Thanks for the revised draft, Greg. I'd rather hope that we could address all 3 .org, .biz. and .info RA renewals in a single statement in an attempt to consider inter-connected ramifications and while still verbalising support for ISOC without singling out the .org RA renewal. My personal position is while I don't object to the proposed price cap removal because I see some merits in Jonathan's explanation, I think it might be worth considering doing so in a less abrupt fashion by deferring the price cap removal to give potential and existing registrants time/leeway to plan for/react to an eventual price cap removal. My proposition here has to do more with the *impact of acquiescing to immediate price cap removals* *on the .biz, and .info TLDs*, and by extension, on .com and .net TLDs eventually. Justine ----- On Tue, 30 Apr 2019 at 15:31, Olivier MJ Crépin-Leblond <ocl@gih.com> wrote:

Dear Greg,

thanks for this revised draft. However, I deplore that once again my proposal of the Registry fees to ICANN following inflation is still not integrated to this Statement whilst this has received support from CPWG participants and I have heard nobody speaking against this. Kindest regards,

Olivier

On 30/04/2019 07:14, Greg Shatan wrote:

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"*

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-- Olivier MJ Crépin-Leblond, PhDhttp://www.gih.com/ocl.html

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Understood with thanks, Marita. I constantly struggle to balance competing arguments, in the form of prima facie views of end-users versus those touching on less-apparent yet broader policy implications, and I know I am not alone in this. While I would much prefer if we could come to a consensus statement with a common position, but on the likelihood that we cannot reach (clear) consensus, I can make available for the WG's consideration and further improvements (for eg. including Olivier's point about registry fees) an alternate re-draft of Greg's 24 April draft. Justine ----- On Tue, 30 Apr 2019 at 16:11, Marita Moll <mmoll@ca.inter.net> wrote:

So, perhaps the price cap removal could be delayed until after the market impact evaluation process that Greg has outlined in the new proposal was in place. Otherwise, there is no incentive to actually proceed with the process. I realize that evaluation process was intended for the .org part of the package but could apply to all.

That said, I am mostly concerned with the impact on .org. I know that some lobby groups have gone into overdrive over this issue -- but users don't respond to these things unless they truly feel threatened. And users have responded in droves.

If we ignore this, whatever the good reasons to release the caps which have been put forward here and which I understand, I don't think we are listening to end-users.

Marita On 4/30/2019 9:46 AM, Justine Chew wrote:

Thanks for the revised draft, Greg.

I'd rather hope that we could address all 3 .org, .biz. and .info RA renewals in a single statement in an attempt to consider inter-connected ramifications and while still verbalising support for ISOC without singling out the .org RA renewal.

My personal position is while I don't object to the proposed price cap removal because I see some merits in Jonathan's explanation, I think it might be worth considering doing so in a less abrupt fashion by deferring the price cap removal to give potential and existing registrants time/leeway to plan for/react to an eventual price cap removal. My proposition here has to do more with the *impact of acquiescing to immediate price cap removals* *on the .biz, and .info TLDs*, and by extension, on .com and .net TLDs eventually.

Justine -----

On Tue, 30 Apr 2019 at 15:31, Olivier MJ Crépin-Leblond <ocl@gih.com> wrote:

...

Dear Greg,

thanks for this revised draft. However, I deplore that once again my proposal of the Registry fees to ICANN following inflation is still not integrated to this Statement whilst this has received support from CPWG participants and I have heard nobody speaking against this. Kindest regards,

Olivier

On 30/04/2019 07:14, Greg Shatan wrote:

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"*

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-- Olivier MJ Crépin-Leblond, PhDhttp://www.gih.com/ocl.html

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I agree with Bastiaan on this, and yes, at least start with Greg’s 30 April draft (thanks Greg for all your work on this and, as much as possible, reflecting views that have been expressed. Holly

On Apr 30, 2019, at 8:22 PM, Bastiaan Goslings <bastiaan.goslings@ams-ix.net> wrote:

...

On 30 Apr 2019, at 11:52, Justine Chew <justine.chew@gmail.com> wrote:

Understood with thanks, Marita. I constantly struggle to balance competing arguments, in the form of prima facie views of end-users versus those touching on less-apparent yet broader policy implications, and I know I am not alone in this.

While I would much prefer if we could come to a consensus statement with a common position, but on the likelihood that we cannot reach (clear) consensus, I can make available for the WG's consideration and further improvements (for eg. including Olivier's point about registry fees) an alternate re-draft of Greg's 24 April draft.

Thanks, Justine - I’d be fine with you including Olivier’s point re correcting fees from registries that go to ICANN for inflation. But then please use the 30 April version of Greg’s draft statement ;-)

regards Bastiaan

...

On Tue, 30 Apr 2019 at 16:11, Marita Moll <mmoll@ca.inter.net> wrote: So, perhaps the price cap removal could be delayed until after the market impact evaluation process that Greg has outlined in the new proposal was in place. Otherwise, there is no incentive to actually proceed with the process. I realize that evaluation process was intended for the .org part of the package but could apply to all.

That said, I am mostly concerned with the impact on .org. I know that some lobby groups have gone into overdrive over this issue -- but users don't respond to these things unless they truly feel threatened. And users have responded in droves.

If we ignore this, whatever the good reasons to release the caps which have been put forward here and which I understand, I don't think we are listening to end-users.

Marita

On 4/30/2019 9:46 AM, Justine Chew wrote:

...

Thanks for the revised draft, Greg.

I'd rather hope that we could address all 3 .org, .biz. and .info RA renewals in a single statement in an attempt to consider inter-connected ramifications and while still verbalising support for ISOC without singling out the .org RA renewal.

My personal position is while I don't object to the proposed price cap removal because I see some merits in Jonathan's explanation, I think it might be worth considering doing so in a less abrupt fashion by deferring the price cap removal to give potential and existing registrants time/leeway to plan for/react to an eventual price cap removal. My proposition here has to do more with the impact of acquiescing to immediate price cap removals on the .biz, and .info TLDs, and by extension, on .com and .net TLDs eventually.

Justine -----

On Tue, 30 Apr 2019 at 15:31, Olivier MJ Crépin-Leblond <ocl@gih.com> wrote: Dear Greg,

thanks for this revised draft. However, I deplore that once again my proposal of the Registry fees to ICANN following inflation is still not integrated to this Statement whilst this has received support from CPWG participants and I have heard nobody speaking against this. Kindest regards,

Olivier

On 30/04/2019 07:14, Greg Shatan wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY "The Internet is for everyone"

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-- Olivier MJ Crépin-Leblond, PhD

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---

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I would not place much weight on the slew of comments sent in on .ORG (and others). Many of these are “cut-and-paste” comments with identical text. Others are one-liners. Some are quite ill-informed (one commenter thought they would have to pay the RO quarterly fee, others have thought that PIR is a for-profit organization, etc., etc.). I assume that some commenters sincerely felt threatened. But was this a credible, well-founded or well-informed fear, or just a trip through a fun-house designed to get a rise out of the commenters? A great number of these comments are the direct result of a well-orchestrated campaign, rife with overblown statements and catastrophic worst-case scenarios. In the absence of other information, such campaigns can be quite effective in fomenting fear and then harnessing that fear in order to flood a comments period. We’ve seen this before. If you wind people up, you can get a lot of them to go in the direction you want. It might be too generous to say that “some lobby groups” are behind this. It appears to be one. A Google search revealed the “engine” used to generate all of those identical comments, complete with four pre-loaded variations, and cleverly engineered so that the comment will come from the sender’s own email account and not from the “engine.” The page is here: https://www.internetcommerce.org/comment-org/. There are multiple links from other pages, blogs, social media accounts, etc., to this resource. These campaigns can reach out in many directions, in different places and in different guises. It can take a great deal of discernment to recognize them for what they are and to resist them. I hope that the CPWG collectively can be discerning. Best regards, Greg On Tue, Apr 30, 2019 at 4:12 AM Marita Moll <mmoll@ca.inter.net> wrote:

So, perhaps the price cap removal could be delayed until after the market impact evaluation process that Greg has outlined in the new proposal was in place. Otherwise, there is no incentive to actually proceed with the process. I realize that evaluation process was intended for the .org part of the package but could apply to all.

That said, I am mostly concerned with the impact on .org. I know that some lobby groups have gone into overdrive over this issue -- but users don't respond to these things unless they truly feel threatened. And users have responded in droves.

If we ignore this, whatever the good reasons to release the caps which have been put forward here and which I understand, I don't think we are listening to end-users.

Marita On 4/30/2019 9:46 AM, Justine Chew wrote:

Thanks for the revised draft, Greg.

I'd rather hope that we could address all 3 .org, .biz. and .info RA renewals in a single statement in an attempt to consider inter-connected ramifications and while still verbalising support for ISOC without singling out the .org RA renewal.

My personal position is while I don't object to the proposed price cap removal because I see some merits in Jonathan's explanation, I think it might be worth considering doing so in a less abrupt fashion by deferring the price cap removal to give potential and existing registrants time/leeway to plan for/react to an eventual price cap removal. My proposition here has to do more with the *impact of acquiescing to immediate price cap removals* *on the .biz, and .info TLDs*, and by extension, on .com and .net TLDs eventually.

Justine -----

On Tue, 30 Apr 2019 at 15:31, Olivier MJ Crépin-Leblond <ocl@gih.com> wrote:

...

Dear Greg,

thanks for this revised draft. However, I deplore that once again my proposal of the Registry fees to ICANN following inflation is still not integrated to this Statement whilst this has received support from CPWG participants and I have heard nobody speaking against this. Kindest regards,

Olivier

On 30/04/2019 07:14, Greg Shatan wrote:

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"*

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Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs

-- Olivier MJ Crépin-Leblond, PhDhttp://www.gih.com/ocl.html

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Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs

-- Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"*

On Tue, Apr 30, 2019, 1:01 PM Olivier MJ Crépin-Leblond <ocl@gih.com> wrote:

Dear Greg,

thanks for this revised draft. However, I deplore that once again my proposal of the Registry fees to ICANN following inflation

+1. Also in favour of an upward review first, and then annual inflation adjustments. is still not integrated to this Statement whilst this has received support

from CPWG participants and I have heard nobody speaking against this. Kindest regards,

Olivier

On 30/04/2019 07:14, Greg Shatan wrote:

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"*

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-- Olivier MJ Crépin-Leblond, PhDhttp://www.gih.com/ocl.html

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ registration-issues-wg mailing list registration-issues-wg@atlarge-lists.icann.org https://mm.icann.org/mailman/listinfo/registration-issues-wg

George, Your comments about Greg somehow "capturing" the At-large (on whose behalf I wonder) are disingenuous given the campaign. In which you are engaged and insulting to everyone on this list attempting to get a handle on a complex and highly political issue. I suggest you withdraw them. Thanks. Jonathan Jonathan Zuck Executive Director Innovators Network Foundation www.Innovatorsnetwork.org<http://www.Innovatorsnetwork.org> ________________________________ From: GTLD-WG <gtld-wg-bounces@atlarge-lists.icann.org> on behalf of George Kirikos <icann@leap.com> Sent: Tuesday, April 30, 2019 7:51:47 AM To: CPWG Subject: Re: [GTLD-WG] [CPWG] Further Revised Draft Statement on .ORG Renewal For the record, I disagree with the statement that Greg prepared, and it doesn't reflect my views (which I linked to in an earlier post). It doesn't even reflect the views expressed by many non-profits who made public comments, including NPR and other high profile ones: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003179.ht... or the Non-Commercial Stakeholders: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003207.ht... If folks wanted to send a letter, they should have sent it in an individual capacity, rather than pretend that this statement is reflective of the views of billions of internet users. Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts. ISOC/PIR is just one of many non-profits, and its mission is no better than any other. Every organization has unlimited wants, but needs to work within a reasonable budget. ISOC/PIR doesn't own .org, and shouldn't pretend it does via unlimited "rent" or taxes payable to it. They'll always be able to spend as much money as they can take in. As I noted in my own comments, nothing would stop ISOC/PIR from selling out to private equity, who could then take the heat for huge price increases, while ISOC/PIR walks away with an enormous multi-billion dollar endowment fund. The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users. The base agreement for new gTLDs is different from that of legacy gTLDs for good reason, and should not be adopted by legacy gTLDs which predate ICANN itself, and whose registrants do not agree with unlimited fee increases. That's changing the rules in the middle of the game (whereas registrants of new gTLDs knew all along the risks they take registering with new gTLDs, where the registry essentially "owns" that TLD). The letter quotes Jonathan Zuck's statement about the "desirability" of higher prices almost verbatim, but hasn't done the same for others in the CPWG. Higher prices are not desirable in any way, except by some twisted logic that makes no economic sense (my own personal background is in economics and finance). New entrants always knew that legacy gTLDs had capped prices, before they entered the space. Furthermore, competition generally leads to *lower* prices, not higher prices! Attempting to argue that capped fees contribute to confusion, phising, fraud and abuse is truly a stretch. The most abused TLDs are the new gTLDs, not the legacy ones, e.g. see: https://www.spamhaus.org/statistics/tlds/ If one wants to target phishing, fraud and other abuses, one needs to actually *target* it using effective tools. Raising prices for *everyone* is not an effective tool, as it has more collateral damage than actual benefits. If 1%, for example, of domains are engaged in abused, it makes no sense to raise costs on 100% of registrants. One wants to raise costs only on those engaged in abuse (e.g. through high penalties for abuse, like jailtime, fines, etc.). Raising prices for *everyone* simply enriches the registry, at the expense of the public. Pretending that an "economic study" will be helpful is absurd, as ICANN has in the past commissioned "experts" who simply regurgitated whatever ICANN wanted them to say. Recall that these so-called "experts" (the Carlton report, etc.) were used to justify the new gTLD program in the first place, which has been a failure. Here's a comment from K. Claffy, which talked about those reports: https://forum.icann.org/lists/economic-framework/msg00004.html which also referenced my scathing comments about them at the time (which proved prescient). She concluded her comments with: "Similar to my observations of what's happening in the security and stability discussion of root scaling, ICANN's behavior looks like it's trying to buy rubberstamps of its current plans from commercial consultants, rather than foster what is needed in the long term: a coherent field of objective, peer-reviewed technical, policy, and economic research on Internet naming and numbering, and incentivized data-sharing to support such research." The ICANN contracts do not have any mechanism to "undo" the changes. Once the caps are removed, that genie cannot be put back in the bottle. One should do an economic study *before* lifting any price caps, rather than doing them after the horse has left the barn, and after the damage has already been done. What "problem" is this contract actually trying to solve? If it's not broken (and legacy gTLDs are successful, obviously), one should stick with the status quo. If new gTLDs are the "broken" thing, they can be fixed directly (by adding fee caps, just like the successful legacy gTLDs, or making other changes). In conclusion, Greg, Jonathan, and others should have simply submitted their own personal comments, rather than try to suggest that this statement is reflective of billions of users. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ On Tue, Apr 30, 2019 at 2:14 AM Greg Shatan <greg@isoc-ny.org> wrote:

