OCL:
As one of those of us who spent the time working the EWG detail, the immediacy of the frustrations working shifts on the PPSAI and WHOIS Conflicts WGs is indeed remarkable.

Take the WHOIS Conflicts and Waiver process. ICANN knows - or should know - that the RAA is conflicted with privacy laws in the several jurisdictions. Yet instead of dealing with the matter on a principled and comprehensive basis, it continues to apply one-by-one waivers to registrars for minding the law in their domiciled jurisdiction. This continuing situation beggars reason and good judgment. And is one of the issues the EWG's recommendations are intended to address.

That the solution is within the reach of anyone who even thinks of this for a few minutes is incontestable. But yet we insist.

Whenever I think of it, I recall the cartoon of Noah - he of that flood - in that [wooden] boat trying his damnedest to trap that woodpecker. We do it to ourselves.

-Carlton

==============================
Carlton A Samuels
Mobile: 876-818-1799
Strategy, Planning, Governance, Assessment & Turnaround
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On Tue, Jul 7, 2015 at 11:52 AM, Olivier MJ Crepin-Leblond <ocl@gih.com> wrote:

Dear Valentina,

thanks for this excellent contribution.

As you mention, the public comment period is open until end of business day today... I really do not know why the ALAC comment period also closes on the same day - but this is all coming in at the very last moment.
I have CC'ed Holly Raiche & Carlton Samuels (as well as ALAC Chair Alan Greenberg & ALAC Policy Staff) to see if your organisation's comments can be taken into account, perhaps with ALAC asking for a few more days from Mary Wong in order to formulate a response.

Alas I have no say in the matter / process or substance. :-)

Kindest regards,

Olivier

ps. my thoughts about the matter of WHOIS Privacy & Proxy is that WHOIS has become inappropriate for the task it is asked to perform. I am flabbergasted that the work of the Expert Working Group on gTLD Directory Services, published on https://www.icann.org/news/blog/ewg-recommends-a-replacement-for-whois is actually not being taken into account. It would save a lot of time from volunteers wasting time with WHOIS privacy/proxy now.

On 07/07/2015 17:46, Valentina Pavel /ApTI wrote:
Dear At-Large Community Members,

Please find attached ApTI's comment regarding ICANN's WHOIS privacy/proxy services proposal.

We believe the new policy presents a serious danger to freedom of speech, privacy and to the rule of law on the Internet and we urge ICANN not to adopt this proposal.

We are also working on publishing a summary of our comment.

The public comment period is open until 7 Jul 2015 23:59 UTC.

Thank you,

Valentina Pavel
Asociația pentru Tehnologie și Internet - ApTI
privacy.apti.ro & apti.ro

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