April 2006 - council - lists.icann.org

Regarding data collected and the purpose of collecting data
by Bruce Tonkin April 11, 2006

April 11, 2006

Hello All, There seem to be some concerns about the work on WHOIS affecting the data that is collected. I am not aware of any efforts in the registrar/registry community to change the data that is collected at the time of registration. As Ross has pointed out, privacy laws in various countries already require us to specify the purpose for which data is being collected (usually in the form of a privacy policy published on the website), as does the registrar accreditation agreement (in the form of the agreement between the registrar and the Registered Name Holder). Thus I recommend that the Council assume the following: (1) There is no change in the data that is collected. This is currently covered in clause 3.4 of the registrar agreement: http://www.icann.org/registrars/ra-agreement-17may01.htm#3 "Retention of Registered Name Holder and Registration Data.". "During the Term of this Agreement, Registrar shall maintain its own electronic database, as updated from time to time, containing data for each active Registered Name sponsored by it within each TLD for which it is accredited. The data for each such registration shall include the elements listed in Subsections 3.3.1.1 through 3.3.1.8; the name and (where available) postal address, e-mail address, voice telephone number, and fax number of the billing contact; and any other Registry Data that Registrar has submitted to the Registry Operator or placed in the Registry Database under Subsection 3.2." (2) There is a policy process around the public publication of some of the data that is collected. This is currently covered in clause 3.3 titled "Public Access to Data on Registered Names" "At its expense, Registrar shall provide an interactive web page and a port 43 Whois service providing free public query-based access to up-to-date (i.e., updated at least daily) data concerning all active Registered Names sponsored by Registrar for each TLD in which it is accredited. The data accessible shall consist of elements that are designated from time to time according to an ICANN adopted specification or policy. " Note the WHOIS policy activity is specifically in relation to the second sentence above. (3) If some data is no longer made public, there are other mechanisms for obtaining the data from the registrar. All registrars that are members of the registrars constituency that I have spoken to cooperate with law enforcement. If there are problems with some registrars - then perhaps this is a matter for the registrar accreditation process. (4) The purpose for collecting data is already defined in the registrar agreement. Regarding the purpose for collecting data - this is already in the registrar agreement, specifically in clauses 3.7.7.3, clause 3.7.7.4 and clause 3.7.7.5. Note there is no mention of the public display of such data in these clauses, nor the purpose for the public display. >From clause 3.7 of the registrar agreement, titled: "Business Dealings, Including with Registered Name Holders." 3.7.7.3 Any Registered Name Holder that intends to license use of a domain name to a third party is nonetheless the Registered Name Holder of record and is responsible for providing its own full contact information and for providing and updating accurate technical and administrative contact information adequate to facilitate timely resolution of any problems that arise in connection with the Registered Name. A Registered Name Holder licensing use of a Registered Name according to this provision shall accept liability for harm caused by wrongful use of the Registered Name, unless it promptly discloses the identity of the licensee to a party providing the Registered Name Holder reasonable evidence of actionable harm. 3.7.7.4 Registrar shall provide notice to each new or renewed Registered Name Holder stating: 3.7.7.4.1 The purposes for which any Personal Data collected from the applicant are intended; 3.7.7.4.2 The intended recipients or categories of recipients of the data (including the Registry Operator and others who will receive the data from Registry Operator); 3.7.7.4.3 Which data are obligatory and which data, if any, are voluntary; and 3.7.7.4.4 How the Registered Name Holder or data subject can access and, if necessary, rectify the data held about them. 3.7.7.5 The Registered Name Holder shall consent to the data processing referred to in Subsection 3.7.7.4." The terms of reference for the WHOIS task force were deliberately drafted to focus on the Public Access to Data on Registered Names Regards, Bruce Tonkin Registrar rep on GNSO Council

3 2

Current GNSO operational plan
by Maria Farrell April 11, 2006

April 11, 2006

Dear all, Ahead of tomorrow's meeting, please find attached the current version of the GNSO's operational plan. All the best, Maria

1 0

RE: [council] Proposed dates for GNSO Council and task force meetings in second quater
by tony.ar.holmes＠bt.com April 11, 2006