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY "The Internet is for everyone" _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ GTLD-WG mailing list GTLD-WG@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs

Jonathan, I find your email: https://mm.icann.org/pipermail/cpwg/2019-April/001168.html which was in response to my email at: https://mm.icann.org/pipermail/cpwg/2019-April/001149.html which was responding to Greg's email at: https://mm.icann.org/pipermail/cpwg/2019-April/001136.html to be quite bizarre. Discussion of capture is and always has been a legitimate topic at ICANN. 1. Before going into the substance, there appears to be a double standard here, where you state my comments are "disingenuous" and refer to some "campaign". Calling someone "disingenuous" isn't nice or respectful. The "campaign" presumably refers to Greg Shatan's statement at: https://mm.icann.org/pipermail/cpwg/2019-April/001162.html where wild accusations of a "well-orchestrated campaign" are made, and pointing to just one "lobby group", the Internet Commerce Association as behind it. Again, not nice words (and which I'll discuss further below), but not a peep when those statements are made (which you presumably share, given you refer to "the campaign"). Greg Shatan's entire email disrespects and attempts to delegitimize the thousands of comments that were made. Again, not a peep of concern about that. 2. There's a great tool called "Google" that allows one to research past discussions of "capture" at ICANN, demonstrating that it has always been a legitimate topic that can be raised. Here are some examples to show that my statements are not out of line (not in any order): a) https://www.icann.org/en/system/files/files/report-comments-atlarge-review-d... In a review of the At-Large itself, comments by the Registry Stakeholder Group (RySG) regarding capture: "While we believe the structural changes proposed by ITEMS will help to improve the quality and representativeness of At-Large advice, we remain skeptical that representation by a few users is the best way to fully capture the user voice. Considering the diversity and breadth of user perspectives and ****pervasive concerns about the motivations of and potential capture by At-Large leaders*****, a more informative approach could be to carry out both quantitative and qualitative user studies about the impact of policies and other proposals and developments on Internet users." (page 40, emphasis added) "Pervasive concerns and motivations of and potential capture by At-Large leaders" -- that's permitted topic for discussion. Later in the same document, also by the RySG: "Carrying out quantitative and qualitative user studies1 on the impact of policies and other proposals and developments on Internet users would be effective way to deal with the breadth and diversity of user perspectives and balance ****ongoing concerns about the motivations of, and potential capture by, At-Large leaders.****" Again, "ongoing concerns about the motivations of, and potential capture by, At-Large leaders" is a legitimate topic for discussion within ICANN. b) The CCWG-Accountability report at: https://www.icann.org/en/system/files/files/ccwg-acct-ws2-draft-recs-improve... "The new Bylaws tasked the CCWG-Accountability WS2 to: “review and develop ... recommendations on SO/AC accountability, including but not limited to improved processes for accountability, transparency, and participation that are helpful to prevent capture”" (page 4) c) By Greg Shatan himself: https://community.icann.org/download/attachments/52892329/Transcript%20Clien... Greg Shatan: "…It’s one of the - I wouldn’t say it’s a bogeyman because there are ****legitimate concerns about capture****. But it’s - it gets thrown around a fair amount and it’s definitely - while it can’t be ignored it’s also - it’s important to try to dig down and do exactly what you do, which is to say, “What are you - what concerns are you actually expressing when you talk about capture?” (page 8, and elsewhere too; emphasis added) d) https://www.icann.org/public-comments/soac-accountability-2017-04-14-en "(iii) Supporting Organization and Advisory Committee accountability, including but not limited to improved processes for accountability, transparency, and participation that are ****helpful to prevent capture*****; This Bylaws mandate for this project specifically mention capture, a concern raised by NTIA in Stress Tests 32-34, *****regarding internal capture by a subset of SO/AC members, and concern that incumbent members might exclude new entrants to an SO/AC.****" (emphasis added) e) https://meetings.icann.org/en/dublin54/schedule/tue-ipc/transcript-ipc-20oct... Kiran Malancharuvil (of the IP Constituency): "…So, but that group, it does make me sad because we - and this maybe a dangerous thing to say in an open meeting, but whatever. It's a really good example of capture in the ICANN community I think. I think that the privacy interests have captured and refused to compromise. I think that the Registrars and the self-interested service providers have captured that group." (pp. 40-41) Greg Shatan was even on that call, and wasn't perturbed at the discussion of capture. Immediately after Kiran spoke, Greg said: "Kiran, there are others. Do you have any idea about solutions to this problem more concretely?" Then Kiran even went further: "And everybody talks about capture at ICANN as if the business interests are the ones capturing the groups, and it's absolutely not the case. And the Privacy interests actually now are starting to the capture the Public Safety Working Group which is the Law Enforcement Group." (p. 42) Again, a legitimate topic of discussion within ICANN. f) https://meetings.icann.org/en/dublin54/schedule/mon-ccwg-accountability/tran... "ANNE AIKMAN-SCALESE: Is this thing on? Can you hear me? Okay. Just three quick points. I think that ****there's been a lot of concern expressed about capture and not keeping things open to capture.**** And from my standpoint if one SO or AC can completely dictate the nuclear option, the use thereof or no use thereof, that would be a capture situation. So if only one can completely block, that's capture. That would mean one SO or AC can capture. So I agree with the way it's formulated now." (page 81, emphasis added) g) https://gnso.icann.org/sites/default/files/file/field-file-attach/transcript... Phil Corwin of Verisign: "Good morning. Phil Corwin. My group, and we had some participation, not a great deal of people involved, was on the question of capture. So I'll of course working group recommendations are subject to challenge as representing ****captured by a single constituency or a single interest and that's why capture should be avoided***** because consensus recommendations of a working group should represent consensus of a fairly board cross-section of the ICANN community, and not simply people from this constituency or that stakeholder group, or this particular economic interest. I'm going to speaking to this, I can't help but think in the context of a working group I'm co-chairing but I'm not going to refer to that specifically. I think you could have two types of capture. One, you could have a working group, which is just the only participants for whatever reason are from a single group, however you define it, and you can't get other people to participate. And I'm not sure what can be done at that point other than trying to encourage others to join in or to disband the group because you know that it's quite likely to have a single point of view and be subject to challenge, and why go through the exercise. The situation I've been dealing with is different. You have a -- it's basically ****what I call operational capture where you have a small group representing a single interest and single point of view who are the most active members of the working group.****" (pp. 24-25, emphasis added; discussion is even longer, than this) h) https://archive.icann.org/meetings/singapore2015/en/schedule/tue-csg/transcr... Elisa Cooper: "Yeah, so, you know, that’s an - if they ask us about that, that’s an opportunity for us. Our explanation was actually quite lengthy and I wanted to keep this to one slide. But it’s risks to coming from marginalized groups. It’s similar to some of these other ones that are out there. ****It’s risk of capture****. It’s risk of over representation by governments. There’s a whole category of items that we think pose potential risk to the multistakeholder model." (pp. 3-4, emphasis added) i) https://www.icann.org/news/announcement-2003-01-09-en "Among the reforms is fresh thinking on how to bring the voices of individual users and registrants into the decision process. An At-Large Advisory Committee is being formed to channel the thinking of users around the world. Last March, the ICANN Board decided that, at this time, online elections of directors is an expensive process too fraught with dangers of capture and fraud, and more effective means of bringing users to the ICANN table needed to be found. "ALAC," added Lynn, "will help bring this about." That was an interesting one. Concerns about capture of online elections for ICANN directors, which then led to the creation of ALAC! j) https://gnso.icann.org/sites/default/files/filefield_4878/transcript-09dec08... Danny Younger: "…The second, more urgent question that I've got is on the topic of capture. ****I'm one of many that views ICANN as having been captured by the contracted parties.**** I see multiple regional registry/registrar gatherings funded every year by ICANN with no equivalent for non- contracted parties whatsoever. Has the committee started thinking about recommendations to deal with the internal capture issue?" (emphasis added) and later: Marilyn Cade: "…Today ****I do think we have been captured by the contracted parties****, but I believe that we can overcome that and I believe that that is in the best interest of the contract parties as well." (emphasis added) Normally 10 examples would be more than enough, but I couldn't resist an 11th: k) https://www.icann.org/en/system/files/correspondence/badiei-to-chalaby-22may...

From NCSG:

"At-Large must develop a robust conflict of interest policy, in particular for their leadership. It is no easy task to represent the interests of the Internet’s over 3 billion end users. However, if At-Large is going to play this function effectively in the multistakeholder process, it is critical to consider their role as being distinct from that of other stakeholder groups at ICANN. ****At-Large should develop a conflict of interest policy to facilitate this distinction, and to avoid capture by interests whose goals may not be in line with those of end-users***** more generally such as, for example, governments and businesses. Although governments and businesses are, of course, end users in their own right, they also have dedicated stakeholder groups in which their interests are represented. Moreover, governments and some business sectors may have interests which are directly divergent from those of the vast majority of Internet users. ****In order to protect the integrity of ALAC, it is important to develop a conflict of interest policy which prevents membership by persons who are closely tied to these other groups.*****" (page 4) There are obviously many more examples, but I'll stop at 11. It should be abundantly clear that discussion of capture has been and is an entirely legitimate topic at ICANN. 3. If one returns to my actual email: https://mm.icann.org/pipermail/cpwg/2019-April/001149.html it mentioned capture twice: a) "Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts." and b) "The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users." The 2nd one is a supporting statement for the first, and literally quotes a statement from Greg Shatan's own draft: https://mm.icann.org/pipermail/cpwg/2019-April/001136.html "Many At-Large Structures are also ISOC Chapters, further demonstrating the commonality of interests." That's a direct conflict of interest in my view, an entirely legitimate concern to raise, as per the many citations pointed to above. 4. Look at the actual history of this matter. At the last meeting, it was decided that At-Large would not be making a statement. What "new information" exists since that decision, to justify change? There is none, other than the fact that thousands of others have made comments, and so presumably some of ISOC's friends and/or allies feel the need to help ISOC. That's not a good justification at all. Remember, Jonathan even wrote on Friday: https://mm.icann.org/pipermail/cpwg/2019-April/001099.html "Let's table this discussion until we can have a more thorough exploration of the issues. Email is a terrible way in which to have such a discussion. " But then some people ignored that, wanting to relitigate a decided issue. And, many of those people were present at last week's meeting too, so they already had their chance. Again, what new information did they have? None. Did Jonathan rebuke them for not tabling the discussion? Nope. Indeed, look at Greg Shatan's email at: https://mm.icann.org/pipermail/cpwg/2019-April/001094.html "I believe that PIR was hoping for a comment along the lines of our first draft (which I believe they saw on our site) or our second draft." That is again entirely consistent with capture. 5. It's obvious that many folks have some past or present connection to ISOC or one of its chapters, or perhaps even aspirational future connections with them. e.g. Greg Shatan's is obvious, via the NYC chapter of ISOC. Maureen Hilyard's SOI: https://community.icann.org/display/atlarge/Maureen+Hilyard+SOI mentions the "Pacific Islands Chapter of the Internet Society" Marita Moll has a history with the Canadian chapter: http://www.maritamoll.ca/content/about-site Cheryl Landon-Orr's SOI: https://community.icann.org/display/atlarge/Cheryl+Langdon-Orr+SOI mentions "Internet Australia (IA) formally known as the Internet Society of Australia ( ISOC-AU)" John Laprise's LinkedIn profile: https://www.linkedin.com/in/jplaprise mentions "cofounding Qatar's Internet Society chapter" as well as "Faculty" of Internet Society in May 2014. I think I've made my point. 6. Let's take a look at Jonathan Zuck himself. Jonathan has 2 SOIs that I could find at ICANN, one for the At Large and one for the GNSO: https://community.icann.org/display/atlarge/Jonathan+Zuck+SOI https://community.icann.org/display/gnsosoi/Jonathan+Zuck+SOI One thing that you won't find mentioned in those SOIs is the history of Jonathan's involvement with Netchoice, as documented by their Form 990 statements: http://foundationcenter.org/find-funding/990-finder http://990finder.foundationcenter.org/990results.aspx?990_type=&fn=netchoice... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... Page 7 of each Form 990 lists Jonathan Zuck as a director of Netchoice, an organization where Verisign is a member. https://netchoice.org/ And of course Verisign desires fee increases too. Indeed, one of the drafters of the Business Constituency's statement in support of fee increases was Steve DelBianco, of Netchoice: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003085.ht... [another drafter of that statement was Andrew Mack, who even has PIR/ISOC as a client, see: https://www.amglobal.com/clients ] And one is trying to assert that "capture" is somehow an inappropriate topic for discussion, given all of the above? I don't agree. 7. Let's not forget about Greg's email at: https://mm.icann.org/pipermail/cpwg/2019-April/001162.html where he is either unaware of or ignores relevant facts, such as: a) I *personally* raised awareness to many .org/info/biz/asia registrants via Slashdot (as well as via my blog and Twitter), see: https://tech.slashdot.org/story/19/04/23/2330210/icann-proposes-allowing-unl... Take a look at the date of that -- it's *before* our last meeting, linking again to a post by Nat Cohen at CircleID *before* our last meeting. On Slashdot, it generated 82 comments, and I didn't link to any form (neither did Nat Cohen via CircleID): http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminati... Take a look at the number of pageviews of the CircleID article -- 35,257 (at the time of this email), which is far above any other recent post: http://www.circleid.com/ (most CircleID articles get 1,000 to 2,000 views) Back in 2006, a similar Slashdot article also vent viral: https://slashdot.org/story/06/08/25/0611209/icann-oks-tiered-pricing-for-org... linking to my CircleID post that generate 76,707 views: http://www.circleid.com/posts/icann_tiered_pricing_tld_biz_info_org_domain/ (and more than a thousand public comments opposing the proposed contracts) There was no "campaign". Individuals simply got interested in an important issue. b) NameCheap themselves blogged about it, *and* sent emails to all their own customers, thus generating many comments, both via the ICA form (which they linked to), and original creations. They certainly have a right to raise awareness. And then those clients also went to social media, to encourage public comment. For example, I don't know Quincy Larson personally, but take a look at his Twitter feed: https://twitter.com/ossia He's involved with FreeCodeCamp.org, and has more than 77,000 followers. His tweet at: https://twitter.com/ossia/status/1121778165406265346 has 322 retweets, and 365 likes, implying it received huge coverage and clicks, raising awareness. And if you look at the WHOIS for FreeCodeCamp.org: http://whois.domaintools.com/freecodecamp.org it's registered at NameCheap, where he presumably learned about the issue. c) While many have been focused on .org, consider the number of public comments re: .info: https://mm.icann.org/pipermail/comments-info-renewal-18mar19/2019q2/date.htm... 250 at the time of this post. Or for .biz: https://mm.icann.org/pipermail/comments-biz-renewal-03apr19/2019q2/date.html 169 at the time of this post. [The .asia archives appear to be broken, haven't been updated in a week, and haven't even posted my own submission yet, so those 6 comments aren't informative] Given the relative size of .org vs. .biz and .info, one would easily have expected more than 1000 comments for .org. d) Even the BBC reported about the issue, further raising awareness. e) Some very large non-profits and organizations representing non-profits made substantial comments: (i) NPR, YMCA, C-SPAN, National Geographic Society, AARP, The Conservation Fund, Oceana, and National Trust for Historic Preservation https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003179.ht... (ii) National Council of Nonprofits https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/000918.ht... (iii) ASAE https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/002154.ht... f) Where are all the public comments from At-Large structures or individuals of this CPWG? We agreed last week that folks should submit individual comments, but where are they? I submitted one, of course. Where are comments from ALSes? Where's any outreach to those ALSes? All the entities that At Large purports to represent --- where are their comments? Doesn't At Large do any outreach or education? Instead, we have a small number of people pushing for an At Large statement at this late date (despite last week's call), one that is rather extreme and illogical, inconsistent with those who've made comments already. It doesn't represent the views of billions of users, nor should it pretend to. It's reactionary, reacting to a perceived desire from PIR/ISOC to have their views (which are self-serving views) put forth at ICANN. That's the very essence of capture. Go back to Greg's email: https://mm.icann.org/pipermail/cpwg/2019-April/001094.html "I believe that PIR was hoping for a comment along the lines of our first draft (which I believe they saw on our site) or our second draft." 8. I feel so strongly about this issue, that if At Large does issue a statement that demonstrates capture, I will definitely cease my involvement with At Large and CPWG. Such a statement would undermine At Large's integrity and reputation. I will not waste my time providing input and analysis that will be ignored, if At Large demonstrates it has been captured. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ On Tue, Apr 30, 2019 at 6:59 PM Jonathan Zuck <JZuck@innovatorsnetwork.org> wrote:

