April 2018 - Gdd-gnso-ppsai-impl

Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April
by Sara Bockey May 18, 2018

May 18, 2018

Regarding Section 4.2.2 “without limitations” is necessary to ensure legitimate instances not yet listed or thought of are covered. Examples of additional causes beyond the control of the Provider: war, terrorism, riots, power outage, internet outage, internet failure, server failure, foreign gov’t changes, labor disputes, etc. Regarding Section 4.2.2.5 – I see no issue with redundancy and there is no harm in including this. If anything, it protects against potential abuse (in parts of the world that are less democratic) Regarding Section 4.2.6 – Not redundant and 100% necessary. Particularly for providers in parts of the world that are less democratic. We must remember this will be applied globally. Belt and suspenders! At ICANN61 this addition gave registrars that spoke with me the most comfort. Finally, I note that Staff is using the 24-hr timeframe as the default in the document instead of one business day as agreed by the registrars. Since one business day is what the registrars have agreed to, should it not be the default until otherwise determined? 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: Tuesday, April 17, 2018 at 10:53 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. For those who could not attend, I regret that we were unable to record this meeting (an issue with a new internal recording policy), but this was a one-time issue and all future meetings will be recorded. I’ve done my best to annotate the LEA specification document with the items we discussed, and have also attached the chat transcript. IRT Action Items We are nearing the completion of discussions on the LEA Specification. Other than the item of clear disagreement among members of the IRT—the time period for high priority requests—we are largely in the refining stage. To that end, we have a few final proposed edits for the group to review and comment on—including some edits that were originally suggested by Sara Bockey a few weeks ago and supported by many registrar members of the IRT. If we don’t hear any opposition to these edits that would warrant further discussion, we will make these edits as requested in the draft we publish for comment. Today, we considered whether the LEA Framework Specification would be clearer if we reorganized it slightly, to make more clear where processes apply to high priority requests and when they don’t. I’ve included two versions of the draft—the one with “orig” at the end of the title—which includes the proposed edits without reorganizing, and the “reorganized” one. Please review both and respond to the list with your thoughts about the proposed reorganizing of this. Please provide any additional input you have on this draft no later than next Friday, 27 April. Please note, specifically, questions in the following sections: Original Numbering Reorganized Version Section 2.1.10 (addition of “except in high priority” language at beginning of edit) Same section Section 3.2.1 (addition of the words “Standard Priority” to make clear this 2 business day receipt process doesn’t apply in high priority cases) Moved to Section 3.2.2 Section 4.2.2 (inclusion of “without limitations” language, plus input about and question from Steve Metalitz—any other reasons that registrars feel would be reasonable for refusing disclosure?); Also see feedback, generally, from PSWG liaison, in meeting chat transcript (most pasted into specification document but cuts off at the end) Same section Section 4.2.2.5 (is this redundant? ) Same section Section 4.2.6 (is this redundant?) Same section I’m also attaching the most recent draft de-accreditation procedure document. As mentioned on the list last week, upon further consideration on the ICANN org side we think we should add back in the proposed transition procedure for customers impacted by the de-accreditation or termination of a third-party provider (section 4). Please review and provide any further comments on this no later than 27 April. For next week, we are hoping to have the requested fees information ready for you to discuss. I’ll update you as soon as I can. 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] Notes, action items from today's PP IRT meeting--feedback requested by 27 April
by Chris Pelling April 30, 2018

