March 2018 - Gdd-gnso-ppsai-impl

Additional Background Re: Proposed PP Reporting Process
by Amy Bivins March 11, 2018

March 11, 2018

Dear Colleagues, Following up on our discussion today about the processes for monthly reporting, I can now provide some additional information from our tech team. I have attached two templates that can be used to get a better idea of how the report contents are expected to look (using RRI) assuming 2 sample registrars and TLDs. These templates were created using our current internal working draft, so the fields don't match the previous version of the specification you reviewed. Certain fields (in the top row) were tentatively deleted, and others added, pending further IRT input on the topic. If the IRT's consensus was that reporting should not be broken out by category, the number of fields would be further reduced. Providers would not be required under the current proposal to automate their end of the reporting and are allowed to generate the files manually if they prefer. Since RRI is a RESTful API, users may upload the report files using a simple command line, or even public web browser extensions that allow users to execute HTTP PUT requests as a REST Client. For example, in a Unix based terminal this can be done by running the following commands replacing the highlighted fields with the corresponding value for the Provider credentials, file name, provider ID and reported date: * Upload Per Registrar report: curl -u username:password --header "Content-Type:text/csv" --request PUT --data-binary @PPSP-registrars-yyyymm.csv --dump-header - <base-url>/report/ppsp-activity-registrar/PPSP-ID/2018-03 * Upload Per TLD report: curl -u username:password --header "Content-Type:text/csv" --request PUT --data-binary @PPSP-tld-yyyymm.csv --dump-header - <base-url>/report/ppsp-activity-tld/PPSP-ID/2018-03 Some REST clients for browsers have similar looks to the screenshot below added for reference to show the ease of use, however ICANN does not provide support for third party software. [cid:image001.jpg@01D3B55A.2B813B10] Please let me know should there be any other questions. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call
by Sara Bockey March 11, 2018

