieu Weill, Thomas Rickert, León Felipe Sánchez Ambía Subject: CCWG Stress Tests v10.2 for discussion on Wed 29-Apr at 11:00 UTC To: Stress Test Work party Over the weekend, we amended our 'Applying Stress Tests’ section to reflect the latest CWG proposal and our CCWG discussions last week. (see attached v10.2) In two places I've noted text in RED requiring your insights. While I know we are enabling challenge to board decisions, I don't see where are we recommending any proscriptive measure preventing ICANN from going beyond its limited technical mission. If I have that right, we should remove the red text on 2 Stress Tests: Another proposed measure is to amend ICANN bylaws to prevent the organization from expanding scope beyond what is needed for SSR in DNS operations and to meet mission and core values of ICANN. Also, co-chair Mathieu Weill added some edit suggestions (in blue underline). Mathieu also suggested we develop a sort of "management summary for stress tests". Reading the document overall, he observes that: - the stress tests demonstrate that our WS1 recommendations do increase Icann's accountability significantly, providing adequate mitigation measures in situations where that was not the case without these recommendations - we can confirm that some of the CWG proposals are providing a useful complement to our own measures. - our accountability measures do not transform Icann into a body that would be "above the laws", and that's a good sign. - there is one stress test we do not cover, pending ccTLD adequate process, about delegation and revocations. ICANN Staff suggested we add a brief guide for readers who come up with their own risks/contingencies/scenarios. Adam Peake suggested we add a ‘Do-It-Yourself’ section explaining how anyone can use our method to apply their own stress test to the existing and proposed accountability measures. Best, Steve — Steve DelBianco Executive Director NetChoice http://www.NetChoice.org<http://www.netchoice.org/> and http://blog.netchoice.org<http://blog.netchoice.org/> +1.703.615.6206

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CCWG Stress Tests v10.2 for discussion on Wed 29-Apr at 11:00 UTC
by Steve DelBianco April 29, 2015

April 29, 2015

To: Stress Test Work party Over the weekend, we amended our 'Applying Stress Tests’ section to reflect the latest CWG proposal and our CCWG discussions last week. (see attached v10.2) In two places I've noted text in RED requiring your insights. While I know we are enabling challenge to board decisions, I don't see where are we recommending any proscriptive measure preventing ICANN from going beyond its limited technical mission. If I have that right, we should remove the red text on 2 Stress Tests: Another proposed measure is to amend ICANN bylaws to prevent the organization from expanding scope beyond what is needed for SSR in DNS operations and to meet mission and core values of ICANN. Also, co-chair Mathieu Weill added some edit suggestions (in blue underline). Mathieu also suggested we develop a sort of "management summary for stress tests". Reading the document overall, he observes that: - the stress tests demonstrate that our WS1 recommendations do increase Icann's accountability significantly, providing adequate mitigation measures in situations where that was not the case without these recommendations - we can confirm that some of the CWG proposals are providing a useful complement to our own measures. - our accountability measures do not transform Icann into a body that would be "above the laws", and that's a good sign. - there is one stress test we do not cover, pending ccTLD adequate process, about delegation and revocations. ICANN Staff suggested we add a brief guide for readers who come up with their own risks/contingencies/scenarios. Adam Peake suggested we add a ‘Do-It-Yourself’ section explaining how anyone can use our method to apply their own stress test to the existing and proposed accountability measures. Best, Steve — Steve DelBianco Executive Director NetChoice http://www.NetChoice.org<http://www.netchoice.org/> and http://blog.netchoice.org<http://blog.netchoice.org/> +1.703.615.6206

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v10.1 of Applying Stress Tests, to meet the draft report "freeze" deadline
by Steve DelBianco April 21, 2015