George, Your comments about Greg somehow "capturing" the At-large (on whose behalf I wonder) are disingenuous given the campaign. In which you are engaged and insulting to everyone on this list attempting to get a handle on a complex and highly political issue. I suggest you withdraw them. Thanks. Jonathan

Jonathan Zuck Executive Director Innovators Network Foundation www.Innovatorsnetwork.org

________________________________ From: GTLD-WG <gtld-wg-bounces@atlarge-lists.icann.org> on behalf of George Kirikos <icann@leap.com> Sent: Tuesday, April 30, 2019 7:51:47 AM To: CPWG Subject: Re: [GTLD-WG] [CPWG] Further Revised Draft Statement on .ORG Renewal

For the record, I disagree with the statement that Greg prepared, and it doesn't reflect my views (which I linked to in an earlier post). It doesn't even reflect the views expressed by many non-profits who made public comments, including NPR and other high profile ones:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003179.ht...

or the Non-Commercial Stakeholders:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003207.ht...

If folks wanted to send a letter, they should have sent it in an individual capacity, rather than pretend that this statement is reflective of the views of billions of internet users. Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts.

ISOC/PIR is just one of many non-profits, and its mission is no better than any other. Every organization has unlimited wants, but needs to work within a reasonable budget. ISOC/PIR doesn't own .org, and shouldn't pretend it does via unlimited "rent" or taxes payable to it. They'll always be able to spend as much money as they can take in. As I noted in my own comments, nothing would stop ISOC/PIR from selling out to private equity, who could then take the heat for huge price increases, while ISOC/PIR walks away with an enormous multi-billion dollar endowment fund.

The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users.

The base agreement for new gTLDs is different from that of legacy gTLDs for good reason, and should not be adopted by legacy gTLDs which predate ICANN itself, and whose registrants do not agree with unlimited fee increases. That's changing the rules in the middle of the game (whereas registrants of new gTLDs knew all along the risks they take registering with new gTLDs, where the registry essentially "owns" that TLD).

The letter quotes Jonathan Zuck's statement about the "desirability" of higher prices almost verbatim, but hasn't done the same for others in the CPWG. Higher prices are not desirable in any way, except by some twisted logic that makes no economic sense (my own personal background is in economics and finance). New entrants always knew that legacy gTLDs had capped prices, before they entered the space. Furthermore, competition generally leads to *lower* prices, not higher prices!

Attempting to argue that capped fees contribute to confusion, phising, fraud and abuse is truly a stretch. The most abused TLDs are the new gTLDs, not the legacy ones, e.g. see:

https://www.spamhaus.org/statistics/tlds/

If one wants to target phishing, fraud and other abuses, one needs to actually *target* it using effective tools. Raising prices for *everyone* is not an effective tool, as it has more collateral damage than actual benefits. If 1%, for example, of domains are engaged in abused, it makes no sense to raise costs on 100% of registrants. One wants to raise costs only on those engaged in abuse (e.g. through high penalties for abuse, like jailtime, fines, etc.). Raising prices for *everyone* simply enriches the registry, at the expense of the public.

Pretending that an "economic study" will be helpful is absurd, as ICANN has in the past commissioned "experts" who simply regurgitated whatever ICANN wanted them to say. Recall that these so-called "experts" (the Carlton report, etc.) were used to justify the new gTLD program in the first place, which has been a failure. Here's a comment from K. Claffy, which talked about those reports:

https://forum.icann.org/lists/economic-framework/msg00004.html

which also referenced my scathing comments about them at the time (which proved prescient). She concluded her comments with:

"Similar to my observations of what's happening in the security and stability discussion of root scaling, ICANN's behavior looks like it's trying to buy rubberstamps of its current plans from commercial consultants, rather than foster what is needed in the long term: a coherent field of objective, peer-reviewed technical, policy, and economic research on Internet naming and numbering, and incentivized data-sharing to support such research."

The ICANN contracts do not have any mechanism to "undo" the changes. Once the caps are removed, that genie cannot be put back in the bottle. One should do an economic study *before* lifting any price caps, rather than doing them after the horse has left the barn, and after the damage has already been done.

What "problem" is this contract actually trying to solve? If it's not broken (and legacy gTLDs are successful, obviously), one should stick with the status quo. If new gTLDs are the "broken" thing, they can be fixed directly (by adding fee caps, just like the successful legacy gTLDs, or making other changes).

In conclusion, Greg, Jonathan, and others should have simply submitted their own personal comments, rather than try to suggest that this statement is reflective of billions of users.

Sincerely,

George Kirikos 416-588-0269 http://www.leap.com/

On Tue, Apr 30, 2019 at 2:14 AM Greg Shatan <greg@isoc-ny.org> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY "The Internet is for everyone" _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ GTLD-WG mailing list GTLD-WG@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg

Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs

Hi George, On a personal note: You took the time to look at my LinkedIn profile in citing it but neglected to notice or mention that I don't work in the Internet industry. I also happen to expend paid vacation days to work at ICANN meetings as an ALAC member. I have been interested in the Internet for a long time. https://global.asc.upenn.edu/internet-governance-the-new-great-game/ My 1993 MA thesis dealt with cyberwarfare. https://ieeexplore.ieee.org/document/1452713 I deeply care about the Internet around the world and am all too aware of capture; by government and industry having been a telecom sector analyst in the US. I find the suggestion that I'm a party to the capture you fear to be insulting and derogatory and not in the spirit of the ICANN community and certainly not of At Large. The Ombudsman should view this email as a formal complaint against you for violating ICANN community standards. Best regards, John Laprise -----Original Message----- From: CPWG <cpwg-bounces@icann.org> On Behalf Of George Kirikos Sent: Wednesday, May 1, 2019 11:44 AM To: CPWG <cpwg@icann.org> Cc: ICANN At-Large Staff <staff@atlarge.icann.org> Subject: [CPWG] Discussion of Capture is and always has been a legitimate topic at ICANN (was Re: ICANN Code of Conduct) Jonathan, I find your email: https://mm.icann.org/pipermail/cpwg/2019-April/001168.html which was in response to my email at: https://mm.icann.org/pipermail/cpwg/2019-April/001149.html which was responding to Greg's email at: https://mm.icann.org/pipermail/cpwg/2019-April/001136.html to be quite bizarre. Discussion of capture is and always has been a legitimate topic at ICANN. 1. Before going into the substance, there appears to be a double standard here, where you state my comments are "disingenuous" and refer to some "campaign". Calling someone "disingenuous" isn't nice or respectful. The "campaign" presumably refers to Greg Shatan's statement at: https://mm.icann.org/pipermail/cpwg/2019-April/001162.html where wild accusations of a "well-orchestrated campaign" are made, and pointing to just one "lobby group", the Internet Commerce Association as behind it. Again, not nice words (and which I'll discuss further below), but not a peep when those statements are made (which you presumably share, given you refer to "the campaign"). Greg Shatan's entire email disrespects and attempts to delegitimize the thousands of comments that were made. Again, not a peep of concern about that. 2. There's a great tool called "Google" that allows one to research past discussions of "capture" at ICANN, demonstrating that it has always been a legitimate topic that can be raised. Here are some examples to show that my statements are not out of line (not in any order): a) https://www.icann.org/en/system/files/files/report-comments-atlarge-review-d... In a review of the At-Large itself, comments by the Registry Stakeholder Group (RySG) regarding capture: "While we believe the structural changes proposed by ITEMS will help to improve the quality and representativeness of At-Large advice, we remain skeptical that representation by a few users is the best way to fully capture the user voice. Considering the diversity and breadth of user perspectives and ****pervasive concerns about the motivations of and potential capture by At-Large leaders*****, a more informative approach could be to carry out both quantitative and qualitative user studies about the impact of policies and other proposals and developments on Internet users." (page 40, emphasis added) "Pervasive concerns and motivations of and potential capture by At-Large leaders" -- that's permitted topic for discussion. Later in the same document, also by the RySG: "Carrying out quantitative and qualitative user studies1 on the impact of policies and other proposals and developments on Internet users would be effective way to deal with the breadth and diversity of user perspectives and balance ****ongoing concerns about the motivations of, and potential capture by, At-Large leaders.****" Again, "ongoing concerns about the motivations of, and potential capture by, At-Large leaders" is a legitimate topic for discussion within ICANN. b) The CCWG-Accountability report at: https://www.icann.org/en/system/files/files/ccwg-acct-ws2-draft-recs-improve... "The new Bylaws tasked the CCWG-Accountability WS2 to: “review and develop ... recommendations on SO/AC accountability, including but not limited to improved processes for accountability, transparency, and participation that are helpful to prevent capture”" (page 4) c) By Greg Shatan himself: https://community.icann.org/download/attachments/52892329/Transcript%20Clien... Greg Shatan: "…It’s one of the - I wouldn’t say it’s a bogeyman because there are ****legitimate concerns about capture****. But it’s - it gets thrown around a fair amount and it’s definitely - while it can’t be ignored it’s also - it’s important to try to dig down and do exactly what you do, which is to say, “What are you - what concerns are you actually expressing when you talk about capture?” (page 8, and elsewhere too; emphasis added) d) https://www.icann.org/public-comments/soac-accountability-2017-04-14-en "(iii) Supporting Organization and Advisory Committee accountability, including but not limited to improved processes for accountability, transparency, and participation that are ****helpful to prevent capture*****; This Bylaws mandate for this project specifically mention capture, a concern raised by NTIA in Stress Tests 32-34, *****regarding internal capture by a subset of SO/AC members, and concern that incumbent members might exclude new entrants to an SO/AC.****" (emphasis added) e) https://meetings.icann.org/en/dublin54/schedule/tue-ipc/transcript-ipc-20oct... Kiran Malancharuvil (of the IP Constituency): "…So, but that group, it does make me sad because we - and this maybe a dangerous thing to say in an open meeting, but whatever. It's a really good example of capture in the ICANN community I think. I think that the privacy interests have captured and refused to compromise. I think that the Registrars and the self-interested service providers have captured that group." (pp. 40-41) Greg Shatan was even on that call, and wasn't perturbed at the discussion of capture. Immediately after Kiran spoke, Greg said: "Kiran, there are others. Do you have any idea about solutions to this problem more concretely?" Then Kiran even went further: "And everybody talks about capture at ICANN as if the business interests are the ones capturing the groups, and it's absolutely not the case. And the Privacy interests actually now are starting to the capture the Public Safety Working Group which is the Law Enforcement Group." (p. 42) Again, a legitimate topic of discussion within ICANN. f) https://meetings.icann.org/en/dublin54/schedule/mon-ccwg-accountability/tran... "ANNE AIKMAN-SCALESE: Is this thing on? Can you hear me? Okay. Just three quick points. I think that ****there's been a lot of concern expressed about capture and not keeping things open to capture.**** And from my standpoint if one SO or AC can completely dictate the nuclear option, the use thereof or no use thereof, that would be a capture situation. So if only one can completely block, that's capture. That would mean one SO or AC can capture. So I agree with the way it's formulated now." (page 81, emphasis added) g) https://gnso.icann.org/sites/default/files/file/field-file-attach/transcript... Phil Corwin of Verisign: "Good morning. Phil Corwin. My group, and we had some participation, not a great deal of people involved, was on the question of capture. So I'll of course working group recommendations are subject to challenge as representing ****captured by a single constituency or a single interest and that's why capture should be avoided***** because consensus recommendations of a working group should represent consensus of a fairly board cross-section of the ICANN community, and not simply people from this constituency or that stakeholder group, or this particular economic interest. I'm going to speaking to this, I can't help but think in the context of a working group I'm co-chairing but I'm not going to refer to that specifically. I think you could have two types of capture. One, you could have a working group, which is just the only participants for whatever reason are from a single group, however you define it, and you can't get other people to participate. And I'm not sure what can be done at that point other than trying to encourage others to join in or to disband the group because you know that it's quite likely to have a single point of view and be subject to challenge, and why go through the exercise. The situation I've been dealing with is different. You have a -- it's basically ****what I call operational capture where you have a small group representing a single interest and single point of view who are the most active members of the working group.****" (pp. 24-25, emphasis added; discussion is even longer, than this) h) https://archive.icann.org/meetings/singapore2015/en/schedule/tue-csg/transcr... Elisa Cooper: "Yeah, so, you know, that’s an - if they ask us about that, that’s an opportunity for us. Our explanation was actually quite lengthy and I wanted to keep this to one slide. But it’s risks to coming from marginalized groups. It’s similar to some of these other ones that are out there. ****It’s risk of capture****. It’s risk of over representation by governments. There’s a whole category of items that we think pose potential risk to the multistakeholder model." (pp. 3-4, emphasis added) i) https://www.icann.org/news/announcement-2003-01-09-en "Among the reforms is fresh thinking on how to bring the voices of individual users and registrants into the decision process. An At-Large Advisory Committee is being formed to channel the thinking of users around the world. Last March, the ICANN Board decided that, at this time, online elections of directors is an expensive process too fraught with dangers of capture and fraud, and more effective means of bringing users to the ICANN table needed to be found. "ALAC," added Lynn, "will help bring this about." That was an interesting one. Concerns about capture of online elections for ICANN directors, which then led to the creation of ALAC! j) https://gnso.icann.org/sites/default/files/filefield_4878/transcript-09dec08... Danny Younger: "…The second, more urgent question that I've got is on the topic of capture. ****I'm one of many that views ICANN as having been captured by the contracted parties.**** I see multiple regional registry/registrar gatherings funded every year by ICANN with no equivalent for non- contracted parties whatsoever. Has the committee started thinking about recommendations to deal with the internal capture issue?" (emphasis added) and later: Marilyn Cade: "…Today ****I do think we have been captured by the contracted parties****, but I believe that we can overcome that and I believe that that is in the best interest of the contract parties as well." (emphasis added) Normally 10 examples would be more than enough, but I couldn't resist an 11th: k) https://www.icann.org/en/system/files/correspondence/badiei-to-chalaby-22may...