March 11, 2018

Amy, It seems clear that the additional language is necessary regardless of 4.2. It’s been raised repeatedly and agreed to by pretty much all of the registrars, so it’s unclear to me why you keep trying to remove it. Additionally, it has been raised repeatedly and agreed to my pretty much all of the registrars that the 3 instances under 4.2.2 are not sufficient. There are extraordinary circumstances that could arise, as outlined previously. At the very least, we need to amend the language to say “including but not limited to”. It’s incredibly frustrating that staff does not appear to hear what we are saying. Sara sara bockey sr. policy manager | GoDaddy™ sbockey(a)godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Amy Bivins <amy.bivins(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Thursday, March 8, 2018 at 8:04 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Thanks, Lindsay! I’ll note that in Section 4.2 (I’ve attached a copy of the specification as it looks now, with no changes), disclosure may be reasonably refused if disclosure would contravene applicable law. What if we added something in this section 4.2, such that disclosure may be reasonably refused if a subpoena or a court order is required to obtain the requested information? From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Lindsay Hamilton-Reid Sent: Thursday, March 8, 2018 10:00 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Hi Amy Thank you for the suggestion and while we have reworded another clause to compensate for the first part of your deletion, the part about court orders must remain. We will not provide information without a court order and will certainly not contravene applicable law. I know we are trying to find the right balance here but it must be reasonable. We will of course do what we can to help law enforcement but we are not here for the benefit of LEAs and do have the rights of our customers to protect, particularly in view of the GDPR and the upcoming ePrivacy regulations. Many thanks Lindsay Lindsay Hamilton-Reid Senior Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid(a)1and1.co.uk<mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk<http://www.fasthosts.co.uk/> www.1and1.co.uk<http://www.1and1.co.uk/> [fh-1and1] © 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. If you are not the intended recipient, you should not disclose, copy or use any part of it - please delete all copies immediately and notify 1&1 on 0844 335 1211 or Fasthosts on 0333 0142 700. Any statements, opinions or information in this message are provided by the author, not on behalf of 1&1 and/or Fasthosts, unless subsequently confirmed by an individual who is authorised to represent 1&1 and/or Fasthosts. [linkedin]<http://www.linkedin.com/company/fasthosts-internet-ltd>[twitter]<https://twitter.com/Fasthosts>[facebook]<https://www.facebook.com/fasthostsinternet>[gplus]<https://plus.google.com/u/0/b/107582097021398424605/+fasthosts/posts>[blog]<http://blogs.fasthosts.co.uk/>[youtube]<http://www.youtube.com/user/Fasthostsinternet> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: 08 March 2018 12:07 To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Thanks, Peter, for your input on this. I’m noticing that while you aren’t happy with the proposed one business day requirement, you didn’t say that it’s a definite non-starter, either. Perhaps there is some room for compromise. Sara and other registrars who supported Sara’s proposed language, how would you feel about trimming the proposal to account for the discussion on Tuesday about points that are already covered elsewhere in the framework? If we did that, it would look something like this (edit to Sara’s proposal in redline): 4.1.2 Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day., noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. As proposed below, we could also update 3.1 to make abundantly clear that this is a direct LEA contact to the provider’s designated LEA contact, which may be an email address, form, phone number, or any other means the provider has shared with LEA. There must be a way for LEA to obtain the designated contact via the website (even instructions to call the provider’s main number would seem to satisfy this request) but the contact itself does not have to be posted on the website. 3.1 Pre‐Request: Provider will establish and maintain a designated LEA Requestor point of contact for submitting disclosure requests. Provider shall publish on its website the designated contact (e.g. email address, telephone number, form) or other means for LEA to obtain designated LEA contact information). If the language looked like this, for compliance purposes we could use some additional clarity about what it means for a provider to “use its best efforts to action the request within one business day.” Sara and other registrars who support this proposal, if we kept the “one business day” standard, would you be able to compromise by editing this a bit to make clear that a human (non-automated) response would be required within one business day of receipt of the request (perhaps by simply reverting to the word “action” if we were to clearly define that as discussed previously)? Peter, what would you and your PSWG colleagues think about this? Thanks, all for your continued attention to this matter. Hopefully, we can reach a conclusion on this while many of you are at ICANN61 in Puerto Rico. I’ll note that the poll is still open through EOD Friday, https://www.surveymonkey.com/r/CMGF8FZ. As of now, there are 18 responses. Four IRT members support raising this issue to the Council, and 14 oppose that (including some registrars). Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Roman, Peter (CRM) Sent: Wednesday, March 7, 2018 1:08 PM To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call FWIW, I am not very happy with the one business day requirement to action the law enforcement High Priority request. Even a 24 hour window is too long. This is an emergency, that’s why we will be using this process. It really should be actioned more or less immediately. If it didn’t need immediate attention, we wouldn’t be using the High Priority process. Peter Roman Senior Counsel Computer Crime & Intellectual Property Section Criminal Division Department of Justice 1301 New York Ave., NW Washington, DC 20530 (202) 305-1323 peter.roman(a)usdoj.gov<mailto:peter.roman@usdoj.gov> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, March 6, 2018 11:42 AM To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. If you couldn’t attend, I encourage you to listen to the recording, https://community.icann.org/display/IRT/06+March+2018 If you haven’t already, please complete the IRT poll regarding the potential policy implications surrounding the IRT discussions on the LEA framework specification no later than Friday, https://www.surveymonkey.com/r/CMGF8FZ Currently, two IRT members have indicated that they believe the issue should be escalated to the Council. Fourteen responded that this should not be escalated to the Council at this stage. Today, we solicited any additional feedback related to the draft reporting specification. I’ve attached a draft with some notes indicating the feedback received to date. We will begin updating the specification based on this feedback, and will consider any additional feedback received between now and the end of the IRT session at ICANN61 in updating the draft. We also discussed a proposal from Sara Bockey on-list, which has been supported by several other registrar members of the IRT, for alternative language for the LEA Framework Specification. The proposed language is: 4.1.2 Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours. The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority. Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Based on the discussion today, it’s possible that an edit could potentially be made in Section 3.1, to eliminate the perceived need for the “contact the Provider directly” language, such as: 3.1 Pre‐Request: Provider will establish and maintain a designated LEA Requestor point of contact for submitting disclosure requests. Provider shall publish on its website the designated contact (e.g. email address, telephone number, form) or other means for LEA to obtain designated LEA contact information). I’ll note that because LEA are not a party to this contract, I don’t think they could be required via this contract to “make every effort,” so that may be a point to consider. Also, the draft already states, at Section 4.2.2.2 that a Provider can refuse disclosure if the disclosure would lead to a contravention of applicable law. Concerns have also been raised about the “best efforts” language. IRT feedback is requested on-list on the above proposed language. If IRT members who oppose the current PSWG-proposed text can reach agreement on proposed language, this can be published for public comment. This will be on the agenda for the session on Sunday at ICANN61. A full agenda will be distributed later this week. In addition, if the IRT would like to discuss any items from the updated PPAA draft in Puerto Rico, please let me know. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Privacy/Proxy IRT Working Meeting at ICANN61
by Amy Bivins March 9, 2018