April 21, 2015

To meet the need for tonight's document ‘freeze’, Cheryl and I quickly generated v10.1 (attached) We added more explanatory overview to page 1. We removed the previously struck-thru measure describing a general community veto of any decision, since that is not being proposed. We updated ST 21 to refer to GAC principles and Framework of Interpretations Mathieu’s suggested security measures in ST 1&2 and ST 11 were not taken up in Work Stream 1, so we noted these for Work Stream 2. We corrected measures where we assumed the community could force implementation of consensus or prior AoC recommendations. Now it reads: "Another measure would allow an ATRT to recommend ICANN implement a recommendation of a prior AoC Review” and/or "A proposed bylaws change would require ICANN board to respond to formal advice from advisory committees such as SSAC and RSSAC." Made several other small edits to reflect what we know about the snapshot of CWG measures coming our way. We will likely have to revisit this after we see which proposed measures from CCWG and CWG will be published for comment. —Steve and Cheryl

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Re: [ST-WP] [CCWG-ACCT] Fwd: [CCWG-Advisors] jan comments on 17 april ccwg materials
by Rudolph Daniel April 21, 2015

April 21, 2015

Of note, Jan's comments are very valuable; the one which sticks out in my mind would be; "How does one ensure that the community empowerment mechanism does not become a vehicle for capture of ICANN by insider activists?" RD On Apr 20, 2015 6:02 AM, "Mathieu Weill" <mathieu.weill(a)afnic.fr> wrote: > Dear Colleagues, > > Please find below a contribution on our draft public comment report by Jan > Aart Scholte, in his capacity as one of our Advisors. > > Best regards, > Mathieu > > > -------- Message transféré -------- Sujet : [CCWG-Advisors] jan comments > on 17 april ccwg materials Date : Mon, 20 Apr 2015 07:19:58 +0000 De : Jan > Aart Scholte <jan.scholte(a)globalstudies.gu.se> > <jan.scholte(a)globalstudies.gu.se> Pour : CCWG-Advisors > <ccwg-advisors(a)icann.org> <ccwg-advisors(a)icann.org>, > jordan(a)internetnz.net.nz <jordan(a)internetnz.net.nz> > <jordan(a)internetnz.net.nz> > > Hello All > > > > Great to see that CCWG continues to make impressive headway after the > productive Istanbul meeting. Many thanks, Adam, for your thorough briefing > accompanying the documents circulated on Friday. My read of the materials > prompts the following thoughts, mainly concerning the community empowerment > mechanism: > > > > (1) The community empowerment mechanism increasingly looks to be based on > SOs and ACs. A key question of course remains with what distribution of > seats, and also whether any other body such as GAC or SSAC would have a > voting representation. > > > > (2) Would any adjustments in the AC and SO constructions be advisable at > this juncture, concurrent with the IANA transition, in order that 'the > Community' as institutionalised in the empowerment mechanism aligns > sufficiently closely with the present actual constellation of ICANN > stakeholders in the world at large? > > > > (3) How (and how readily) could the the formula which constitutes 'the > Community' in the empowerment mechanism be adjusted in future, as and when > the prevailing arrangement is found inadequately to reflect the > constellation of ICANN stakeholders at that future time? Consider how > difficult it has been to adjust membership of the UN Security Council and > the Boards of the Bretton Woods institutions, which remain largely frozen > in the world of 1945. The world of 2045 is likely to be quite different > from that of 2015 - will ICANN's constitution allow it readily to change > with the times? > > > > (4) Related to (3), could overly high supermajorities have unwanted > consequences of excessive constitutional conservatism? To be sure, too low > a threshold could invite constitutional instability, but too high a > threshold could invite institutional ossification. For example, > constitutional reform of the International Monetary Fund has been so > difficult in good part because an 85% vote is needed to alter the Articles > of Agreement, which has effectively entrenched a US Government veto. > > > > (5) Then there is that ever-present thorn of the accountability of those > who hold ICANN to account. How will participants in the empowerment > mechanism be held accountable to wider stakeholder circles, both within > ICANN (i.e. the ACs and SOs) *and beyond*? Legislators in democratic > nation-states are subject to election by the general population, but > delegates in the ICANN 'parliament' would only be elected by ACs and SOs, > whose connections to wider constituencies - and that so-called 'global > public interest' - can be quite thin? How does one ensure that the > community empowerment mechanism does not become a vehicle for capture of > ICANN by insider activists? > > > > Happy for this note to be made available to all CCWG if thought suitable. > Not sure about the protocols of advisors' communications. > > > > Greetings > > > > Jan > > > > > > _______________________________________________ > Accountability-Cross-Community mailing list > Accountability-Cross-Community(a)icann.org > https://mm.icann.org/mailman/listinfo/accountability-cross-community > >