From NCSG:

"At-Large must develop a robust conflict of interest policy, in particular for their leadership. It is no easy task to represent the interests of the Internet’s over 3 billion end users. However, if At-Large is going to play this function effectively in the multistakeholder process, it is critical to consider their role as being distinct from that of other stakeholder groups at ICANN. ****At-Large should develop a conflict of interest policy to facilitate this distinction, and to avoid capture by interests whose goals may not be in line with those of end-users***** more generally such as, for example, governments and businesses. Although governments and businesses are, of course, end users in their own right, they also have dedicated stakeholder groups in which their interests are represented. Moreover, governments and some business sectors may have interests which are directly divergent from those of the vast majority of Internet users. ****In order to protect the integrity of ALAC, it is important to develop a conflict of interest policy which prevents membership by persons who are closely tied to these other groups.*****" (page 4) There are obviously many more examples, but I'll stop at 11. It should be abundantly clear that discussion of capture has been and is an entirely legitimate topic at ICANN. 3. If one returns to my actual email: https://mm.icann.org/pipermail/cpwg/2019-April/001149.html it mentioned capture twice: a) "Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts." and b) "The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users." The 2nd one is a supporting statement for the first, and literally quotes a statement from Greg Shatan's own draft: https://mm.icann.org/pipermail/cpwg/2019-April/001136.html "Many At-Large Structures are also ISOC Chapters, further demonstrating the commonality of interests." That's a direct conflict of interest in my view, an entirely legitimate concern to raise, as per the many citations pointed to above. 4. Look at the actual history of this matter. At the last meeting, it was decided that At-Large would not be making a statement. What "new information" exists since that decision, to justify change? There is none, other than the fact that thousands of others have made comments, and so presumably some of ISOC's friends and/or allies feel the need to help ISOC. That's not a good justification at all. Remember, Jonathan even wrote on Friday: https://mm.icann.org/pipermail/cpwg/2019-April/001099.html "Let's table this discussion until we can have a more thorough exploration of the issues. Email is a terrible way in which to have such a discussion. " But then some people ignored that, wanting to relitigate a decided issue. And, many of those people were present at last week's meeting too, so they already had their chance. Again, what new information did they have? None. Did Jonathan rebuke them for not tabling the discussion? Nope. Indeed, look at Greg Shatan's email at: https://mm.icann.org/pipermail/cpwg/2019-April/001094.html "I believe that PIR was hoping for a comment along the lines of our first draft (which I believe they saw on our site) or our second draft." That is again entirely consistent with capture. 5. It's obvious that many folks have some past or present connection to ISOC or one of its chapters, or perhaps even aspirational future connections with them. e.g. Greg Shatan's is obvious, via the NYC chapter of ISOC. Maureen Hilyard's SOI: https://community.icann.org/display/atlarge/Maureen+Hilyard+SOI mentions the "Pacific Islands Chapter of the Internet Society" Marita Moll has a history with the Canadian chapter: http://www.maritamoll.ca/content/about-site Cheryl Landon-Orr's SOI: https://community.icann.org/display/atlarge/Cheryl+Langdon-Orr+SOI mentions "Internet Australia (IA) formally known as the Internet Society of Australia ( ISOC-AU)" John Laprise's LinkedIn profile: https://www.linkedin.com/in/jplaprise mentions "cofounding Qatar's Internet Society chapter" as well as "Faculty" of Internet Society in May 2014. I think I've made my point. 6. Let's take a look at Jonathan Zuck himself. Jonathan has 2 SOIs that I could find at ICANN, one for the At Large and one for the GNSO: https://community.icann.org/display/atlarge/Jonathan+Zuck+SOI https://community.icann.org/display/gnsosoi/Jonathan+Zuck+SOI One thing that you won't find mentioned in those SOIs is the history of Jonathan's involvement with Netchoice, as documented by their Form 990 statements: http://foundationcenter.org/find-funding/990-finder http://990finder.foundationcenter.org/990results.aspx?990_type=&fn=netchoice... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... Page 7 of each Form 990 lists Jonathan Zuck as a director of Netchoice, an organization where Verisign is a member. https://netchoice.org/ And of course Verisign desires fee increases too. Indeed, one of the drafters of the Business Constituency's statement in support of fee increases was Steve DelBianco, of Netchoice: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003085.ht... [another drafter of that statement was Andrew Mack, who even has PIR/ISOC as a client, see: https://www.amglobal.com/clients ] And one is trying to assert that "capture" is somehow an inappropriate topic for discussion, given all of the above? I don't agree. 7. Let's not forget about Greg's email at: https://mm.icann.org/pipermail/cpwg/2019-April/001162.html where he is either unaware of or ignores relevant facts, such as: a) I *personally* raised awareness to many .org/info/biz/asia registrants via Slashdot (as well as via my blog and Twitter), see: https://tech.slashdot.org/story/19/04/23/2330210/icann-proposes-allowing-unl... Take a look at the date of that -- it's *before* our last meeting, linking again to a post by Nat Cohen at CircleID *before* our last meeting. On Slashdot, it generated 82 comments, and I didn't link to any form (neither did Nat Cohen via CircleID): http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminati... Take a look at the number of pageviews of the CircleID article -- 35,257 (at the time of this email), which is far above any other recent post: http://www.circleid.com/ (most CircleID articles get 1,000 to 2,000 views) Back in 2006, a similar Slashdot article also vent viral: https://slashdot.org/story/06/08/25/0611209/icann-oks-tiered-pricing-for-org... linking to my CircleID post that generate 76,707 views: http://www.circleid.com/posts/icann_tiered_pricing_tld_biz_info_org_domain/ (and more than a thousand public comments opposing the proposed contracts) There was no "campaign". Individuals simply got interested in an important issue. b) NameCheap themselves blogged about it, *and* sent emails to all their own customers, thus generating many comments, both via the ICA form (which they linked to), and original creations. They certainly have a right to raise awareness. And then those clients also went to social media, to encourage public comment. For example, I don't know Quincy Larson personally, but take a look at his Twitter feed: https://twitter.com/ossia He's involved with FreeCodeCamp.org, and has more than 77,000 followers. His tweet at: https://twitter.com/ossia/status/1121778165406265346 has 322 retweets, and 365 likes, implying it received huge coverage and clicks, raising awareness. And if you look at the WHOIS for FreeCodeCamp.org: http://whois.domaintools.com/freecodecamp.org it's registered at NameCheap, where he presumably learned about the issue. c) While many have been focused on .org, consider the number of public comments re: .info: https://mm.icann.org/pipermail/comments-info-renewal-18mar19/2019q2/date.htm... 250 at the time of this post. Or for .biz: https://mm.icann.org/pipermail/comments-biz-renewal-03apr19/2019q2/date.html 169 at the time of this post. [The .asia archives appear to be broken, haven't been updated in a week, and haven't even posted my own submission yet, so those 6 comments aren't informative] Given the relative size of .org vs. .biz and .info, one would easily have expected more than 1000 comments for .org. d) Even the BBC reported about the issue, further raising awareness. e) Some very large non-profits and organizations representing non-profits made substantial comments: (i) NPR, YMCA, C-SPAN, National Geographic Society, AARP, The Conservation Fund, Oceana, and National Trust for Historic Preservation https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003179.ht... (ii) National Council of Nonprofits https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/000918.ht... (iii) ASAE https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/002154.ht... f) Where are all the public comments from At-Large structures or individuals of this CPWG? We agreed last week that folks should submit individual comments, but where are they? I submitted one, of course. Where are comments from ALSes? Where's any outreach to those ALSes? All the entities that At Large purports to represent --- where are their comments? Doesn't At Large do any outreach or education? Instead, we have a small number of people pushing for an At Large statement at this late date (despite last week's call), one that is rather extreme and illogical, inconsistent with those who've made comments already. It doesn't represent the views of billions of users, nor should it pretend to. It's reactionary, reacting to a perceived desire from PIR/ISOC to have their views (which are self-serving views) put forth at ICANN. That's the very essence of capture. Go back to Greg's email: https://mm.icann.org/pipermail/cpwg/2019-April/001094.html "I believe that PIR was hoping for a comment along the lines of our first draft (which I believe they saw on our site) or our second draft." 8. I feel so strongly about this issue, that if At Large does issue a statement that demonstrates capture, I will definitely cease my involvement with At Large and CPWG. Such a statement would undermine At Large's integrity and reputation. I will not waste my time providing input and analysis that will be ignored, if At Large demonstrates it has been captured. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ On Tue, Apr 30, 2019 at 6:59 PM Jonathan Zuck <JZuck@innovatorsnetwork.org> wrote:

George, Your comments about Greg somehow "capturing" the At-large (on whose behalf I wonder) are disingenuous given the campaign. In which you are engaged and insulting to everyone on this list attempting to get a handle on a complex and highly political issue. I suggest you withdraw them. Thanks. Jonathan

Jonathan Zuck Executive Director Innovators Network Foundation www.Innovatorsnetwork.org

________________________________ From: GTLD-WG <gtld-wg-bounces@atlarge-lists.icann.org> on behalf of George Kirikos <icann@leap.com> Sent: Tuesday, April 30, 2019 7:51:47 AM To: CPWG Subject: Re: [GTLD-WG] [CPWG] Further Revised Draft Statement on .ORG Renewal

For the record, I disagree with the statement that Greg prepared, and it doesn't reflect my views (which I linked to in an earlier post). It doesn't even reflect the views expressed by many non-profits who made public comments, including NPR and other high profile ones:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003 179.html

or the Non-Commercial Stakeholders:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003 207.html

If folks wanted to send a letter, they should have sent it in an individual capacity, rather than pretend that this statement is reflective of the views of billions of internet users. Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts.

ISOC/PIR is just one of many non-profits, and its mission is no better than any other. Every organization has unlimited wants, but needs to work within a reasonable budget. ISOC/PIR doesn't own .org, and shouldn't pretend it does via unlimited "rent" or taxes payable to it. They'll always be able to spend as much money as they can take in. As I noted in my own comments, nothing would stop ISOC/PIR from selling out to private equity, who could then take the heat for huge price increases, while ISOC/PIR walks away with an enormous multi-billion dollar endowment fund.

The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users.

The base agreement for new gTLDs is different from that of legacy gTLDs for good reason, and should not be adopted by legacy gTLDs which predate ICANN itself, and whose registrants do not agree with unlimited fee increases. That's changing the rules in the middle of the game (whereas registrants of new gTLDs knew all along the risks they take registering with new gTLDs, where the registry essentially "owns" that TLD).

The letter quotes Jonathan Zuck's statement about the "desirability" of higher prices almost verbatim, but hasn't done the same for others in the CPWG. Higher prices are not desirable in any way, except by some twisted logic that makes no economic sense (my own personal background is in economics and finance). New entrants always knew that legacy gTLDs had capped prices, before they entered the space. Furthermore, competition generally leads to *lower* prices, not higher prices!