April 30, 2018

I also agree with Sara's, Eric and Theo points. Sent by Chris on the move. -------- Original message --------From: theo geurts <gtheo(a)xs4all.nl> Date: 30/04/2018 20:28 (GMT+00:00) To: gdd-gnso-ppsai-impl(a)icann.org, Eric Rokobauer <eric.rokobauer(a)endurance.com> Subject: Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Agreed with Eric and Sara, 4.2.6, we could move that one around some. 4.2.2.5, I rather keep it in, it does not hurt and I 100% agree, democracy is not a given. Theo On 30-4-2018 21:05, Eric Rokobauer wrote: Apologies for the late reply in providing some feedback. Comments following Sara's comments from 19 April: Inclusion of "without limitations" in section 4.2.2 - I agree with Sara here. Ideally again it is to cover the Provider from potential instances that we here in this IRT may not be recognizing here. 4.2.2.5 being potentially redundant - I believe this should be removed if IRT does find to be redundant. While I do appreciate Sara's comments, if we do all agree there is duplication here with the statement, best we remove to clear any potential confusion that could come later (thinking when we may not necessarily remember why we had this added in the first place). 4.2.6 - I agree that this is not redundant and should still be kept, but open to having it included elsewhere within section 4.2 if majority feels it would be better represented. As for the timeframe, agree that one business day should be our default. Thanks Eric Eric Rokobauer Sr. Registrar Compliance Manager | Endurance International Group 10 Corporate Drive, Suite 300, Burlington MA 01803 T - 781.852.3445 E - eric.rokobauer(a)endurance.com On Mon, Apr 30, 2018 at 5:12 AM, Volker Greimann <vgreimann(a)key-systems.net> wrote: If you are not willing to compromise, we may get nowhere. If the line has to be drawn between this is what is reasonably possible for us to deliver (meaning everything beyond that is either unreasonable or impossible) and this is what we (meaning the PSWG) want because it is an artificial number we want, it seems clear where the policy should end up. So you are not willing to compromise and continue to demand the impossible or unreasonable. Fine, but that is not how this works at ICANN. Our compromise line is one business day. If no one moves, we are at an impasse. But please remember: Usually, you are going to get answers quicker, it is just a minimum guaranteed response time we are talking about. And anything you get here - ANYTHING! - is better than what you have now. We are not proposing to take anything away from you. We are freely agreeing to give you something. Let's not lose focus on this very important point. Volker Am 27.04.2018 um 23:24 schrieb Roman, Peter (CRM): All, A quick additional response to the comments in the LEA specification: Note 7 says that “Registrar members of the IRT contend that the 24-hour period recommended by the PSWG is unworkable; PSWG members contend that 24 hours should be the maximum allowable time for a request to be actioned in an emergency situation.” This is a complete misrepresentation of the PSWG position. The PSWG has maintained from the beginning of the conversation on emergency requests that they needed to be “actioned” immediately. The PSWG does NOT recommend the 24-hour period, the PSWG is willing to COMPROMISE to the 24 hour period. The PSWG is NOT willing to compromise to the one business day response time. One business day, as the providers have explained it, means that an emergency request delivered to the provider on Friday afternoon does not need to be responded to until Monday afternoon. So, one business day means 72 hours or more. In an emergency, this is completely useless response time. By that time, people are dead. An imminent threat to life means that somebody is going to die any moment without this information. I hope that you never have to respond to one of these requests but I also hope that if you do, you will not ignore it until you get to it the next business day. 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 From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Metalitz, Steven Sent: Friday, April 27, 2018 2:24 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Please see in-line feedback below regarding some of Sara’s points on the LEA specification. On behalf of Coalition for Online Accountability (COA) | www.onlineaccountability.net Steven J. Metalitz | Partner, through his professional corporation T: +1.202.355.7902 | met(a)msk.com Mitchell Silberberg & Knupp LLP | www.msk.com 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, April 19, 2018 2:36 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Thanks, Sara and Steve, for your comments on this draft thus far. I’ve updated the draft to address your last point, Sara, and in line with Steve’s comment about separating out standard and high priority requests. I’ve left the comments in the draft from Tuesday’s call for now. Absent any strong opposition to the inclusion of the other edits proposed by Sara, as noted in the draft, these will be accepted in the next draft. I encourage all IRT members to review the draft again when you are able and provide any further feedback no later than the end of next week. I don’t have any further information or materials for you today for next week’s meeting, but I hope to have something for you soon (I’ll send it as soon as I have it). Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Thursday, April 19, 2018 1:20 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Regarding Section 4.2.2 “without limitations” is necessary to ensure legitimate instances not yet listed or thought of are covered. Examples of additional causes beyond the control of the Provider: war, terrorism, riots, power outage, internet outage, internet failure, server failure, foreign gov’t changes, labor disputes, etc. Steve’s comment: (I think this refers to 4.1.2 of the revised document Amy sent out 4/17. ) This strikes me as a reasonable list of reasons why a provider would not be able to respond in a timely fashion to an LEA disclosure request (whether High Priority or Standard Priority), but not of reasons to deny altogether a request that otherwise meets the requirements of the specification. Should we append this list to what is now 4.1.4 (following “acts of nature”)? I would be much more comfortable including “without limitations” there rather than in 4.1.2. Regarding Section 4.2.2.5 – I see no issue with redundancy and there is no harm in including this. If anything, it protects against potential abuse (in parts of the world that are less democratic) Steve’s comment: This refers to the “well founded” phrasing in 4.1.2.5. I still have trouble understanding what would make a request that meets all the requirements of the specification not “well founded,” and believe I pointed out on the April 17 call why this situation differs from RAA 3.18.2 where “well-founded” appears (in short, that the RAA does not define what needs to go into an actionable LE request, and this specification does). Can Sara or others provide an example of when this ground for refusal of an LEA request might come into play? Regarding Section 4.2.6 – Not redundant and 100% necessary. Particularly for providers in parts of the world that are less democratic. We must remember this will be applied globally. Belt and suspenders! At ICANN61 this addition gave registrars that spoke with me the most comfort. Steve’s comment (this refers to the “due process” language now appearing in 4.1.6): I think it is redundant and for that reason do not object to it. “Foregoing due process within its applicable jurisdiction” is really a subset of 4.1.2.2, disclosure in contravention of applicable law. Regarding the legitimate concerns about “less democratic” jurisdictions: remember that this entire specification only applies to disclosure requests received from LE authorities within the provider’s own jurisdiction. If you choose to establish the provider within a “less democratic” jurisdiction, that provider still has to follow the laws of that jurisdiction, including the laws that define what process is due in a particular situation. Finally, I note that Staff is using the 24-hr timeframe as the default in the document instead of one business day as agreed by the registrars. Since one business day is what the registrars have agreed to, should it not be the default until otherwise determined? Steve’s comments: I have suggested putting the two options in square brackets, don’t care which one is listed first. sara bockey sr. policy manager | GoDaddy™ sbockey(a)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: Tuesday, April 17, 2018 at 10:53 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. For those who could not attend, I regret that we were unable to record this meeting (an issue with a new internal recording policy), but this was a one-time issue and all future meetings will be recorded. I’ve done my best to annotate the LEA specification document with the items we discussed, and have also attached the chat transcript. IRT Action Items We are nearing the completion of discussions on the LEA Specification. Other than the item of clear disagreement among members of the IRT—the time period for high priority requests—we are largely in the refining stage. To that end, we have a few final proposed edits for the group to review and comment on—including some edits that were originally suggested by Sara Bockey a few weeks ago and supported by many registrar members of the IRT. If we don’t hear any opposition to these edits that would warrant further discussion, we will make these edits as requested in the draft we publish for comment. Today, we considered whether the LEA Framework Specification would be clearer if we reorganized it slightly, to make more clear where processes apply to high priority requests and when they don’t. I’ve included two versions of the draft—the one with “orig” at the end of the title—which includes the proposed edits without reorganizing, and the “reorganized” one. Please review both and respond to the list with your thoughts about the proposed reorganizing of this. Please provide any additional input you have on this draft no later than next Friday, 27 April. Please note, specifically, questions in the following sections: Original Numbering Reorganized Version Section 2.1.10 (addition of “except in high priority” language at beginning of edit) Same section Section 3.2.1 (addition of the words “Standard Priority” to make clear this 2 business day receipt process doesn’t apply in high priority cases) Moved to Section 3.2.2 Section 4.2.2 (inclusion of “without limitations” language, plus input about and question from Steve Metalitz—any other reasons that registrars feel would be reasonable for refusing disclosure?); Also see feedback, generally, from PSWG liaison, in meeting chat transcript (most pasted into specification document but cuts off at the end) Same section Section 4.2.2.5 (is this redundant? ) Same section Section 4.2.6 (is this redundant?) Same section I’m also attaching the most recent draft de-accreditation procedure document. As mentioned on the list last week, upon further consideration on the ICANN org side we think we should add back in the proposed transition procedure for customers impacted by the de-accreditation or termination of a third-party provider (section 4). Please review and provide any further comments on this no later than 27 April. For next week, we are hoping to have the requested fees information ready for you to discuss. I’ll update you as soon as I can. 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 www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann(a)key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann(a)key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone. _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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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1 May PP IRT meeting canceled
by Amy Bivins April 27, 2018