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Legal advice request for clarification
by León Felipe Sánchez Ambía April 15, 2015

April 15, 2015

Dear Cheryl and Steve (ladies first, of course), We have received a request from staff to ask questions to the external legal advisors regarding some of the work of the stress test work party. Staff's comment was: "The stress-test work party is asking for external legal advice on mechanisms/community powers to 'remedy' Board inaction. Specifically whether, for example, if consensus advice from an AC is not acted on by the Board might this 'trigger' a mechanism? ST-WP particularly asks if the external legal advisory could review Stress test 17, and provided an MP3 clip of the relevant part of discussions of their last call, and supporting email from Jonathan Zuck." If staff's comments are a fair reflection of your request, could you formulate these into questions we can put to lawyers? Some suggested wording for the questions could be along “Considering the different mechanisms that have already been analyzed: Which would be the requisites to trigger community action against Board inaction? Do this requisites or situations need to be specified in some document i.e. bylaws?” I would welcome your feedback on this suggested wording. Would you also like us to forward the document "Applying Stress Tests [Draft v9]" https://community.icann.org/display/acctcrosscomm/ST-WP+Draft+Documents <https://community.icann.org/display/acctcrosscomm/ST-WP+Draft+Documents> to the laywers to have read in anticipation of future questions from the ST-WP? Best regards, León

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Re: [ST-WP] Spurring Board Action
by Steve DelBianco April 8, 2015