March 9, 2018

Dear Colleagues, Below, you will find our agenda and dial-in information for Sunday's face-to-face Privacy/Proxy IRT meeting at ICANN61, scheduled for 18:30-19:30 local time. For those that cannot attend, an update will be distributed to the group after the meeting, and the recording will be posted. Agenda: * Update on Project Status and Timeline * Finance Presentation * Outstanding Issues * LEA Framework Specification * Pending Updates to Reporting Specification, Per IRT Feedback * IRT Discussion Question Re: Data Escrow Specification (IRT views solicited about making Escrow Specification a Separate Document from PPAA (as is done in RAA), per question in circulated PPAA draft, to make it easier to update if/when technical requirements evolve) * Any IRT Feedback on Updated PPAA Draft * AOB Adobe Connect: https://participate.icann.org/sju61-208a If you haven't completed the poll requested by Darcy Southwell, as GNSO Council Liaison, related to the LEA Framework Specification, please complete it no later than your end of day today, https://www.surveymonkey.com/r/CMGF8FZ. As of now, 18 IRT members have completed the poll. Four support taking the LEA Framework Specification issue to the Council at this stage, and 14 oppose this course of action. Please let me know if you have any questions or concerns or specific items you would like to add to the agenda.

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Action items from today's IRT call
by Amy Bivins March 8, 2018

March 8, 2018

Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. If you couldn’t attend, I encourage you to listen to the recording, https://community.icann.org/display/IRT/06+March+2018 If you haven’t already, please complete the IRT poll regarding the potential policy implications surrounding the IRT discussions on the LEA framework specification no later than Friday, https://www.surveymonkey.com/r/CMGF8FZ Currently, two IRT members have indicated that they believe the issue should be escalated to the Council. Fourteen responded that this should not be escalated to the Council at this stage. Today, we solicited any additional feedback related to the draft reporting specification. I’ve attached a draft with some notes indicating the feedback received to date. We will begin updating the specification based on this feedback, and will consider any additional feedback received between now and the end of the IRT session at ICANN61 in updating the draft. We also discussed a proposal from Sara Bockey on-list, which has been supported by several other registrar members of the IRT, for alternative language for the LEA Framework Specification. The proposed language is: 4.1.2 Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours. The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority. Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Based on the discussion today, it’s possible that an edit could potentially be made in Section 3.1, to eliminate the perceived need for the “contact the Provider directly” language, such as: 3.1 Pre‐Request: Provider will establish and maintain a designated LEA Requestor point of contact for submitting disclosure requests. Provider shall publish on its website the designated contact (e.g. email address, telephone number, form) or other means for LEA to obtain designated LEA contact information). I’ll note that because LEA are not a party to this contract, I don’t think they could be required via this contract to “make every effort,” so that may be a point to consider. Also, the draft already states, at Section 4.2.2.2 that a Provider can refuse disclosure if the disclosure would lead to a contravention of applicable law. Concerns have also been raised about the “best efforts” language. IRT feedback is requested on-list on the above proposed language. If IRT members who oppose the current PSWG-proposed text can reach agreement on proposed language, this can be published for public comment. This will be on the agenda for the session on Sunday at ICANN61. A full agenda will be distributed later this week. In addition, if the IRT would like to discuss any items from the updated PPAA draft in Puerto Rico, please let me know. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Re: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call
by Michele Neylon - Blacknight March 6, 2018

March 6, 2018

I’m attending Puerto Rico in person, but I sincerely doubt I’ll be attending that meeting in person, as I’ve a strong aversion to doing 12 hour days Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Chris Pelling <chris(a)netearth.net> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday 6 March 2018 at 12:40 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call Hi Jenn, Can you please confirm that the slides and their "reasoning" is sent out via this list please - as I am not attending in person, nor remotely as thats gone midnight UK time. Kind regards, Chris ________________________________ From: "Jennifer Gore" <jennifer.gore(a)icann.org> To: gdd-gnso-ppsai-impl(a)icann.org Sent: Tuesday, 6 March, 2018 12:28:37 Subject: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call Dear Colleagues, Unfortunately, the finance team will not be available to join our meeting today to present the data associated with the PP program fee schedule. However, they have committed to present in person during the IRT mtg in Puerto Rico on Sunday March 11, 2018 at 6:30 PM. If the meantime, please let me know if you have any questions. Thank you, Jennifer Gore _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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Summary, action items from today's PP IRT call
by Amy Bivins March 6, 2018

March 6, 2018

Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency-IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission-on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today's meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format-on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields-on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today's call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate "total" numbers for requests for specific contacts, eliminate "publication" fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded "reasons for denial" fields. PP Applicant Guide 1. Issue 1: Shift to "rolling" application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many "essay" questions in favor of "checkbox" questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today's call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today's call, it appears that * If "action" is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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IRT Member Poll, Please Complete by EOD Friday, 9 March
by Amy Bivins March 5, 2018