April 27, 2018

Dear Colleagues, We will not have a privacy/proxy IRT meeting this upcoming Tuesday, 1 May, as we don't have any new items to discuss next week. ICANN org intends to have the more detailed document on the fees-setting process, as referenced by Xavier Calvez on Tuesday's call, ready to share with the IRT by the end of next week. In terms of overall timeline, we are currently doing final reviews of the draft accreditation agreement and doing some outreach to the data escrow agents with respect to the draft escrow specification. We will need to discuss both with you prior to proceeding to the public comment period, so it's looking like it will be at least late May by the time we are able to reach that point. Thanks, and have a great weekend. 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] FW: PP fees document from ICANN61 attached
by Darcy Southwell April 26, 2018

April 26, 2018

Amy, given the activity that took place during the meetings on April 17 and 24, and the follow up requests by email regarding fees, what is your new estimate timeline for publication? The last estimate was late April/early May, but the same fee-related information is still at issue. Thanks, Darcy 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> Date: Tuesday, April 24, 2018 at 7:26 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached From: Amy Bivins Sent: Tuesday, April 24, 2018 10:20 AM To: Chris Pelling <chris(a)netearth.net> Subject: PP fees document from ICANN61 attached 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 www.icann.org _______________________________________________ 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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Re: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached
by Michele Neylon - Blacknight April 25, 2018

April 25, 2018

Amy et al Will ICANN be providing a detailed breakdown and rationale for the proposed fees structure? We’ve been asking for this for some time and to the best of my knowledge nothing in writing beyond the very high level fees list has been forthcoming. 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 Amy Bivins <amy.bivins(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday 24 April 2018 at 15:26 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached From: Amy Bivins Sent: Tuesday, April 24, 2018 10:20 AM To: Chris Pelling <chris(a)netearth.net> Subject: PP fees document from ICANN61 attached 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] FW: PP fees document from ICANN61 attached
by Michelle DeSmyter April 25, 2018

April 25, 2018

Hi Seth, Thank you, I will go ahead and remove you from the mailing list. Best regards, Michelle From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Seth M Reiss <seth.reiss(a)lex-ip.com> Organization: Seth M Reiss, AAL, ALLLC Reply-To: "seth.reiss(a)lex-ip.com" <seth.reiss(a)lex-ip.com>, "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Wednesday, April 25, 2018 at 12:05 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached Please remove me from this list. Thank you. Seth Reiss From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Wednesday, April 25, 2018 2:36 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached Hi Michele and all, Yes. ICANN will provide an explanation in writing (building upon Xavier’s presentation yesterday) about the factors that were used to reach the proposed fees structure (estimated costs being one of the three factors that influenced the proposal). We hope to have this for the group next week. Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Michele Neylon - Blacknight Sent: Wednesday, April 25, 2018 5:18 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached Amy et al Will ICANN be providing a detailed breakdown and rationale for the proposed fees structure? We’ve been asking for this for some time and to the best of my knowledge nothing in writing beyond the very high level fees list has been forthcoming. 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<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Tuesday 24 April 2018 at 15:26 To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: [Gdd-gnso-ppsai-impl] FW: PP fees document from ICANN61 attached From: Amy Bivins Sent: Tuesday, April 24, 2018 10:20 AM To: Chris Pelling <chris(a)netearth.net<mailto:chris@netearth.net>> Subject: PP fees document from ICANN61 attached 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[icann.org]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMGaQ&…>

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FW: PP fees document from ICANN61 attached
by Amy Bivins April 24, 2018

April 24, 2018

From: Amy Bivins Sent: Tuesday, April 24, 2018 10:20 AM To: Chris Pelling <chris(a)netearth.net> Subject: PP fees document from ICANN61 attached 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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Agenda for today's PP IRT call
by Amy Bivins April 24, 2018

April 24, 2018

Dear Colleagues, On the PP IRT call this morning (starting in about 90 minutes at 1400 UTC) we will have Xavier Calvez joining us to provide an overview of how ICANN org developed the PP IRT fees proposal. Xavier will also be available to answer any questions. I'm aware that there is a community call on GDPR starting at 1500 UTC, so we plan to wrap up before that call begins, as I know many of you will likely be attending that meeting. I look forward to meeting with you shortly. 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] Agenda for today's PP IRT call
by Michele Neylon - Blacknight April 24, 2018

April 24, 2018

What “community call” on GDPR? -- 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 Amy Bivins <amy.bivins(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday 24 April 2018 at 13:34 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda for today's PP IRT call Dear Colleagues, On the PP IRT call this morning (starting in about 90 minutes at 1400 UTC) we will have Xavier Calvez joining us to provide an overview of how ICANN org developed the PP IRT fees proposal. Xavier will also be available to answer any questions. I’m aware that there is a community call on GDPR starting at 1500 UTC, so we plan to wrap up before that call begins, as I know many of you will likely be attending that meeting. I look forward to meeting with you shortly. 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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Remove, unsubscribe
by Denise Michel April 19, 2018

April 19, 2018

Please remove me from this group and unsubscribe me from this email list. Thanks Denise Michel Domain Name System Strategy & Management Facebook, Inc. denisemichel(a)fb.com<mailto:denisemichel@fb.com>