Attempting to argue that capped fees contribute to confusion, phising, fraud and abuse is truly a stretch. The most abused TLDs are the new gTLDs, not the legacy ones, e.g. see:

https://www.spamhaus.org/statistics/tlds/

If one wants to target phishing, fraud and other abuses, one needs to actually *target* it using effective tools. Raising prices for *everyone* is not an effective tool, as it has more collateral damage than actual benefits. If 1%, for example, of domains are engaged in abused, it makes no sense to raise costs on 100% of registrants. One wants to raise costs only on those engaged in abuse (e.g. through high penalties for abuse, like jailtime, fines, etc.). Raising prices for *everyone* simply enriches the registry, at the expense of the public.

Pretending that an "economic study" will be helpful is absurd, as ICANN has in the past commissioned "experts" who simply regurgitated whatever ICANN wanted them to say. Recall that these so-called "experts" (the Carlton report, etc.) were used to justify the new gTLD program in the first place, which has been a failure. Here's a comment from K. Claffy, which talked about those reports:

https://forum.icann.org/lists/economic-framework/msg00004.html

which also referenced my scathing comments about them at the time (which proved prescient). She concluded her comments with:

"Similar to my observations of what's happening in the security and stability discussion of root scaling, ICANN's behavior looks like it's trying to buy rubberstamps of its current plans from commercial consultants, rather than foster what is needed in the long term: a coherent field of objective, peer-reviewed technical, policy, and economic research on Internet naming and numbering, and incentivized data-sharing to support such research."

The ICANN contracts do not have any mechanism to "undo" the changes. Once the caps are removed, that genie cannot be put back in the bottle. One should do an economic study *before* lifting any price caps, rather than doing them after the horse has left the barn, and after the damage has already been done.

What "problem" is this contract actually trying to solve? If it's not broken (and legacy gTLDs are successful, obviously), one should stick with the status quo. If new gTLDs are the "broken" thing, they can be fixed directly (by adding fee caps, just like the successful legacy gTLDs, or making other changes).

In conclusion, Greg, Jonathan, and others should have simply submitted their own personal comments, rather than try to suggest that this statement is reflective of billions of users.

Sincerely,

George Kirikos 416-588-0269 http://www.leap.com/

On Tue, Apr 30, 2019 at 2:14 AM Greg Shatan <greg@isoc-ny.org> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY "The Internet is for everyone" _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ GTLD-WG mailing list GTLD-WG@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg

Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

John: Point to me one thing I wrote about you that is false and I'd be happy to correct it. I quoted your own LinkedIn profile, *and* I linked directly to it, so folks could see for themselves the historical connection with Internet Society or its chapters, etc., like I did for others. Why don't you re-read the 11 examples I cited from within ICANN's own archives that demonstrate that discussions of capture are certainly not out of line. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ On Wed, May 1, 2019 at 1:21 PM John Laprise <jlaprise@gmail.com> wrote:

Hi George,

On a personal note:

You took the time to look at my LinkedIn profile in citing it but neglected to notice or mention that I don't work in the Internet industry. I also happen to expend paid vacation days to work at ICANN meetings as an ALAC member.

I have been interested in the Internet for a long time.

https://global.asc.upenn.edu/internet-governance-the-new-great-game/

My 1993 MA thesis dealt with cyberwarfare. https://ieeexplore.ieee.org/document/1452713

I deeply care about the Internet around the world and am all too aware of capture; by government and industry having been a telecom sector analyst in the US. I find the suggestion that I'm a party to the capture you fear to be insulting and derogatory and not in the spirit of the ICANN community and certainly not of At Large.

The Ombudsman should view this email as a formal complaint against you for violating ICANN community standards.

Best regards,

John Laprise

-----Original Message----- From: CPWG <cpwg-bounces@icann.org> On Behalf Of George Kirikos Sent: Wednesday, May 1, 2019 11:44 AM To: CPWG <cpwg@icann.org> Cc: ICANN At-Large Staff <staff@atlarge.icann.org> Subject: [CPWG] Discussion of Capture is and always has been a legitimate topic at ICANN (was Re: ICANN Code of Conduct)

Jonathan,

I find your email:

https://mm.icann.org/pipermail/cpwg/2019-April/001168.html

which was in response to my email at:

https://mm.icann.org/pipermail/cpwg/2019-April/001149.html

which was responding to Greg's email at:

https://mm.icann.org/pipermail/cpwg/2019-April/001136.html

to be quite bizarre. Discussion of capture is and always has been a legitimate topic at ICANN.

1. Before going into the substance, there appears to be a double standard here, where you state my comments are "disingenuous" and refer to some "campaign". Calling someone "disingenuous" isn't nice or respectful. The "campaign" presumably refers to Greg Shatan's statement at:

https://mm.icann.org/pipermail/cpwg/2019-April/001162.html

where wild accusations of a "well-orchestrated campaign" are made, and pointing to just one "lobby group", the Internet Commerce Association as behind it. Again, not nice words (and which I'll discuss further below), but not a peep when those statements are made (which you presumably share, given you refer to "the campaign"). Greg Shatan's entire email disrespects and attempts to delegitimize the thousands of comments that were made. Again, not a peep of concern about that.

2. There's a great tool called "Google" that allows one to research past discussions of "capture" at ICANN, demonstrating that it has always been a legitimate topic that can be raised. Here are some examples to show that my statements are not out of line (not in any order):

a) https://www.icann.org/en/system/files/files/report-comments-atlarge-review-d...

In a review of the At-Large itself, comments by the Registry Stakeholder Group (RySG) regarding capture:

"While we believe the structural changes proposed by ITEMS will help to improve the quality and representativeness of At-Large advice, we remain skeptical that representation by a few users is the best way to fully capture the user voice. Considering the diversity and breadth of user perspectives and ****pervasive concerns about the motivations of and potential capture by At-Large leaders*****, a more informative approach could be to carry out both quantitative and qualitative user studies about the impact of policies and other proposals and developments on Internet users." (page 40, emphasis added)

"Pervasive concerns and motivations of and potential capture by At-Large leaders" -- that's permitted topic for discussion.

Later in the same document, also by the RySG:

"Carrying out quantitative and qualitative user studies1 on the impact of policies and other proposals and developments on Internet users would be effective way to deal with the breadth and diversity of user perspectives and balance ****ongoing concerns about the motivations of, and potential capture by, At-Large leaders.****"

Again, "ongoing concerns about the motivations of, and potential capture by, At-Large leaders" is a legitimate topic for discussion within ICANN.

b) The CCWG-Accountability report at:

https://www.icann.org/en/system/files/files/ccwg-acct-ws2-draft-recs-improve...

"The new Bylaws tasked the CCWG-Accountability WS2 to: “review and develop ... recommendations on SO/AC accountability, including but not limited to improved processes for accountability, transparency, and participation that are helpful to prevent capture”" (page 4)

c) By Greg Shatan himself:

https://community.icann.org/download/attachments/52892329/Transcript%20Clien...

Greg Shatan: "…It’s one of the - I wouldn’t say it’s a bogeyman because there are ****legitimate concerns about capture****. But it’s - it gets thrown around a fair amount and it’s definitely - while it can’t be ignored it’s also - it’s important to try to dig down and do exactly what you do, which is to say, “What are you - what concerns are you actually expressing when you talk about capture?” (page 8, and elsewhere too; emphasis added)

d) https://www.icann.org/public-comments/soac-accountability-2017-04-14-en

"(iii) Supporting Organization and Advisory Committee accountability, including but not limited to improved processes for accountability, transparency, and participation that are ****helpful to prevent capture*****;

This Bylaws mandate for this project specifically mention capture, a concern raised by NTIA in Stress Tests 32-34, *****regarding internal capture by a subset of SO/AC members, and concern that incumbent members might exclude new entrants to an SO/AC.****" (emphasis added)

e) https://meetings.icann.org/en/dublin54/schedule/tue-ipc/transcript-ipc-20oct...

Kiran Malancharuvil (of the IP Constituency): "…So, but that group, it does make me sad because we - and this maybe a dangerous thing to say in an open meeting, but whatever. It's a really good example of capture in the ICANN community I think.

I think that the privacy interests have captured and refused to compromise. I think that the Registrars and the self-interested service providers have captured that group." (pp. 40-41)

Greg Shatan was even on that call, and wasn't perturbed at the discussion of capture. Immediately after Kiran spoke, Greg said:

"Kiran, there are others. Do you have any idea about solutions to this problem more concretely?"

Then Kiran even went further:

"And everybody talks about capture at ICANN as if the business interests are the ones capturing the groups, and it's absolutely not the case. And the Privacy interests actually now are starting to the capture the Public Safety Working Group which is the Law Enforcement Group." (p. 42)

Again, a legitimate topic of discussion within ICANN.

f) https://meetings.icann.org/en/dublin54/schedule/mon-ccwg-accountability/tran...

"ANNE AIKMAN-SCALESE: Is this thing on? Can you hear me? Okay. Just three quick points. I think that ****there's been a lot of concern expressed about capture and not keeping things open to capture.**** And from my standpoint if one SO or AC can completely dictate the nuclear option, the use thereof or no use thereof, that would be a capture situation. So if only one can completely block, that's capture. That would mean one SO or AC can capture. So I agree with the way it's formulated now." (page 81, emphasis added)

g) https://gnso.icann.org/sites/default/files/file/field-file-attach/transcript...

Phil Corwin of Verisign:

"Good morning. Phil Corwin. My group, and we had some participation, not a great deal of people involved, was on the question of capture. So I'll of course working group recommendations are subject to challenge as representing ****captured by a single constituency or a single interest and that's why capture should be avoided***** because consensus recommendations of a working group should represent consensus of a fairly board cross-section of the ICANN community, and not simply people from this constituency or that stakeholder group, or this particular economic interest.

I'm going to speaking to this, I can't help but think in the context of a working group I'm co-chairing but I'm not going to refer to that specifically. I think you could have two types of capture. One, you could have a working group, which is just the only participants for whatever reason are from a single group, however you define it, and you can't get other people to participate. And I'm not sure what can be done at that point other than trying to encourage others to join in or to disband the group because you know that it's quite likely to have a single point of view and be subject to challenge, and why go through the exercise.

The situation I've been dealing with is different. You have a -- it's basically ****what I call operational capture where you have a small group representing a single interest and single point of view who are the most active members of the working group.****" (pp. 24-25, emphasis added; discussion is even longer, than this)

h) https://archive.icann.org/meetings/singapore2015/en/schedule/tue-csg/transcr...

Elisa Cooper: "Yeah, so, you know, that’s an - if they ask us about that, that’s an opportunity for us. Our explanation was actually quite lengthy and I wanted to keep this to one slide. But it’s risks to coming from marginalized groups. It’s similar to some of these other ones that are out there.

****It’s risk of capture****. It’s risk of over representation by governments. There’s a whole category of items that we think pose potential risk to the multistakeholder model." (pp. 3-4, emphasis added)

i) https://www.icann.org/news/announcement-2003-01-09-en

"Among the reforms is fresh thinking on how to bring the voices of individual users and registrants into the decision process. An At-Large Advisory Committee is being formed to channel the thinking of users around the world. Last March, the ICANN Board decided that, at this time, online elections of directors is an expensive process too fraught with dangers of capture and fraud, and more effective means of bringing users to the ICANN table needed to be found. "ALAC," added Lynn, "will help bring this about."

That was an interesting one. Concerns about capture of online elections for ICANN directors, which then led to the creation of ALAC!

j) https://gnso.icann.org/sites/default/files/filefield_4878/transcript-09dec08...

Danny Younger: "…The second, more urgent question that I've got is on the topic of capture. ****I'm one of many that views ICANN as having been captured by the contracted parties.**** I see multiple regional registry/registrar gatherings funded every year by ICANN with no equivalent for non- contracted parties whatsoever. Has the committee started thinking about recommendations to deal with the internal capture issue?" (emphasis added)

and later:

Marilyn Cade: "…Today ****I do think we have been captured by the contracted parties****, but I believe that we can overcome that and I believe that that is in the best interest of the contract parties as well." (emphasis added)

Normally 10 examples would be more than enough, but I couldn't resist an 11th:

k) https://www.icann.org/en/system/files/correspondence/badiei-to-chalaby-22may...

From NCSG:

"At-Large must develop a robust conflict of interest policy, in particular for their leadership.

It is no easy task to represent the interests of the Internet’s over 3 billion end users. However, if At-Large is going to play this function effectively in the multistakeholder process, it is critical to consider their role as being distinct from that of other stakeholder groups at ICANN. ****At-Large should develop a conflict of interest policy to facilitate this distinction, and to avoid capture by interests whose goals may not be in line with those of end-users***** more generally such as, for example, governments and businesses. Although governments and businesses are, of course, end users in their own right, they also have dedicated stakeholder groups in which their interests are represented. Moreover, governments and some business sectors may have interests which are directly divergent from those of the vast majority of Internet users. ****In order to protect the integrity of ALAC, it is important to develop a conflict of interest policy which prevents membership by persons who are closely tied to these other groups.*****" (page 4)

There are obviously many more examples, but I'll stop at 11. It should be abundantly clear that discussion of capture has been and is an entirely legitimate topic at ICANN.

3. If one returns to my actual email:

https://mm.icann.org/pipermail/cpwg/2019-April/001149.html

it mentioned capture twice:

a) "Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts."

and

b) "The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users."

The 2nd one is a supporting statement for the first, and literally quotes a statement from Greg Shatan's own draft:

https://mm.icann.org/pipermail/cpwg/2019-April/001136.html

"Many At-Large Structures are also ISOC Chapters, further demonstrating the commonality of interests."

That's a direct conflict of interest in my view, an entirely legitimate concern to raise, as per the many citations pointed to above.

4. Look at the actual history of this matter. At the last meeting, it was decided that At-Large would not be making a statement. What "new information" exists since that decision, to justify change? There is none, other than the fact that thousands of others have made comments, and so presumably some of ISOC's friends and/or allies feel the need to help ISOC. That's not a good justification at all.

Remember, Jonathan even wrote on Friday:

https://mm.icann.org/pipermail/cpwg/2019-April/001099.html

"Let's table this discussion until we can have a more thorough exploration of the issues. Email is a terrible way in which to have such a discussion. "

But then some people ignored that, wanting to relitigate a decided issue. And, many of those people were present at last week's meeting too, so they already had their chance. Again, what new information did they have? None. Did Jonathan rebuke them for not tabling the discussion? Nope.