April 11, 2006

Glen Tomorrow - OK 18 May - OK 24 -27 May - OK for Brussels but will have to leave lunchtime on 27th 8 June - unable to participate due to conflicting business commitment Regards Tony -----Original Message----- From: owner-council(a)gnso.icann.org [mailto:owner-council@gnso.icann.org] On Behalf Of GNSO.SECRETARIAT(a)GNSO.ICANN.ORG Sent: 11 April 2006 17:16 To: council(a)gnso.icann.org Subject: [council] Proposed dates for GNSO Council and task force meetings in second quater [To: council[at]gnso.icann.org] Dear Council Members, This is a resend as a reminder for tomorrow's Council call of some proposed dates for Council teleconference meetings and face to face working sessions for the second quarter up to the Marrakesh meetings on 26-30 June 2006: Wednesday 12 April GNSO Council teleconference - Summer time in Europe 12:00 UTC (there will be voting on this call so please indicate whether you will be present as there are no proxies) Thursday 18 May GNSO Council teleconference - 12:00 UTC Thursday afternoon 25 May, Friday all day 26 May, Saturday all day 27 May - proposed face to face policy work session in Brussels Thursday 8 June GNSO Council teleconference - 12:00 UTC Friday 9 June proposed new PDP-Feb06 task force teleconference (time to be decided) Thursday 15 June GNSO Council teleconference - 12:00 UTC (just before Marrakesh meeting) Thank you very much. Glen -- Glen de Saint Géry GNSO Secretariat - ICANN gnso.secretariat[at]gnso.icann.org http://gnso.icann.org

2 1

Proposed approach to travel funding in the ICANN operating plan
by Bruce Tonkin April 11, 2006

April 11, 2006

Hello All, Based on discussions I have had over the past two ICANN meetings, there seems to be reasonable support for ICANN to fund some of the travel expenses for members of the Council and task forces. Even though some Council members are employed by members of the Internet industry that may seem like well resourced organisations, the reality is that it is becoming increasingly difficult for Council and task force members to get regular travel support to attend several meetings a year where there is not a direct commercial return from each meeting. The Internet industry is intensely competitive and most organizations in the industry manage costs very tightly. Some of these organisations already feel they are making a significant contribution through the time that they allow their staff to spend on ICANN matters. Note that ICANN already funds some of the travel of members of ICANN's nominating committee, the Council members appointed by the Nominating committee, and members of the At-Large Advisory Committee. Recent experience with meetings in Washington and Wellington have shown that face-to-face meetings are an important part of making more rapid progress on complex policy issues. However I don't believe that ICANN funding of travel should be taken for granted, and any recipients of funding should ensure that they have done significant work in advance of travelling to any physical meeting. I intend to submit feedback to the Kurt Pritz with respect to the Operating Plan for 1 July 2006 to 30 June 2007. Here is my proposal so far: (1) GNSO Council - All GNSO Council members should receive travel support consistent with the support provided to other members of the ICANN community (e.g ICANN Board, nominating committee etc) for the three ICANN meetings per year. - I assume that there is some sort of consistent ICANN travel policy for the organisation, with respect to things like class of airline travel, class of hotel accommodation etc. (2) For major PDPs that are of strategic significance to the organisation - e.g new gTLDs, IDNs, and WHOIS - that allowance be made for up to three face-to-face meetings a year separate from the normal ICANN meetings - that funding be provided for: -- the chair of the committee/task force -- one representative from each constituency (not including the chair) -- one of the three appointees from the Nominating committee (not including the chair) -- each representative would need to apply to the Council for funding, and provide information on the outreach conducted by that representative, as well as a written summary of material that will be used as part of the physical meeting. This application would be public. If an application was inadequate the Council could decide to deny funding. - the location of the face-to-face meetings have a studio-quality audio-visual environment that allows for effective remote participation The intent is that meetings may be rotated around the major regions of the world, and that representatives that are located close to the location for the meeting would receive no funding for that meeting. Each rep would also typically have the opportunity to be funded once per year, assuming that the role is rotated. Please let me know any feedback, before I submit to Kurt Pritz. Regards, Bruce Tonkin