April 8, 2015

Thanks, Jonathan. Per our discussion today’s stress test WP call, we want to inform the rest of CCWG about this. Here’s a draft for your consideration: When ST-WP applies the stress tests to proposed mechanisms, we look at all proposed measures that are under active consideration in the CCWG. (Those are the measures cited in the right column of each stress test). When the CCWG and CWG package their proposals for public comment, the ST-WP can then re-apply the stress tests to what is actually proposed. Until then, the ST-WP is monitoring discussions in WP1 and WP2 and wanted to flag two proposed measures that have implications for stress testing. First, we note that the ‘Community Veto’ measure first proposed in Singapore seems not to be under active consideration in WP1, and is unlikely to make the cut for our first public comment document. As initially proposed, a community veto would enable a supermajority of the community representatives to veto a board decision, putting it back in the hands of the board. At the Sunday Istanbul meeting, a sub-team proposed limiting the community veto only to a list of specified board decisions. Further discussion revealed reservations about allowing community veto to block decisions of the board without citing standards or principles, and attention turned to enhancing other community challenge powers, such as Reconsideration and IRP. In our latest draft of Applying Stress Tests, we applied a strike-thru to the community veto mechanism in the 8 stress tests that had cited the measure. On today’s call, we concluded that the absence of a community veto would not in itself flip any stress tests from ‘Adequate’ to ‘Inadequate’, since the reconsideration and IRP measures are available to the community. So we are alerting the CCWG to this situation, although we do not believe stress testing reveals that community veto must be further developed as long as other challenge mechanisms are available. Second, we note that 6 stress tests anticipated another community power that may also fail to make the cut for first public comment. As explained in the email below from Jonathan Zuck, a proposal from the Frankfurt meeting would allow the community to force ICANN to implement a previously-approved Review Team Recommendation or consensus policy. Another suggested power would allow the community to force ICANN to respond to formal advice from an Advisory Committee (SSAC, ALAC, GAC, RSSAC). We note that several stress tests would likely flip from ’Adequate’ to ‘Inadequate’ if the community lacked any new powers to force ICANN to consider and respond to formal advice from an Advisory Committee. It’s possible that WP1 could address this concern by developing a power for the community to force ICANN board to acknowledge and respond to AC advice, since that board response could trigger community challenge mechanisms such as Reconsideration or IRP. This possibility requires some advice from legal experts, as described in Jonathan’s note below. In conclusion, we believe that CCWG WP1 could adopt the ATRT2 recommendation for a bylaws change along these lines: 9.1. ICANN Bylaws Article XI should be amended to include the following language to mandate Board Response to Advisory Committee Formal Advice: The ICANN Board will respond in a timely manner to formal advice from all Advisory Committees, explaining what action it took and the rationale for doing so. — Steve DelBianco Executive Director NetChoice http://www.NetChoice.org<http://www.netchoice.org/> and http://blog.netchoice.org<http://blog.netchoice.org/> +1.703.615.6206 From: Jonathan Zuck Date: Wednesday, April 8, 2015 at 9:05 AM To: "ccwg-accountability4(a)icann.org<mailto:ccwg-accountability4@icann.org>" Subject: [ST-WP] Spurring Board Action Greetings! On the call this morning, we had a discussion of some stress tests that risk falling through the cracks. Cheryl asked me to briefly summarize the portion of the discussion dealing with stress tests which involved board inaction. You might recall that Alan Greenberg originally brought up the notion of "compelling the board to take action" and there are several of the existing stress tests that highlight the need for that capability on the part of the community. Specifically, ST 11: “force ICANN to implement a recommendation arising from an AOC review, namely SSR" ST 17: "force ICANN to respond to recommendations from advisory committees such as SSAC." ST 3,4, 20, 22: “force ICANN to implement a consensus policy or recommendation of an AoC review” Cheryl brought up the fact that 11 and 17 had piqued the interest of the CWG so we focused on those two. Stress test 11 was inspired by the recent breach at ICANN and the inability of the community to extract information about the breach. Without the ability to spur action, that stress test would fail. Stress test 17 was about recommendations that are ignored by the board. One example we have used for some time is on the issue of Name Collisions and certs where a fairly large outcry on the part of the community was required to spur action a year ago. Another example, near and dear to the ALAC is dotless domains where there was very specific advice from SSAC as well as consensus concern and the board was slow to respond. Avri brought up recommendation 9 of the ATRT with respect to advice which dictates the board respond to advice in a timely manner: 9.1. ICANN Bylaws Article XI should be amended to include the following language to mandate Board Response to Advisory Committee Formal Advice: The ICANN Board will respond in a timely manner to formal advice from all Advisory Committees, explaining what action it took and the rationale for doing so. The question then arose whether a board "response" would be sufficient to trigger the other review mechanisms currently under consideration by WP2 so it was resolved to discuss that with Becky and her team. Perhaps it would be enough to dictate that the trigger mechanism for a review is a decision or response from the board. If not, we might need revisit a specific community power to induce the board to vote on a recommendation so that the vote can act as a trigger for further review if necessary. Cheryl, I hope I have sufficiently stressed everyone out with the possibility of board inaction. Feel free to ask questions or raise issues I have forgotten. I'll clip the mp3 for the topic if that's helpful to folks. Jonathan Jonathan Zuck President 202-331-2130 X 101 | jzuck(a)actonline.org<mailto:jzuck@actonline.org> | Skype: jvzuck ACT | The App Association [https://dl.dropboxusercontent.com/u/6442666/twitter.png]<https://twitter.com/actonline> [https://dl.dropboxusercontent.com/u/6442666/fb.png]<https://www.facebook.com/actonline.org> [https://dl.dropboxusercontent.com/u/6442666/actonline.png]<http://actonline.org>

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Notes, Recordings, Transcript ST-WP Meeting #3
by Brenda Brewer April 8, 2015