Indeed, look at Greg Shatan's email at:

https://mm.icann.org/pipermail/cpwg/2019-April/001094.html

"I believe that PIR was hoping for a comment along the lines of our first draft (which I believe they saw on our site) or our second draft."

That is again entirely consistent with capture.

5. It's obvious that many folks have some past or present connection to ISOC or one of its chapters, or perhaps even aspirational future connections with them. e.g. Greg Shatan's is obvious, via the NYC chapter of ISOC.

Maureen Hilyard's SOI:

https://community.icann.org/display/atlarge/Maureen+Hilyard+SOI

mentions the "Pacific Islands Chapter of the Internet Society"

Marita Moll has a history with the Canadian chapter:

http://www.maritamoll.ca/content/about-site

Cheryl Landon-Orr's SOI:

https://community.icann.org/display/atlarge/Cheryl+Langdon-Orr+SOI

mentions "Internet Australia (IA) formally known as the Internet Society of Australia ( ISOC-AU)"

John Laprise's LinkedIn profile:

https://www.linkedin.com/in/jplaprise

mentions "cofounding Qatar's Internet Society chapter" as well as "Faculty" of Internet Society in May 2014.

I think I've made my point.

6. Let's take a look at Jonathan Zuck himself. Jonathan has 2 SOIs that I could find at ICANN, one for the At Large and one for the GNSO:

https://community.icann.org/display/atlarge/Jonathan+Zuck+SOI https://community.icann.org/display/gnsosoi/Jonathan+Zuck+SOI

One thing that you won't find mentioned in those SOIs is the history of Jonathan's involvement with Netchoice, as documented by their Form 990 statements:

http://foundationcenter.org/find-funding/990-finder http://990finder.foundationcenter.org/990results.aspx?990_type=&fn=netchoice...

http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201... http://990s.foundationcenter.org/990_pdf_archive/271/271716101/271716101_201...

Page 7 of each Form 990 lists Jonathan Zuck as a director of Netchoice, an organization where Verisign is a member.

https://netchoice.org/

And of course Verisign desires fee increases too.

Indeed, one of the drafters of the Business Constituency's statement in support of fee increases was Steve DelBianco, of Netchoice:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003085.ht...

[another drafter of that statement was Andrew Mack, who even has PIR/ISOC as a client, see:

https://www.amglobal.com/clients ]

And one is trying to assert that "capture" is somehow an inappropriate topic for discussion, given all of the above? I don't agree.

7. Let's not forget about Greg's email at:

https://mm.icann.org/pipermail/cpwg/2019-April/001162.html

where he is either unaware of or ignores relevant facts, such as:

a) I *personally* raised awareness to many .org/info/biz/asia registrants via Slashdot (as well as via my blog and Twitter), see:

https://tech.slashdot.org/story/19/04/23/2330210/icann-proposes-allowing-unl...

Take a look at the date of that -- it's *before* our last meeting, linking again to a post by Nat Cohen at CircleID *before* our last meeting. On Slashdot, it generated 82 comments, and I didn't link to any form (neither did Nat Cohen via CircleID):

http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminati...

Take a look at the number of pageviews of the CircleID article -- 35,257 (at the time of this email), which is far above any other recent post:

http://www.circleid.com/

(most CircleID articles get 1,000 to 2,000 views)

Back in 2006, a similar Slashdot article also vent viral:

https://slashdot.org/story/06/08/25/0611209/icann-oks-tiered-pricing-for-org...

linking to my CircleID post that generate 76,707 views:

http://www.circleid.com/posts/icann_tiered_pricing_tld_biz_info_org_domain/

(and more than a thousand public comments opposing the proposed contracts)

There was no "campaign". Individuals simply got interested in an important issue.

b) NameCheap themselves blogged about it, *and* sent emails to all their own customers, thus generating many comments, both via the ICA form (which they linked to), and original creations. They certainly have a right to raise awareness. And then those clients also went to social media, to encourage public comment. For example, I don't know Quincy Larson personally, but take a look at his Twitter feed:

https://twitter.com/ossia

He's involved with FreeCodeCamp.org, and has more than 77,000 followers. His tweet at:

https://twitter.com/ossia/status/1121778165406265346

has 322 retweets, and 365 likes, implying it received huge coverage and clicks, raising awareness. And if you look at the WHOIS for FreeCodeCamp.org:

http://whois.domaintools.com/freecodecamp.org

it's registered at NameCheap, where he presumably learned about the issue.

c) While many have been focused on .org, consider the number of public comments re: .info:

https://mm.icann.org/pipermail/comments-info-renewal-18mar19/2019q2/date.htm...

250 at the time of this post. Or for .biz:

https://mm.icann.org/pipermail/comments-biz-renewal-03apr19/2019q2/date.html

169 at the time of this post. [The .asia archives appear to be broken, haven't been updated in a week, and haven't even posted my own submission yet, so those 6 comments aren't informative]

Given the relative size of .org vs. .biz and .info, one would easily have expected more than 1000 comments for .org.

d) Even the BBC reported about the issue, further raising awareness.

e) Some very large non-profits and organizations representing non-profits made substantial comments:

(i) NPR, YMCA, C-SPAN, National Geographic Society, AARP, The Conservation Fund, Oceana, and National Trust for Historic Preservation

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003179.ht...

(ii) National Council of Nonprofits https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/000918.ht...

(iii) ASAE

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/002154.ht...

f) Where are all the public comments from At-Large structures or individuals of this CPWG? We agreed last week that folks should submit individual comments, but where are they? I submitted one, of course. Where are comments from ALSes? Where's any outreach to those ALSes? All the entities that At Large purports to represent --- where are their comments? Doesn't At Large do any outreach or education?

Instead, we have a small number of people pushing for an At Large statement at this late date (despite last week's call), one that is rather extreme and illogical, inconsistent with those who've made comments already. It doesn't represent the views of billions of users, nor should it pretend to. It's reactionary, reacting to a perceived desire from PIR/ISOC to have their views (which are self-serving views) put forth at ICANN. That's the very essence of capture. Go back to Greg's email:

https://mm.icann.org/pipermail/cpwg/2019-April/001094.html

"I believe that PIR was hoping for a comment along the lines of our first draft (which I believe they saw on our site) or our second draft."

8. I feel so strongly about this issue, that if At Large does issue a statement that demonstrates capture, I will definitely cease my involvement with At Large and CPWG. Such a statement would undermine At Large's integrity and reputation. I will not waste my time providing input and analysis that will be ignored, if At Large demonstrates it has been captured.

Sincerely,

George Kirikos 416-588-0269 http://www.leap.com/

On Tue, Apr 30, 2019 at 6:59 PM Jonathan Zuck <JZuck@innovatorsnetwork.org> wrote:

...

George, Your comments about Greg somehow "capturing" the At-large (on whose behalf I wonder) are disingenuous given the campaign. In which you are engaged and insulting to everyone on this list attempting to get a handle on a complex and highly political issue. I suggest you withdraw them. Thanks. Jonathan

Jonathan Zuck Executive Director Innovators Network Foundation www.Innovatorsnetwork.org

________________________________ From: GTLD-WG <gtld-wg-bounces@atlarge-lists.icann.org> on behalf of George Kirikos <icann@leap.com> Sent: Tuesday, April 30, 2019 7:51:47 AM To: CPWG Subject: Re: [GTLD-WG] [CPWG] Further Revised Draft Statement on .ORG Renewal

For the record, I disagree with the statement that Greg prepared, and it doesn't reflect my views (which I linked to in an earlier post). It doesn't even reflect the views expressed by many non-profits who made public comments, including NPR and other high profile ones:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003 179.html

or the Non-Commercial Stakeholders:

https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003 207.html

If folks wanted to send a letter, they should have sent it in an individual capacity, rather than pretend that this statement is reflective of the views of billions of internet users. Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts.

ISOC/PIR is just one of many non-profits, and its mission is no better than any other. Every organization has unlimited wants, but needs to work within a reasonable budget. ISOC/PIR doesn't own .org, and shouldn't pretend it does via unlimited "rent" or taxes payable to it. They'll always be able to spend as much money as they can take in. As I noted in my own comments, nothing would stop ISOC/PIR from selling out to private equity, who could then take the heat for huge price increases, while ISOC/PIR walks away with an enormous multi-billion dollar endowment fund.

The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users.

The base agreement for new gTLDs is different from that of legacy gTLDs for good reason, and should not be adopted by legacy gTLDs which predate ICANN itself, and whose registrants do not agree with unlimited fee increases. That's changing the rules in the middle of the game (whereas registrants of new gTLDs knew all along the risks they take registering with new gTLDs, where the registry essentially "owns" that TLD).

The letter quotes Jonathan Zuck's statement about the "desirability" of higher prices almost verbatim, but hasn't done the same for others in the CPWG. Higher prices are not desirable in any way, except by some twisted logic that makes no economic sense (my own personal background is in economics and finance). New entrants always knew that legacy gTLDs had capped prices, before they entered the space. Furthermore, competition generally leads to *lower* prices, not higher prices!

Attempting to argue that capped fees contribute to confusion, phising, fraud and abuse is truly a stretch. The most abused TLDs are the new gTLDs, not the legacy ones, e.g. see:

https://www.spamhaus.org/statistics/tlds/

If one wants to target phishing, fraud and other abuses, one needs to actually *target* it using effective tools. Raising prices for *everyone* is not an effective tool, as it has more collateral damage than actual benefits. If 1%, for example, of domains are engaged in abused, it makes no sense to raise costs on 100% of registrants. One wants to raise costs only on those engaged in abuse (e.g. through high penalties for abuse, like jailtime, fines, etc.). Raising prices for *everyone* simply enriches the registry, at the expense of the public.

Pretending that an "economic study" will be helpful is absurd, as ICANN has in the past commissioned "experts" who simply regurgitated whatever ICANN wanted them to say. Recall that these so-called "experts" (the Carlton report, etc.) were used to justify the new gTLD program in the first place, which has been a failure. Here's a comment from K. Claffy, which talked about those reports:

https://forum.icann.org/lists/economic-framework/msg00004.html

which also referenced my scathing comments about them at the time (which proved prescient). She concluded her comments with:

"Similar to my observations of what's happening in the security and stability discussion of root scaling, ICANN's behavior looks like it's trying to buy rubberstamps of its current plans from commercial consultants, rather than foster what is needed in the long term: a coherent field of objective, peer-reviewed technical, policy, and economic research on Internet naming and numbering, and incentivized data-sharing to support such research."

The ICANN contracts do not have any mechanism to "undo" the changes. Once the caps are removed, that genie cannot be put back in the bottle. One should do an economic study *before* lifting any price caps, rather than doing them after the horse has left the barn, and after the damage has already been done.

What "problem" is this contract actually trying to solve? If it's not broken (and legacy gTLDs are successful, obviously), one should stick with the status quo. If new gTLDs are the "broken" thing, they can be fixed directly (by adding fee caps, just like the successful legacy gTLDs, or making other changes).

In conclusion, Greg, Jonathan, and others should have simply submitted their own personal comments, rather than try to suggest that this statement is reflective of billions of users.

Sincerely,

George Kirikos 416-588-0269 http://www.leap.com/

On Tue, Apr 30, 2019 at 2:14 AM Greg Shatan <greg@isoc-ny.org> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY "The Internet is for everyone" _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ GTLD-WG mailing list GTLD-WG@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg

Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

*TL;DR version:* Q: Are capture and conflict of interest issues in ICANN fair game to talk about? A: Well, sure, but norms on these issues in the outside world are gleefully ignored within ICANN. So good luck with your conversation. *Long version:* Well, this has been ... interesting. First, a few disclosures: - I have been involved in the Internet Society though many vectors. I co-started a chapter, was the primary drafter of its most recent chapters advisory council charter, and I have been recruited by ISOC staff to help impartially resolve disputes in other chapters. All of this has been done voluntarily. My involvement at this moment is negligible. - I own or manage about a dozen domains, none of which are being held for resale. - While on ALAC I "benefited" from travel subsidy that nowhere near covered the value of my time participating at ICANN conferences. I have also gone to two ICANN meetings at my own expense, and I am one of only two people I know (besides Sebastien) who has hosted ALAC social events at their home. - Codes of conduct and conflicts of interest are a thing to me. I created the code currently in use <https://www.lpi.org/conduct> at my nonprofit employer which addresses multiple contexts, and is an amalgam of a number of other codes. - Not only do I agree that the dot-org price cap should be lifted as a significant matter of public interest, I advocate a sharp increase of the fees that ICANN charges all registries for domains. I'd actually like to set a minimum fee rather than a maximum. More details on the rationale can come later, but this discussion seems well beyond the specifics of that public comment issue. Now to a few points: 1. Conflict of interest, in a governance context, has a more specific definition than simply one's having conflicting interests (by being part of multiple constituencies, perhaps). It means that someone's vote, or advocated point of view, is driven by potential gain in either money or power. If we want to strictly apply CofI principles, we find that Internet Society chapters who are ALSs and whose members are not ISOC staff do *not* have a direct conflict of interest, because their policy viewpoints would not affect their income and power. Conversely, NGOs who protest the lifting of the .ORG price cap are absolutely conflicted because they are defending their own ability to pay as little as possible for domains. Their actions are those of registrants, not end-users, and the issue of price caps is one of those few where the interests of registrants and end users can be very, very different. 2. I experience hand-wringing denouncements of conflict-of-interest within ICANN with the sense of creepy entertainment that I get watching an episode of Black Mirror. ICANN was built on a foundation of widespread and openly visible conflict of interest and remains that way to this day. *Nothing is off-limits so long as you declare*. Quoting other constituencies' harping about CofI within ALAC betrays a dangerous ignorance of both history and culture. From the day At-Large began as an alternative to direct public elections of the ICANN Board there has been a constant and predictable effort within most of ICANN, including certain senior staff, to de-legitimize us. The goal of that has been to preempt anything we might say that dare disrupt the cozy compact between domain buyers and domain sellers. Sadly, over the years ALAC has been so timid and self-censoring that such belittling campaigns have proven largely unnecessary. 3. As for capture, I struggle to see it within ALAC. Despite a list of flaws that I could take a book to detail, ALAC and the other ACs are by far the least-corrupted components of ICANN. Elections tend to be robust, and the NomCom factor works to reduce cronyism. If anything, ALAC suffers from the same ills as many democratic entities in that often the politically sociable will win over the duller policy wonks, and ALAC has traditionally been wonk-poor. I myself once believed that there was ISOC chapter capture until I saw just how freaking diverse the chapters are; considering them a cohesive interest bloc within At-Large, once one looks at the reality, is laughable. Just because a group has reached a conclusion with which one disagrees doesn't make it "captured" without further evidence of manipulation. 4. Of *course* complaints are legit that a poorly-resourced 25-person ALAC/RALO council can't possibly do a fantastic job representing "the billions". Yet it does sorta OK with what it's given, considering that it has no discretionary budget; ALAC-approved projects have been rejected by ICANN without reason. I have always wished that ALAC got more involved in public polling and education to better know with confidence what the global public wants from ICANN, but (a) doing that is expensive and (b) I'm quite sure ICANN really doesn't want to know this information. I also note that ALAC is the only constituency within ICANN that has forced geographic diversity. 5. Small nit that I couldn't let pass, even though the point is irrelevant: The assertion that "*nothing would stop ISOC/PIR from selling out to private equity*" is bullshit. Conversion of a nonprofit body to a for-profit is impossible or horribly difficult in most jurisdictions, and even transfer of assets would quickly come under the disapproving eye of regulators. I've seen some attempts first-hand and they didn't end well. Cheers, Evan