5 11

Compromise wording on WHOIS
by Philip Sheppard April 11, 2006

April 11, 2006

Council, In preparation for the discussion and possible vote on WHOIS purpose please find attached a proposed compromise definition. The background to this compromise is as follows: - It is not intended to be a new formulation 2 but a new approach and thus an amendment to the proposed vote. - The new wording seeks to accommodate numerous concerns expressed at the last Council meeting and in the recent WG paper: 1. it speaks not of the purpose of "WHOIS" but the purpose for which the "data is collected". This reflects the concerns rightly raised by the non-commercial constituency in that previous definitions were not compliant with data protection laws such as the EU data protection directive. The intent here is that the scope should be no wider than the scope of such laws. 2. The new wording removes the overly wide phrase "or other uses" phrase in a previous definition. In this way it stays compliant also with data protection laws in that purpose has to be explicit. 3. The definition is silent on questions of subsequent access to data or data publication. This issue was raised by the Registrars in that the purpose of WHOIS was being defined in the context of the current manifestation of WHOIS with its current open access and publication. This definition is intended not to make ANY assumption about access. 4. In the same way this definition is not intended to override any subsequent debate on privacy. I hope that by addressing the concerns above, we can get the full support of Council to a definition describing the purposes of data collection and one that is not blind to the use that such data is being put today in pursuit of consumer protection and measures to prevent crime. To pursue a vote that would divide Council between the previous formulations 1 and 2 would not move us forward. I hope this third way ( excuse me sounding like UK prime minister Tony Blair!) will be a positive way forward for Council and one that will also get the full support of the GAC. Philip

5 10

Regarding law enforcement access to data
by Bruce Tonkin April 11, 2006

April 11, 2006

Hello Philip, Much seems to be made of the law enforcement issues of access to data. The argument seems to be: (1) Law enforcement need access to data for investigation (2) The data must be made public for everyone in the world to see for this to happen I can't understand this logic. The policy development process is focussed on the release of information to the public via the WHOIS service (either through the port-43 protocol or the http protocol). Registrars have substantial data that is useful for law enforcement efforts including credit card information, the source IP addresses used in transactions, etc that is not published in the WHOIS. ISPs also have information relating to who was allocated a particular IP address at any point in time. Registrars already have processes for supplying necessary data to law enforcement. I am sure this can be improved - but that should be either the subject of a separate policy development effort, or, in the first instance, a discussion between law enforcement and registrars. You mention the issue of data protection laws. It is quite common for data protection laws to specifically take into account requirements for law enforcement. This does not need to be explicitly included in a registration agreement relating to the purpose or use of data collected. For example, from the Australian National privacy principles at: http://www.privacy.gov.au/publications/npps01.html It states under the heading of "Use and disclosure": "An organisation must not use or disclose personal information about an individual for a purpose (the secondary purpose) other than the primary purpose of collection UNLESS: "(f) the organisation has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or (g) the use or disclosure is required or authorised by or under law; or (h) the organisation reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body: (i) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; (ii) the enforcement of laws relating to the confiscation of the proceeds of crime; (iii) the protection of the public revenue; (iv) the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; (v) the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal." The privacy principle also states: "If an organisation uses or discloses personal information under paragraph (h), it must make a written note of the use or disclosure." So at least in Australia, law enforcement activities are already covered under the privacy laws. What is not envisaged in the privacy laws is that the method to provide data to law enforcement should be via public publication. There is literally no practical way to restrict the subsequent "use" of data once it is published in the public. There is mention about defining uses, but our role within the ICANN mission is all about purpose - what is the purpose of providing certain information to the public. Whatever information is eventually published to the public is clearly going to be "used" for an endless range of activities - thus we need to be very careful in ensuring we only provide information that is "sufficient" to meet the purpose of the service. Regards, Bruce Tonkin