April 8, 2015

Dear all, The notes, recordings and transcripts for the CCWG Accountability Stress Tests WP Meeting #3 on 8 April are available here: https://community.icann.org/pages/viewpage.action?pageId=52892510 Action Items * ACTION ITEM: Ask Co-chairs as soon as possible when we would be expected to apply stress tests to conclusions published for public comment. * ACTION ITEM: Leave strike-through on community veto and alert CCWG. * ACTION ITEM: Pass on legal questions to legal subteam * ACTION ITEM WP2 to look at ATRT rec to ensure that is a sufficient trigger. * ACTION ITEM: Steve and Jonathan to write paper and alert WP1/WP2/CCWG * ACTION ITEM: ST-WP address CWG accountability measures during next call * ACTION ITEM: Schedule next week's call for 90 min * ACTION ITEM: Jonathan to send a note to list which identifies Board inaction-related stress tests Notes These high-level notes are designed to help you navigate through content of the call and do not substitute in any way the transcript. 1. Beran Gillan is on audio line 2. Further editing of stress test 18 since Istanbul 3. There are many anticipated mechanisms which we supposed would be part of the comment period e.g. mechanism of community veto - that was present in 8 of our stress tests. Community veto, however, is not being developed as part of WS1. May need to strikethrough some mechanisms. Eberhard has sent language for ST 21. Edward provided new ST (p.15) to be discussed Progress on ST 18. WP1 fully endorsed suggestion to proceed with change to Bylaw. Notion of how do we get Board to initiate action in proactive way - mechanism needed to force action. CWG identified set of stress tests as critical. 3&4 still up for discussion Expectation that we will apply stress test to what will be published for public comment. ACTION ITEM: Ask Co-chairs as soon as possible when we would be expected to apply stress tests to conclusions published for public comment. Community Veto Stress test 3 litigation arising from existing public policy & stress test 4 new regulations or legislation. Proposal to leave strikethrough and alert colleagues as a warning. If no community veto, we would take it out. Removing community veto would not be fatal. --> Alternatives: reconsideration or IRP - these two mechanisms are close but not identical to community veto. Parameters are being set for reconsideration request (Cf Robin Gross' template) --> Community veto is not redundant ACTION ITEM: Leave strikethrough on community veto and alert CCWG. Forcing ICANN's Board to implement a recommendation ST 17 ICANN attempts to add a new top-level domain in spite of security and stability concerns expressed by technical community or other SG. ATRT2 recommendation compels Board to respond to advice from AC. Is a response enough to trigger a review mechanism or do we need Board to make resolution/take a vote in order to have something to review? LEGAL QUESTION: can we ensure there is a response which relates to inaction of Board, not just responses that are triggered by action of Board? ACTION ITEM: Pass on legal questions to legal subteam If there is a response to issue, it is a far more high consequence such as proposal to spill whole Board. Spilling Board could be result of inaction. If inaction from Board, is it enough to trigger reconsideration or IRP? Where is the linkage? ACTION ITEM WP2 to look at ATRT rec to ensure that is a sufficient trigger. It would depend on nature of response/decision. We must have clarity about triggers. ST11 Compromise of credentials WP1 and WP2 to ensure reconsideration or IRP can be triggered on inaction of Board. ACTION ITEM: Steve and Jonathan to write paper and alert WP1/WP2/CCWG ST 26 suggested by Edward Morris was added. 4. ST 18 will be discussed on next CCWG call. 5. Following stress tests have been identified in context of CWG work: Failure to Meet Operational Expectations 1. Change authority for the Root Zone ceases to function, in part or in whole. 2. Delegation authority for the Root Zone ceases to function, in part or in whole. 11. Compromise of credentials. 17. ICANN attempts to add a new top-level domain in spite of security and stability concerns expressed by technical community or other stakeholder groups. 21. A government official demands ICANN rescind responsibility for management of a ccTLD from an incumbent ccTLD Manager. High priority should be given to this. On 13-14 April the CWG is having intensive work day Expecting long form document The CWG would have to build text around it to show how this would be applicable and how it is mapped. Suggestion to have Cheryl & Avri circulate CWG accountability mechanisms as soon as high confidence they are close to final stage ACTION ITEM: ST-WP address CWG accountability measures during next call ACTION ITEM: Schedule next week's call for 90 min ACTION ITEM: Jonathan to send a note to list which identifies Board inaction-related stress tests ST 21 TBD