Oops, sorry. I skipped a word: "For your point about a minimum fee in disclosures section, that's a fee between and the registry operators --- if that was raised," should be: "For your point about a minimum fee in disclosures section, that's a fee between *****ICANN***** and the registry operators --- if that was raised," On Thu, May 2, 2019 at 5:38 AM George Kirikos <icann@leap.com> wrote:

Hi Evan:

Thanks for your reply. I disagree with much of what you said, obviously, but you're entitled to your opinion.

Without going point by point, I'll note that for #5, one need not convert from a non-profit to a for-profit, as one could simply *assign* the underlying contract itself. If ISOC/PIR was offered USD $8 Billion, to pick a plausible figure, that would be highly tempting. [Everyone has a "magic number", even if an asset isn't for sale. If someone offered you $1 million for Telly.org, or another high enough figure, you might decide to take it, i.e the proverbial] As for regulators, they only get involved when anti-trust is in play, and to date they've sat on their hands, so your "disapproving eye of regulators" statement is not going to work, especially given they've not gone after the egregious presumptive renewal clause. For your point about a minimum fee in disclosures section, that's a fee between and the registry operators --- if that was raised, but left the fee between registry operators and registrars unchanged, then that's fine (i.e. that therefore sets a floor for the registry operator, unless they want to take a loss on every registration; recall under competition, the actual wholesale cost of domains should be on the order of USD $1 or less, which is similar to what fees for phone numbers are these days, see somos.com for example for the wholesale cost of 1-800 numbers).

Sincerely,

George Kirikos 416-588-0269 http://www.leap.com/

On Thu, May 2, 2019 at 4:23 AM Evan Leibovitch <evan@telly.org> wrote:

...

TL;DR version:

Q: Are capture and conflict of interest issues in ICANN fair game to talk about? A: Well, sure, but norms on these issues in the outside world are gleefully ignored within ICANN. So good luck with your conversation.

Long version:

Well, this has been ... interesting.

First, a few disclosures:

I have been involved in the Internet Society though many vectors. I co-started a chapter, was the primary drafter of its most recent chapters advisory council charter, and I have been recruited by ISOC staff to help impartially resolve disputes in other chapters. All of this has been done voluntarily. My involvement at this moment is negligible.

I own or manage about a dozen domains, none of which are being held for resale.

While on ALAC I "benefited" from travel subsidy that nowhere near covered the value of my time participating at ICANN conferences. I have also gone to two ICANN meetings at my own expense, and I am one of only two people I know (besides Sebastien) who has hosted ALAC social events at their home.

Codes of conduct and conflicts of interest are a thing to me. I created the code currently in use at my nonprofit employer which addresses multiple contexts, and is an amalgam of a number of other codes.

Not only do I agree that the dot-org price cap should be lifted as a significant matter of public interest, I advocate a sharp increase of the fees that ICANN charges all registries for domains. I'd actually like to set a minimum fee rather than a maximum. More details on the rationale can come later, but this discussion seems well beyond the specifics of that public comment issue.

Now to a few points:

Conflict of interest, in a governance context, has a more specific definition than simply one's having conflicting interests (by being part of multiple constituencies, perhaps). It means that someone's vote, or advocated point of view, is driven by potential gain in either money or power. If we want to strictly apply CofI principles, we find that Internet Society chapters who are ALSs and whose members are not ISOC staff do *not* have a direct conflict of interest, because their policy viewpoints would not affect their income and power. Conversely, NGOs who protest the lifting of the .ORG price cap are absolutely conflicted because they are defending their own ability to pay as little as possible for domains. Their actions are those of registrants, not end-users, and the issue of price caps is one of those few where the interests of registrants and end users can be very, very different.

I experience hand-wringing denouncements of conflict-of-interest within ICANN with the sense of creepy entertainment that I get watching an episode of Black Mirror. ICANN was built on a foundation of widespread and openly visible conflict of interest and remains that way to this day. Nothing is off-limits so long as you declare. Quoting other constituencies' harping about CofI within ALAC betrays a dangerous ignorance of both history and culture. From the day At-Large began as an alternative to direct public elections of the ICANN Board there has been a constant and predictable effort within most of ICANN, including certain senior staff, to de-legitimize us. The goal of that has been to preempt anything we might say that dare disrupt the cozy compact between domain buyers and domain sellers. Sadly, over the years ALAC has been so timid and self-censoring that such belittling campaigns have proven largely unnecessary.

As for capture, I struggle to see it within ALAC. Despite a list of flaws that I could take a book to detail, ALAC and the other ACs are by far the least-corrupted components of ICANN. Elections tend to be robust, and the NomCom factor works to reduce cronyism. If anything, ALAC suffers from the same ills as many democratic entities in that often the politically sociable will win over the duller policy wonks, and ALAC has traditionally been wonk-poor. I myself once believed that there was ISOC chapter capture until I saw just how freaking diverse the chapters are; considering them a cohesive interest bloc within At-Large, once one looks at the reality, is laughable. Just because a group has reached a conclusion with which one disagrees doesn't make it "captured" without further evidence of manipulation.

Of *course* complaints are legit that a poorly-resourced 25-person ALAC/RALO council can't possibly do a fantastic job representing "the billions". Yet it does sorta OK with what it's given, considering that it has no discretionary budget; ALAC-approved projects have been rejected by ICANN without reason. I have always wished that ALAC got more involved in public polling and education to better know with confidence what the global public wants from ICANN, but (a) doing that is expensive and (b) I'm quite sure ICANN really doesn't want to know this information. I also note that ALAC is the only constituency within ICANN that has forced geographic diversity.

Small nit that I couldn't let pass, even though the point is irrelevant: The assertion that "nothing would stop ISOC/PIR from selling out to private equity" is bullshit. Conversion of a nonprofit body to a for-profit is impossible or horribly difficult in most jurisdictions, and even transfer of assets would quickly come under the disapproving eye of regulators. I've seen some attempts first-hand and they didn't end well.

Cheers, Evan

I wonder why there seems to be some presumption that a company (Public Interest Registry) that has a proven record of good behaviour would suddenly change its attitude and ruin its reputation. But even more strange is the assumption that a group of people (the domainers) who are acting only for the maximisation of their profits would suddenly care in good faith about the poor NGOs who might be affected by a raise of the price. Go figure! R. On 03.05.2019, at 18:51, Greg Shatan <greg@isoc-ny.org<mailto:greg@isoc-ny.org>> wrote: George, This is all basically incorrect. As Daniel Patrick Moynihan used to say, you’re entitled to your own opinion, but not to your own facts. A corollary may be that you’re not entitled to portray someone else’s facts as opinion, as you did to Evan. A non-profit cannot simply assign a contract (or any other assets) outside the ordinary course of business. The non-profit must file with and receive approval from the state Attorney General (and/or a court, depending on the state). A transfer to another non-profit will be somewhat easier, but either way, the transfer must benefit the public interest. Approval from an AG is not a foregone conclusion, and they can even oppose the transaction after it takes place. This is a significant distinction between non-profit and for-profit corporations. It’s important not to miss that distinction. The AG (or an office within the AG, such as the Charities Bureau) is the principal state regulator of non-profits. I believe that is what Evan was referring to. As for the idea that “regulators only get involved when anti-trust is in play,” that is clearly false. Most regulators are not antitrust regulators. It’s probably true that “antitrustregulators only get involved when antitrust is in play,” but that does not extend to all regulators. The proposition that “under competition, the actual wholesale cost of domains should be on the order of $1 or less” seems to be an opinion shared only (and an idea concocted) by a few domain investors, based on a raft of self-serving assumptions and in large part, a single datapoint, the bid for backend services for .in, which is at best an apples to oranges (or apples to apple tree or fruit basket) comparison. Perhaps this is another corollary to the rule at the beginning of this email: you are not entitled to depict your own opinions as fact. Best regards, Greg On Fri, May 3, 2019 at 3:54 AM George Kirikos <icann@leap.com<mailto:icann@leap.com>> wrote: Oops, sorry. I skipped a word: "For your point about a minimum fee in disclosures section, that's a fee between and the registry operators --- if that was raised," should be: "For your point about a minimum fee in disclosures section, that's a fee between *****ICANN***** and the registry operators --- if that was raised," On Thu, May 2, 2019 at 5:38 AM George Kirikos <icann@leap.com<mailto:icann@leap.com>> wrote:

Hi Evan:

Thanks for your reply. I disagree with much of what you said, obviously, but you're entitled to your opinion.

Without going point by point, I'll note that for #5, one need not convert from a non-profit to a for-profit, as one could simply *assign* the underlying contract itself. If ISOC/PIR was offered USD $8 Billion, to pick a plausible figure, that would be highly tempting. [Everyone has a "magic number", even if an asset isn't for sale. If someone offered you $1 million for Telly.org<http://Telly.org>, or another high enough figure, you might decide to take it, i.e the proverbial] As for regulators, they only get involved when anti-trust is in play, and to date they've sat on their hands, so your "disapproving eye of regulators" statement is not going to work, especially given they've not gone after the egregious presumptive renewal clause. For your point about a minimum fee in disclosures section, that's a fee between and the registry operators --- if that was raised, but left the fee between registry operators and registrars unchanged, then that's fine (i.e. that therefore sets a floor for the registry operator, unless they want to take a loss on every registration; recall under competition, the actual wholesale cost of domains should be on the order of USD $1 or less, which is similar to what fees for phone numbers are these days, see somos.com<http://somos.com/> for example for the wholesale cost of 1-800 numbers).

Sincerely,

George Kirikos 416-588-0269 http://www.leap.com/

On Thu, May 2, 2019 at 4:23 AM Evan Leibovitch <evan@telly.org<mailto:evan@telly.org>> wrote:

...

TL;DR version:

Q: Are capture and conflict of interest issues in ICANN fair game to talk about? A: Well, sure, but norms on these issues in the outside world are gleefully ignored within ICANN. So good luck with your conversation.

Long version:

Well, this has been ... interesting.

First, a few disclosures:

I have been involved in the Internet Society though many vectors. I co-started a chapter, was the primary drafter of its most recent chapters advisory council charter, and I have been recruited by ISOC staff to help impartially resolve disputes in other chapters. All of this has been done voluntarily. My involvement at this moment is negligible.

I own or manage about a dozen domains, none of which are being held for resale.

While on ALAC I "benefited" from travel subsidy that nowhere near covered the value of my time participating at ICANN conferences. I have also gone to two ICANN meetings at my own expense, and I am one of only two people I know (besides Sebastien) who has hosted ALAC social events at their home.

Codes of conduct and conflicts of interest are a thing to me. I created the code currently in use at my nonprofit employer which addresses multiple contexts, and is an amalgam of a number of other codes.

Not only do I agree that the dot-org price cap should be lifted as a significant matter of public interest, I advocate a sharp increase of the fees that ICANN charges all registries for domains. I'd actually like to set a minimum fee rather than a maximum. More details on the rationale can come later, but this discussion seems well beyond the specifics of that public comment issue.

Now to a few points:

Conflict of interest, in a governance context, has a more specific definition than simply one's having conflicting interests (by being part of multiple constituencies, perhaps). It means that someone's vote, or advocated point of view, is driven by potential gain in either money or power. If we want to strictly apply CofI principles, we find that Internet Society chapters who are ALSs and whose members are not ISOC staff do *not* have a direct conflict of interest, because their policy viewpoints would not affect their income and power. Conversely, NGOs who protest the lifting of the .ORG price cap are absolutely conflicted because they are defending their own ability to pay as little as possible for domains. Their actions are those of registrants, not end-users, and the issue of price caps is one of those few where the interests of registrants and end users can be very, very different.

I experience hand-wringing denouncements of conflict-of-interest within ICANN with the sense of creepy entertainment that I get watching an episode of Black Mirror. ICANN was built on a foundation of widespread and openly visible conflict of interest and remains that way to this day. Nothing is off-limits so long as you declare. Quoting other constituencies' harping about CofI within ALAC betrays a dangerous ignorance of both history and culture. From the day At-Large began as an alternative to direct public elections of the ICANN Board there has been a constant and predictable effort within most of ICANN, including certain senior staff, to de-legitimize us. The goal of that has been to preempt anything we might say that dare disrupt the cozy compact between domain buyers and domain sellers. Sadly, over the years ALAC has been so timid and self-censoring that such belittling campaigns have proven largely unnecessary.