1 0

NCUC analysis of WHOIS purpose definitions
by Robin Gross April 11, 2006

April 11, 2006

I would like to share with my fellow GNSO Council Members this analysis regarding the two WHOIS purpose formulations from NCUC member and WHOIS TASK FORCE member Kathryn Kleiman, who is also a DC attorney: ICANN has a very narrow technical mission. It is that defined mandate that gives ICANN its legitimacy. ICANN is the technical coordinator of the domain name system. Its mission does not extend to the use of a domain name. Use is a matter of discretion and balance. What is posted on a website, what is sent in an email, what is shared in a listserv all involve the use of a domain name, but far exceed the narrow bounds of ICANN’s work. It is for countries, by law and treaty, to determine how they want to share and disclose data if someone does not like the religious or political content posted on a website, shared in an email, or conveyed on a list. Only Formulation 1 continues to keep the purpose of Whois within the narrow technical scope of “issues related to the configuration of the records associated with the domain name within a DNS nameserver.” This use directly involves the registration of a domain name, its resolution, and technical problems associated directly with DNS issues – powers clearly given to ICANN. Revised Formulation 2 gives certain constituencies unlimited access to personal data for any purpose even remotely related to their Internet work. While the words “technical” and “networking” resonate nicely in our ears, the Business and ISP constituencies repeatedly told the Whois Task Force the broad definition they have for these terms. “Technical” and “networking” is anything online! It includes any use, question or concern an ISP or large online business might have about anyone coming to their website, transacting business with them or even having mail routed through their servers. ICANN never received unlimited power to regulate all technical and networking activities online, and it is a scope few would want it to have. “Legal issues related to registration or use of a gTLD domain name” is similarly undefined and unbounded. Any question of content that any attorney may have is covered by this definition. Should he/she want to use the Whois personal data to harass, criticize or intimidate a domain name registrant for content on a website, listserv or email, the attorney would have the right to do so under Revised Formulation 2 because the content involves “use of a domain name.” Nowhere is there any standard that the attorney has to state a cause of action or even present a non-frivolous claim. Any attorney can state a legal issue for any type of problem (just ask them!) But allowing such action would also foster intimidation and abuse of all who hold and share minority opinions online using domain names – minority personal, political and religious speech could be driven off the Net. An example of balance between personal data and legal needs occurred in the US a few years ago. ISPs used to disclose chatroom identities on demand. Attorneys would come to ISPs claiming that people had defamed their companies, engaged in violations of insider trading, etc. Attorneys received the personal data, but it turns out that in many cases, they were really trying to find out and silence whistleblowers (those pointing out illegalities in businesses or government contracts), stop those complaining of workplace harassment, or just harass anyone who criticized their company’s products or services (even legitimately) in a chatroom. The legal claims were trumped up. Now to seek disclosure of chatroom identities in the US, attorneys must go to court in “John Doe” suits. They must first demonstrate to the court that they have solid evidence of illegality, a true cause of action under law, and clear evidence that the chatroom identity they seek is really the one involved in the unlawful conduct they allege. No more fishing expeditions or intimidation of speakers. Formulation 1 provides a similar balance – a purpose for Whois within the narrow technical DNS mandates of ICANN. The personal data remains in the hands of registrars for all other legitimate purposes. It is available for access to resolve all other technical, networking, legal or social issues or concerns consistent with law and due process.

1 0

Facts about Whois
by Ross Rader April 10, 2006

April 10, 2006

I thought it would be useful to share some basic facts about Whois and Whois data. These are taken from the various registry/registrar agreements and might be useful in terms of gaining a better understanding of the current deliberation. For the purpose of this discussion, I am limiting this definition to those uses by gTLD operators. There are many other Whois based services in use around the world (IP address registries, ccTLD managers, etc.) The important point of understanding is the difference between the customer transaction data that registrars must undertake to process a customer request for a domain registration, and the Whois publishing requirements imposed on registrars and registries by the ICANN agreement. The current whois task force is only chartered to deal with the policy related to the publishing mechanism. **** 1. What is whois? Whois is a simple API based protocol that provides query access to a database of information related to domain name registrations. Queries can be sent to a Whois server via a desktop client using port 43, or via a web form, which may also use back-end logic to communicate with the Whois server also via port 43. This two types, while very similar, are referred to respectively as "Port 43" and "Web-based" whois. 2. What is whois data? Whois data, according to the contracts, is the data that is published via the Whois API. Currently, this data consists of; The domain name; The nameservers for the domain names The name of the registrar responsible for the registration The date of registration The date the domain name expires The name and postal address of the registrant The name, postal address, e-mail address, voice telephone number, and (where available) fax number of the technical contact; and The name, postal address, e-mail address, voice telephone number, and (where available) fax number of the administrative contact. Collection of this data is undertaken per the requirements of the ICANN-Registrar agreements, and the laws of the country in in which each of the registrar and registrant reside. 3. What other registration data do registrars collect? Registrars collect a lot more data than that which is required by the ICANN contracts (see 2). For example, Registrars collect credit card information, address information for the registrant, various opt-in and agreements to various legal clauses, and so on. The information registrars collect is very similar to the information that any internet merchant collects. The collection of this additional data permits the registrar to conduct its business and support the needs of its clients. Collection of this data is undertaken per the requirements of the national law in effect in the country in which each of the registrar and registrant reside. **** -- -rr "Don't be too timid and squeamish about your actions. All life is an experiment. The more experiments you make the better." - Ralph Waldo Emerson Contact Info: Ross Rader Director, Research & Innovation Tucows Inc. c. 416.828.8783 Get Started? http://start.tucows.com My Blogware: http://www.byte.org