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Notes, action items from today's PP IRT meeting--feedback requested by 27 April
by Amy Bivins April 17, 2018

April 17, 2018

Dear Colleagues, Thank you for your participation on today's privacy/proxy IRT call. For those who could not attend, I regret that we were unable to record this meeting (an issue with a new internal recording policy), but this was a one-time issue and all future meetings will be recorded. I've done my best to annotate the LEA specification document with the items we discussed, and have also attached the chat transcript. IRT Action Items We are nearing the completion of discussions on the LEA Specification. Other than the item of clear disagreement among members of the IRT-the time period for high priority requests-we are largely in the refining stage. To that end, we have a few final proposed edits for the group to review and comment on-including some edits that were originally suggested by Sara Bockey a few weeks ago and supported by many registrar members of the IRT. If we don't hear any opposition to these edits that would warrant further discussion, we will make these edits as requested in the draft we publish for comment. Today, we considered whether the LEA Framework Specification would be clearer if we reorganized it slightly, to make more clear where processes apply to high priority requests and when they don't. I've included two versions of the draft-the one with "orig" at the end of the title-which includes the proposed edits without reorganizing, and the "reorganized" one. Please review both and respond to the list with your thoughts about the proposed reorganizing of this. Please provide any additional input you have on this draft no later than next Friday, 27 April. Please note, specifically, questions in the following sections: Original Numbering Reorganized Version Section 2.1.10 (addition of "except in high priority" language at beginning of edit) Same section Section 3.2.1 (addition of the words "Standard Priority" to make clear this 2 business day receipt process doesn't apply in high priority cases) Moved to Section 3.2.2 Section 4.2.2 (inclusion of "without limitations" language, plus input about and question from Steve Metalitz-any other reasons that registrars feel would be reasonable for refusing disclosure?); Also see feedback, generally, from PSWG liaison, in meeting chat transcript (most pasted into specification document but cuts off at the end) Same section Section 4.2.2.5 (is this redundant? ) Same section Section 4.2.6 (is this redundant?) Same section I'm also attaching the most recent draft de-accreditation procedure document. As mentioned on the list last week, upon further consideration on the ICANN org side we think we should add back in the proposed transition procedure for customers impacted by the de-accreditation or termination of a third-party provider (section 4). Please review and provide any further comments on this no later than 27 April. For next week, we are hoping to have the requested fees information ready for you to discuss. I'll update you as soon as I can. 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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Items for PP IRT discussion on Tuesday
by Amy Bivins April 17, 2018

April 17, 2018

Dear Colleagues, Attached are updated documents for discussion on Tuesday's Privacy/Proxy IRT call, at 1400 UTC: 1. Updated draft de-accreditation procedure 2. Updated LEA Framework Specification markup On our call Tuesday, I'll walk you through the updates that have been made to the de-accreditation procedure based on your feedback. Please come prepared to discuss any further feedback you may have on this document, particularly the re-introduction of a proposed transition procedure that could be used to attempt to transfer impacted customers to a new provider if a provider is de-accredited. We considered whether to remove this process in the prior draft, due to practical concerns, but upon further consideration we think this process should be included, with the caveat that once it is tested adjustments may be needed to make the process work. For the updated markup of the LEA framework specification, the goal is to determine whether we have consensus among IRT members to adopt any of the changes proposed by registrar members of the IRT. There appears to be strong support for many of these proposed changes, so unless there is opposition to changes they can be incorporated into the draft. It's clear that the 24-hour response time proposed by the PSWG for high-priority requests does not have consensus support of the IRT, so we plan to call out this section specifically during the public comment period for community feedback. I hope to also have an update for you on data escrow next week and, if not, soon thereafter. As Adobe Connect is still unavailable, Michelle will circulate alternative information for you to dial in for the meeting. 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] Items for PP IRT discussion on Tuesday
by Sara Bockey April 16, 2018