As for capture, I struggle to see it within ALAC. Despite a list of flaws that I could take a book to detail, ALAC and the other ACs are by far the least-corrupted components of ICANN. Elections tend to be robust, and the NomCom factor works to reduce cronyism. If anything, ALAC suffers from the same ills as many democratic entities in that often the politically sociable will win over the duller policy wonks, and ALAC has traditionally been wonk-poor. I myself once believed that there was ISOC chapter capture until I saw just how freaking diverse the chapters are; considering them a cohesive interest bloc within At-Large, once one looks at the reality, is laughable. Just because a group has reached a conclusion with which one disagrees doesn't make it "captured" without further evidence of manipulation.

Of *course* complaints are legit that a poorly-resourced 25-person ALAC/RALO council can't possibly do a fantastic job representing "the billions". Yet it does sorta OK with what it's given, considering that it has no discretionary budget; ALAC-approved projects have been rejected by ICANN without reason. I have always wished that ALAC got more involved in public polling and education to better know with confidence what the global public wants from ICANN, but (a) doing that is expensive and (b) I'm quite sure ICANN really doesn't want to know this information. I also note that ALAC is the only constituency within ICANN that has forced geographic diversity.

Small nit that I couldn't let pass, even though the point is irrelevant: The assertion that "nothing would stop ISOC/PIR from selling out to private equity" is bullshit. Conversion of a nonprofit body to a for-profit is impossible or horribly difficult in most jurisdictions, and even transfer of assets would quickly come under the disapproving eye of regulators. I've seen some attempts first-hand and they didn't end well.

Cheers, Evan

_______________________________________________ CPWG mailing list CPWG@icann.org<mailto:CPWG@icann.org> https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ GTLD-WG mailing list GTLD-WG@atlarge-lists.icann.org<mailto:GTLD-WG@atlarge-lists.icann.org> https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg Working Group direct URL: https://community.icann.org/display/atlarge/New+GTLDs -- Greg Shatan greg@isoc-ny.org<mailto:greg@isoc-ny.org> President, ISOC-NY "The Internet is for everyone" _______________________________________________ CPWG mailing list CPWG@icann.org<mailto:CPWG@icann.org> https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ registration-issues-wg mailing list registration-issues-wg@atlarge-lists.icann.org<mailto:registration-issues-wg@atlarge-lists.icann.org> https://mm.icann.org/mailman/listinfo/registration-issues-wg

Here you go again Evan, this malignant propensity to being erudite and sane. FWIW, I am proud to associate and support the POV expressed. CAS On Thu, 2 May 2019, 4:24 am Evan Leibovitch, <evan@telly.org> wrote:

*TL;DR version:*

Q: Are capture and conflict of interest issues in ICANN fair game to talk about? A: Well, sure, but norms on these issues in the outside world are gleefully ignored within ICANN. So good luck with your conversation.

*Long version:*

Well, this has been ... interesting.

First, a few disclosures:

- I have been involved in the Internet Society though many vectors. I co-started a chapter, was the primary drafter of its most recent chapters advisory council charter, and I have been recruited by ISOC staff to help impartially resolve disputes in other chapters. All of this has been done voluntarily. My involvement at this moment is negligible.

- I own or manage about a dozen domains, none of which are being held for resale.

- While on ALAC I "benefited" from travel subsidy that nowhere near covered the value of my time participating at ICANN conferences. I have also gone to two ICANN meetings at my own expense, and I am one of only two people I know (besides Sebastien) who has hosted ALAC social events at their home.

- Codes of conduct and conflicts of interest are a thing to me. I created the code currently in use <https://www.lpi.org/conduct> at my nonprofit employer which addresses multiple contexts, and is an amalgam of a number of other codes.

- Not only do I agree that the dot-org price cap should be lifted as a significant matter of public interest, I advocate a sharp increase of the fees that ICANN charges all registries for domains. I'd actually like to set a minimum fee rather than a maximum. More details on the rationale can come later, but this discussion seems well beyond the specifics of that public comment issue.

Now to a few points:

1. Conflict of interest, in a governance context, has a more specific definition than simply one's having conflicting interests (by being part of multiple constituencies, perhaps). It means that someone's vote, or advocated point of view, is driven by potential gain in either money or power. If we want to strictly apply CofI principles, we find that Internet Society chapters who are ALSs and whose members are not ISOC staff do *not* have a direct conflict of interest, because their policy viewpoints would not affect their income and power. Conversely, NGOs who protest the lifting of the .ORG price cap are absolutely conflicted because they are defending their own ability to pay as little as possible for domains. Their actions are those of registrants, not end-users, and the issue of price caps is one of those few where the interests of registrants and end users can be very, very different.

2. I experience hand-wringing denouncements of conflict-of-interest within ICANN with the sense of creepy entertainment that I get watching an episode of Black Mirror. ICANN was built on a foundation of widespread and openly visible conflict of interest and remains that way to this day. *Nothing is off-limits so long as you declare*. Quoting other constituencies' harping about CofI within ALAC betrays a dangerous ignorance of both history and culture. From the day At-Large began as an alternative to direct public elections of the ICANN Board there has been a constant and predictable effort within most of ICANN, including certain senior staff, to de-legitimize us. The goal of that has been to preempt anything we might say that dare disrupt the cozy compact between domain buyers and domain sellers. Sadly, over the years ALAC has been so timid and self-censoring that such belittling campaigns have proven largely unnecessary.

3. As for capture, I struggle to see it within ALAC. Despite a list of flaws that I could take a book to detail, ALAC and the other ACs are by far the least-corrupted components of ICANN. Elections tend to be robust, and the NomCom factor works to reduce cronyism. If anything, ALAC suffers from the same ills as many democratic entities in that often the politically sociable will win over the duller policy wonks, and ALAC has traditionally been wonk-poor. I myself once believed that there was ISOC chapter capture until I saw just how freaking diverse the chapters are; considering them a cohesive interest bloc within At-Large, once one looks at the reality, is laughable. Just because a group has reached a conclusion with which one disagrees doesn't make it "captured" without further evidence of manipulation.

4. Of *course* complaints are legit that a poorly-resourced 25-person ALAC/RALO council can't possibly do a fantastic job representing "the billions". Yet it does sorta OK with what it's given, considering that it has no discretionary budget; ALAC-approved projects have been rejected by ICANN without reason. I have always wished that ALAC got more involved in public polling and education to better know with confidence what the global public wants from ICANN, but (a) doing that is expensive and (b) I'm quite sure ICANN really doesn't want to know this information. I also note that ALAC is the only constituency within ICANN that has forced geographic diversity.

5. Small nit that I couldn't let pass, even though the point is irrelevant: The assertion that "*nothing would stop ISOC/PIR from selling out to private equity*" is bullshit. Conversion of a nonprofit body to a for-profit is impossible or horribly difficult in most jurisdictions, and even transfer of assets would quickly come under the disapproving eye of regulators. I've seen some attempts first-hand and they didn't end well.

Cheers, Evan

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ registration-issues-wg mailing list registration-issues-wg@atlarge-lists.icann.org https://mm.icann.org/mailman/listinfo/registration-issues-wg

Thanks Judith. 4 people already on record asking for the economic study before the lifting of price caps. Anyone else? And thanks Greg for handling what has become a pretty controversial comment Marita On 4/30/2019 2:44 PM, Judith Hellerstein wrote:

Hi Greg I very much like the new and improved statement. I agree with you about UA but perhaps we can include it somehow in the statement.

I also agree with Marita and Justine that  we should ask fur the economic study first and only upon the study’s results decide whether to keep price caps or not to give potential and existing registrants time/leeway to plan for/react to an eventual price cap removal.

Thanks for this revised draft. Since we are not meeting today but Thursday how will we be able to adopt this proposal.

Best Judith

Sent from my iPhone Judith@jhellerstein.com <mailto:Judith@jhellerstein.com> Skype ID:Judithhellerstein

On Apr 30, 2019, at 2:14 AM, Greg Shatan <greg@isoc-ny.org <mailto:greg@isoc-ny.org>> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list.   I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org <mailto:greg@isoc-ny.org> President, ISOC-NY /"The Internet is for everyone"/ <#4244345-v3-Draft ALAC Statement on the Proposed Renewal of the ORG Registry Agreement.DOCX> _______________________________________________ CPWG mailing list CPWG@icann.org <mailto:CPWG@icann.org> https://mm.icann.org/mailman/listinfo/cpwg

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Maureen, In the event that you're not at tomorrow's meeting, do you want me to take any action on your behalf as vice chair? Sent from my Pixel 3XL John Laprise, Ph.D. On Tue, Apr 30, 2019, 9:59 AM Maureen Hilyard <maureen.hilyard@gmail.com> wrote:

I like this version Greg .

In case I can't make tomorrow's CPWG meeting. I believe the new version provides a good compromise of the different views that have been presented by the CPWG discussants. I like the idea of an economic study as well as Marita's suggestion to delay any change until the results of such a study were revealed. I also prefer putting the RAs under one umbrella statement. The separate .asia statement reinforces support for the inclusion of UA. Anything else that is relevant would be in the general ALAC RA statement.

On Mon, Apr 29, 2019 at 8:14 PM Greg Shatan <greg@isoc-ny.org> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"* _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

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All, A few responses to the various earlier emails. @Ricardo, Good point. I think it makes sense to call for several studies over time, rather than a single study. @Olivier, My omission of your contribution was an oversight, not a conclusion that the view lacked support or was off-topic. My apologies. I, for one, would be happy to add something on Registry fees to the draft. Please provide text or point me to the best iteration of your suggested text (which I missed, sadly). Or I can take what is in Justine’s draft. Personally, I am not in favor of doing an economic study before removing the price cap. As Jonathan notes, this work has already been done. My thought was to have a study done in “real time,” based on observing the domain name market(s) after the caps were lifted, so that the effects could be accurately observed and analyzed, and used to inform future action. Predictive studies are by their nature speculative, and can more easily be bent in one direction or the other.. They tend to be more successful and reliable when the study structure and method is well-understood and time-tested (e.g., a pre-merger analysis). A predictive study here may prove far less reliable and useful, given the number of variables and inputs and the novelty of the study. I also think it’s an unrealistic request. But as penholder, I will draft whatever the consensus becomes. Greg On Tue, Apr 30, 2019 at 12:11 PM Maureen Hilyard <maureen.hilyard@gmail.com> wrote:

Thank you, John. I think a consensus call on the document will be required from this session because the extension we requested closes soon after and Evin has to prepare the doc for submission. We can do ratification by the ALAC after the fact but a recorded consensus would be helpful.

M

On Tue, Apr 30, 2019 at 5:50 AM John Laprise <jlaprise@gmail.com> wrote:

...

Maureen,

In the event that you're not at tomorrow's meeting, do you want me to take any action on your behalf as vice chair?

Sent from my Pixel 3XL

John Laprise, Ph.D.

On Tue, Apr 30, 2019, 9:59 AM Maureen Hilyard <maureen.hilyard@gmail.com> wrote:

...

I like this version Greg .

In case I can't make tomorrow's CPWG meeting. I believe the new version provides a good compromise of the different views that have been presented by the CPWG discussants. I like the idea of an economic study as well as Marita's suggestion to delay any change until the results of such a study were revealed. I also prefer putting the RAs under one umbrella statement. The separate .asia statement reinforces support for the inclusion of UA. Anything else that is relevant would be in the general ALAC RA statement.

On Mon, Apr 29, 2019 at 8:14 PM Greg Shatan <greg@isoc-ny.org> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"* _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

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-- Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"*

Thanks Greg I can certainly support this approach. On Wed, May 1, 2019, 02:50 Greg Shatan <greg@isoc-ny.org> wrote:

All,

A few responses to the various earlier emails.

@Ricardo, Good point. I think it makes sense to call for several studies over time, rather than a single study.

@Olivier, My omission of your contribution was an oversight, not a conclusion that the view lacked support or was off-topic. My apologies. I, for one, would be happy to add something on Registry fees to the draft. Please provide text or point me to the best iteration of your suggested text (which I missed, sadly). Or I can take what is in Justine’s draft.

Personally, I am not in favor of doing an economic study before removing the price cap. As Jonathan notes, this work has already been done. My thought was to have a study done in “real time,” based on observing the domain name market(s) after the caps were lifted, so that the effects could be accurately observed and analyzed, and used to inform future action. Predictive studies are by their nature speculative, and can more easily be bent in one direction or the other.. They tend to be more successful and reliable when the study structure and method is well-understood and time-tested (e.g., a pre-merger analysis). A predictive study here may prove far less reliable and useful, given the number of variables and inputs and the novelty of the study. I also think it’s an unrealistic request. But as penholder, I will draft whatever the consensus becomes.

Greg

On Tue, Apr 30, 2019 at 12:11 PM Maureen Hilyard < maureen.hilyard@gmail.com> wrote:

...

Thank you, John. I think a consensus call on the document will be required from this session because the extension we requested closes soon after and Evin has to prepare the doc for submission. We can do ratification by the ALAC after the fact but a recorded consensus would be helpful.

M

On Tue, Apr 30, 2019 at 5:50 AM John Laprise <jlaprise@gmail.com> wrote:

...

Maureen,

In the event that you're not at tomorrow's meeting, do you want me to take any action on your behalf as vice chair?

Sent from my Pixel 3XL

John Laprise, Ph.D.

On Tue, Apr 30, 2019, 9:59 AM Maureen Hilyard <maureen.hilyard@gmail.com> wrote:

...

I like this version Greg .

In case I can't make tomorrow's CPWG meeting. I believe the new version provides a good compromise of the different views that have been presented by the CPWG discussants. I like the idea of an economic study as well as Marita's suggestion to delay any change until the results of such a study were revealed. I also prefer putting the RAs under one umbrella statement. The separate .asia statement reinforces support for the inclusion of UA. Anything else that is relevant would be in the general ALAC RA statement.

On Mon, Apr 29, 2019 at 8:14 PM Greg Shatan <greg@isoc-ny.org> wrote:

...

All,

I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.

I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.

Best regards,

Greg

Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"* _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg

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-- Greg Shatan greg@isoc-ny.org President, ISOC-NY *"The Internet is for everyone"* _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ registration-issues-wg mailing list registration-issues-wg@atlarge-lists.icann.org https://mm.icann.org/mailman/listinfo/registration-issues-wg