1 0

Participation through Conference calls, Netmeeting, Live meetings, etc.
by Mawaki Chango April 10, 2006

April 10, 2006

I would say why not, Sophia. It is certainly more engaging than a plain conference call, but I guess less than a live meeting. Personally, I have been 24/7 English speaking just for a few months, and my ears are not yet fully "fluent," so to speak (*), in hearing properly all what you guys say in a meeting over the phone (and sometimes even live, still:)), thus my limited participation on the calls. In those conditions, it's kind of hard, I must confess, not to be distracted with multi-tasking, when one is sitting in one's usual working environment and trying to focus on the conference call. In sum, live meetings may still be useful especially in such a multicultural setting, which I'm sure we all agree on. Best, Mawaki (*) For those who don't know, I grew up and have been educated speaking French, among other local languages, and had to learn and speak Portuguese over the last three years, before being now in my first year in an all-English speaking environment. --- Sophia B <sophiabekele(a)gmail.com> wrote: > I am sorry we have to go thru this, but has any one thought of > MS 'netmeetiing' software, it is free and supports remote > conference > including document viewing. It is absolutely great. > > We use it at Intel Corp, at all times for global conferences. I > am not > sure of its transcription capabilities, but MP3 recording should > not be a > problem with netmeeting. > > I have heard Ross mention a software with transcription > capabilities, I am > not sure the cost. But, if you want me to explore Net Meetimg, > concurrently > is advise. > > regards, > Sophie > > > On 05/04/06, Marilyn Cade <marilynscade(a)hotmail.com> wrote: > > > > can we please see a spread sheet from staff with the options. > We seem to > > be doing most of the work and a spread sheet from staff with the > options > > will faciliate Councilor/TF members abilty to make "selections". > > > > > > > > Tom, thanks for checking with DeNIC. I would support that as a > meeting > > location, if they are willing to bear with the demands of support > for remote > > participation. I've also just spoken to Bruce about our starting > to do web > > meetings so that documents are able to be viewed remotely.And, we > need to > > simply purchse the necessary equipment and install it and then > insist that > > it be used. I am not sure that MdR or Brussels have sufficient > "rooms" to > > support what we need at this point in space,and I don't think > that is the > > issue to focus on. It is easy to just suggest to ICANN that they > "buy", but > > instead, I'd like to focus on how to support remote > participation, since we > > don';t watn to be limited to moving people to Brussels or MdR, > although that > > is good for future in face meetings. > > > > > > > > Instead, I'd make it a priority to 1) start using web meeting > software 2) > > purchase a few microphones, extender mikes, etc. and 3) do real > time > > transcription [after the fact translation of MP3 recordings is > good and > > appropriate for the conf. calls that Council holds, , but not the > same for > > full participation of councilors whne a meeting is underway, so > in certain > > circumstances, we need real time transcription, or a form of > scribbing that > > is summary type scribbing... but the point is that we need to > insist now, > > and initiate now, real support for remote participation. > > > > As to the time of the Euroepan meeting, I will do my best, within > the > > limits of > > > > 1) not first week of May > > > > 2) not 5/19 > > > > 3) not 5/29-30, with travel limiations on both sides > > > > > > > > > > > > > > > > I have an absolute date that I must be in Missouri. It is > possible that I > > will miss our Council meeting in Europe, if those are the only > dates. They > > are 5/29-30. > > > > I apologize that this is a public list, but we