March 5, 2018

Dear Colleagues, Pursuant to Darcy's request sent to the list on Friday, please complete this linked poll, which will be used to gauge IRT consensus with respect to any potential policy implications raised by the current IRT debate on the draft LEA framework specification, https://www.surveymonkey.com/r/CMGF8FZ. Please complete this poll no later than your end of day Friday, 9 March. I've also included a couple of questions related to the reporting specification, to ensure we collect as many IRT member views on this topic as possible. For our meeting tomorrow, we will have a presentation from the Finance team with more information about the proposed program fees schedule. We can also discuss any issues you would like to raise related to the updated PPAA draft that was distributed last week and the proposed agenda for the IRT meeting at ICANN61. If you have specific you would like to discuss, please send them to the list before the call if possible. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Updated PPAA draft and related materials attached for IRT review
by Amy Bivins March 3, 2018

March 3, 2018

Dear Colleagues, Attached is the updated PPAA draft, in redline and non-redline versions. I've also included a version with references to the Final report and notes to the IRT about where edits were made (or not made). The attached slide deck includes an overview of the accreditation program materials, remaining open issues, and identifies how each of the Final Recommendations are proposed to be implemented. Please begin reviewing the updates to the PPAA draft and come prepared to discuss at our meeting on Tuesday. Also, please provide any final feedback on the LEA framework and reporting specification no later than this Friday, 2 March. We plan to update this draft with respect to feedback received on those issues next week as we prepare these materials for the public comment period. Brief, high-level summary of the changes/questions for the IRT in this PPAA draft: 1. Non-substantive copy edits throughout 2. Labeling specification (and all references to this specification) deleted based on IRT feedback that the requirements therein appeared to be beyond scope. Labeling requirement included in PPAA body at Section 3.15. 3. Reporting specification (and references to this specification) added. Specification remains under IRT review (deadline for feedback 2 March). Links to PP IETF documents are not yet functional, as these are not yet published. These are expected to be published prior to the publication of the draft PPAA for public comment and links will be updated if needed when this specification is finalized based on final IRT feedback. 4. Definition of "Working Group" (applicable to amendment, negotiation processes-See, e.g., Section 7.4.1) updated throughout PPAA to eliminate references to any future PPSG. In its place, the WG will now be convened by the GNSO Council (See PPAA Section 1.43), as recommended by the IRT. 5. All references to a Provider terminating a customer's domain registration or requesting that a registrar do so in response to a breach of the terms of service or other wrongs have been deleted, per IRT input. (See, e.g. Section 3.5.3.1; See, specifically, Section 3.5.3.17 (regarding cancellations of services related to names that are subject to UDRP/URS proceedings.) 6. Explicit requirement that Provider publish its terms of service has been added (See Section 3.8.1). Prior draft referenced requirements for ToS contents but didn't explicitly require that ToS be published, as directed by the Final Report. 7. Abuse desk requirement in PPAA Section 3.12.1 edited to match language in Final Report (language about the abuse contact being "capable and authorized to investigate..." from the Final Report had been inadvertently deleted at some point in a prior draft). 8. Deletion of LEA-related abuse contact requirements in PPAA text (formerly section 3.12.2). All LEA-specific requirements are now included in the LEA Disclosure Framework Specification. 9. Reference to use of "high-volume, automated electronic processes..." in PPAA section 3.14 was moved to Intellectual Property Disclosure Framework Specification. 10. Clarification added that a provider on suspended status may continue to provide services for existing registrations (Section 5.7.3) 11. Several clean-up edits in Specification 1, Data Escrow Specification. ICANN is currently reviewing the inclusion of this Specification in the PPAA itself, as opposed to the RAA format which has the escrow specification separate from the accreditation agreement. As technical requirements/RFCs may be updated from time to time, there are benefits to having this outside the PPAA itself. IRT feedback is requested on this topic. 12. Specification 2: Customer Data Accuracy Program Specification. Edit to Section 1, to clarify that obligation applies when Provider begins providing the Services for a name, as opposed to when the name is registered. 13. Specification 4: Law Enforcement Authority Specification. This specification is currently under final IRT review (deadline for feedback 2 March). Substantive edits may be made after this review period. There is currently some disagreement among IRT members regarding high priority requests, specifically: (a) how the receipt process should or should not apply to high priority requests, (b) the time that should be allowed for a provider to action a "high priority" request. In addition, the IRT is considering defining "action" for greater clarity. 14. Data retention specification: The data required to be retained has been reduced by the deletion of the labeling specification (see Section 1.1.6). Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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