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Spurring Board Action
by Jonathan Zuck April 8, 2015

April 8, 2015

Greetings! On the call this morning, we had a discussion of some stress tests that risk falling through the cracks. Cheryl asked me to briefly summarize the portion of the discussion dealing with stress tests which involved board inaction. You might recall that Alan Greenberg originally brought up the notion of "compelling the board to take action" and there are several of the existing stress tests that highlight the need for that capability on the part of the community. Specifically, ST 11: "force ICANN to implement a recommendation arising from an AOC review, namely SSR" ST 17: "force ICANN to respond to recommendations from advisory committees such as SSAC." ST 3,4, 20, 22: "force ICANN to implement a consensus policy or recommendation of an AoC review" Cheryl brought up the fact that 11 and 17 had piqued the interest of the CWG so we focused on those two. Stress test 11 was inspired by the recent breach at ICANN and the inability of the community to extract information about the breach. Without the ability to spur action, that stress test would fail. Stress test 17 was about recommendations that are ignored by the board. One example we have used for some time is on the issue of Name Collisions and certs where a fairly large outcry on the part of the community was required to spur action a year ago. Another example, near and dear to the ALAC is dotless domains where there was very specific advice from SSAC as well as consensus concern and the board was slow to respond. Avri brought up recommendation 9 of the ATRT with respect to advice which dictates the board respond to advice in a timely manner: 9.1. ICANN Bylaws Article XI should be amended to include the following language to mandate Board Response to Advisory Committee Formal Advice: The ICANN Board will respond in a timely manner to formal advice from all Advisory Committees, explaining what action it took and the rationale for doing so. The question then arose whether a board "response" would be sufficient to trigger the other review mechanisms currently under consideration by WP2 so it was resolved to discuss that with Becky and her team. Perhaps it would be enough to dictate that the trigger mechanism for a review is a decision or response from the board. If not, we might need revisit a specific community power to induce the board to vote on a recommendation so that the vote can act as a trigger for further review if necessary. Cheryl, I hope I have sufficiently stressed everyone out with the possibility of board inaction. Feel free to ask questions or raise issues I have forgotten. I'll clip the mp3 for the topic if that's helpful to folks. Jonathan Jonathan Zuck President 202-331-2130 X 101 | jzuck(a)actonline.org<mailto:jzuck@actonline.org> | Skype: jvzuck ACT | The App Association [https://dl.dropboxusercontent.com/u/6442666/twitter.png]<https://twitter.com/actonline> [https://dl.dropboxusercontent.com/u/6442666/fb.png]<https://www.facebook.com/actonline.org> [https://dl.dropboxusercontent.com/u/6442666/actonline.png]<http://actonline.org>

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Document for WP1 and WP2: Stress test 18 and proposed bylaws change regarding GAC advice
by Steve DelBianco April 7, 2015

April 7, 2015

To: members of Work Party 1, Work Party 2, and the stress test WP While in Istanbul, the stress test WP had hoped to discuss appropriate responses to stress test 18, regarding GAC advice that might no longer be supported by consensus. We didn’t get to this in Istanbul, so I drafted a summary of previous discussions of ST 18, and a proposed a way forward (page 5). It’s now for WP1 and WP2 to discuss mechanisms/powers to respond to the stress test. I ran this draft by the CCWG co-chairs, who advised several key edits and agreed this was an issue we need to address, despite the political sensitivities. I cannot join the WP1 call on 1-April, but hope this document is sufficient for you to consider the proposed bylaws change. Best, Steve — Steve DelBianco Executive Director NetChoice http://www.NetChoice.org<http://www.netchoice.org/> and http://blog.netchoice.org<http://blog.netchoice.org/> +1.703.615.6206

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