don't have a > private > > council only list for communications related to scheduling, and > thus I have > > no choice but to use this list. Perhaps this will serve as the > emphasis for > > staff to set up a adm issues only list that we can do stuff like > this on, > > since I suspect even those who advocate transparency to teh nth > degree might > > be bored by our looking at each others calendars. :-) > > > > Due to family health issues I must be in MIssouri on 5/29-30. > While I can > > miss birthdays of my elderly parents, and spent my own birthday > at ICANN > > meetings, and have done both, I can't not be in Missouri for > those dates. I > > can work around them though, and will. > > > > > > > > > > > > ------------------------------ > > From: *"Anthony Harris" <harris(a)cabase.org.ar>* > > To: *"Thomas Keller" <tom(a)schlund.de>, "Marilyn Cade" < > > marilynscade(a)hotmail.com>* > > CC: *"Tom Keller" <tom(a)schlund.de>, > <owner-gtld-council(a)gnso.icann.org>, > > "Bruce Tonkin" <bruce.tonkin(a)melbourneit.com.au>, < > > gtld-council(a)gnso.icann.org>* > > > > > > Subject: *Re: [gtld-council] Dates for a possible physical > meeting in > > Brussels* > > Date: *Wed, 5 Apr 2006 14:53:02 -0300* > > > > >Just thought I should mention there is a LACNIC annual > > >meeting in Guatemala on May 22-26th. Its very likely I > > >may have to be there... > > > > > >Tony Harris > > > > > >----- Original Message ----- From: "Thomas Keller" > <tom(a)schlund.de> > > >To: "Marilyn Cade" <marilynscade(a)hotmail.com> > > >Cc: "Tom Keller" <tom(a)schlund.de>; > > ><owner-gtld-council(a)gnso.icann.org>; "Bruce Tonkin" > > ><bruce.tonkin(a)melbourneit.com.au>; <gtld-council(a)gnso.icann.org> > > >Sent: Wednesday, April 05, 2006 8:04 AM > > >Subject: Re: [gtld-council] Dates for a possible physical > meeting in > > >Brussels > > > > > > > > >>Marilyn, all, > > >> > > >>both dates, before or after the meeting, would be fine with me > as > > >>long as > > >>it is in Barcelona. Thought that parts of our discussion could > be > > >>public > > >>I imagine that this would be a very interessting contribution > to > > >>all > > >>participants of the Registrar meeting. > > >> > > >>Alternatively I would suggest to hold the meeting in Frankfurt > (for > > >>the > > >>very selfish reason that I won't be able to participate on > three > > >>meetings in the intercourse of a bit more than one month). > > >>I already talked to DENIC and they would be ready to > accommodate a > > >>location > > >>for our meeting. > > >> > > >>Best, > > >> > > >>tom > > >> > > >>Am 29.03.2006 schrieb Marilyn Cade: > > >>>Tom, since the registrars meet 5/24-26, could you suggest what > > >>>days wk for you for separate Council TF on new gTLDs? Before? > Or > > >>>after? > > >>>Regards, > > >>>Marilyn Cade > > >>> > > >>> > > >>>-----Original Message----- > > >>>From: Thomas Keller <tom(a)schlund.de> > > >>>Date: Wed, 29 Mar 2006 09:39:43 > > >>>To:Bruce Tonkin <Bruce.Tonkin(a)melbourneit.com.au> > > >>>Cc:gtld-council@gnso.icann.org > > >>>Subject: Re: [gtld-council] Dates for a possible physical > meeting > > >>>in Brussels > > >>> > > >>>As far as I know there is a ICANN European Registrar meeting > > >>>scheduled > > >>>for the 24-26 of May in Barcelona. If possible in any way I > would > > >>>like to recommend to use this venue for a intermediate meeting > === message truncated ===

3 4

RE: Time line for IDN PDP
by Bruce Tonkin April 10, 2006

April 10, 2006

Hello Sophia, > Just a note to suggest that we may want to add to the upcoming GNSO agenda, the timeline discussion for the IDN PDP. As the testing is announced and would start soon, the objective as we all understand is to do a parallel run. Well the first step is to get the issues report done. We have a teleconference scheduled for 18 May 2006. Hopefully we can get the issues report completed by, say 8 May 2006, to allow time to consider it prior to that teleconference. Regards, Bruce Tonkin

3 2