April 16, 2018

Hi Amy, I hate to be nitpicky, I noticed in the revised LEA Spec you are stating that only Eric and Volker supported my proposal. Theo and Chris Pelling also noted their support. Please revise your records to accurately reflect this. Thanks, 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: Wednesday, April 11, 2018 at 11:32 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday Dear Colleagues, Attached are updated documents for discussion on Tuesday’s Privacy/Proxy IRT call, at 1400 UTC: 1. Updated draft de-accreditation procedure 2. Updated LEA Framework Specification markup On our call Tuesday, I’ll walk you through the updates that have been made to the de-accreditation procedure based on your feedback. Please come prepared to discuss any further feedback you may have on this document, particularly the re-introduction of a proposed transition procedure that could be used to attempt to transfer impacted customers to a new provider if a provider is de-accredited. We considered whether to remove this process in the prior draft, due to practical concerns, but upon further consideration we think this process should be included, with the caveat that once it is tested adjustments may be needed to make the process work. For the updated markup of the LEA framework specification, the goal is to determine whether we have consensus among IRT members to adopt any of the changes proposed by registrar members of the IRT. There appears to be strong support for many of these proposed changes, so unless there is opposition to changes they can be incorporated into the draft. It’s clear that the 24-hour response time proposed by the PSWG for high-priority requests does not have consensus support of the IRT, so we plan to call out this section specifically during the public comment period for community feedback. I hope to also have an update for you on data escrow next week and, if not, soon thereafter. As Adobe Connect is still unavailable, Michelle will circulate alternative information for you to dial in for the meeting. 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] Items for PP IRT discussion on Tuesday
by Michele Neylon - Blacknight April 16, 2018

April 16, 2018

Amy I would hope that our repeated queries about the fee structure are addressed before Staff proceeds to put this out for public comment. 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 Amy Bivins <amy.bivins(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Monday 16 April 2018 at 15:17 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday Dear Colleagues, This is a reminder that on tomorrow’s IRT call, we will be discussing the following: 1. any feedback you have on the current draft of the de-accreditation procedure (the change in this version of the draft is that we’ve added back in a draft ICANN-facilitated transition procedure that can be used to try to transition customers to a new provider in the event a provider is terminated). 2. the draft LEA disclosure framework specification. We will go through the most recent edits proposed by Sara Bockey and supported by many other registrars in the group to determine whether there is sufficient support in the IRT to incorporate these edits into the draft that will be published for public comment. We are planning to use the Zoom conferencing software for the call, and Michelle will be circulating login information to the list later today. If there are any issues with using Zoom, we will revert to using a phone bridge only, but are hoping to have Zoom so that we can review the LEA framework specification markup together in real time. As this is a new (to us) program, please long in early if you can to get a feel for how it works. Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Wednesday, April 11, 2018 2:32 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday Dear Colleagues, Attached are updated documents for discussion on Tuesday’s Privacy/Proxy IRT call, at 1400 UTC: 1. Updated draft de-accreditation procedure 2. Updated LEA Framework Specification markup On our call Tuesday, I’ll walk you through the updates that have been made to the de-accreditation procedure based on your feedback. Please come prepared to discuss any further feedback you may have on this document, particularly the re-introduction of a proposed transition procedure that could be used to attempt to transfer impacted customers to a new provider if a provider is de-accredited. We considered whether to remove this process in the prior draft, due to practical concerns, but upon further consideration we think this process should be included, with the caveat that once it is tested adjustments may be needed to make the process work. For the updated markup of the LEA framework specification, the goal is to determine whether we have consensus among IRT members to adopt any of the changes proposed by registrar members of the IRT. There appears to be strong support for many of these proposed changes, so unless there is opposition to changes they can be incorporated into the draft. It’s clear that the 24-hour response time proposed by the PSWG for high-priority requests does not have consensus support of the IRT, so we plan to call out this section specifically during the public comment period for community feedback. I hope to also have an update for you on data escrow next week and, if not, soon thereafter. As Adobe Connect is still unavailable, Michelle will circulate alternative information for you to dial in for the meeting. 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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PP IRT meeting cancelled next week
by Amy Bivins April 6, 2018

April 6, 2018

Dear Colleagues, The privacy/proxy IRT meeting scheduled for next Tuesday, 10 April, has been canceled, because new materials are still being finzlied for IRT review. The several recent cancelations will impact our overall timeline and projected date for proceeding to public comment. We will provide updated materials for IRT review as soon as they are ready, and I hope to be able to update you next week on overall status/timeline issues. Thanks, and have a great weekend. 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] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins)
by Sara Bockey April 3, 2018

April 3, 2018

Amy, Following our F2F discussion on Sunday, many of us have continuing and renewed concerns regarding the LEA spec, in particular the high priority disclosure framework and Section 4.2. After much discussion and many options being put to staff, 4.1.2 has devolved to a “compromise” which is basically the exact same language we started with 6 months ago, with the exception of adding “in accordance with Section 4.2.” As such, we are very concerned that the LEA Spec as written creates a presumption of disclosure and means to bypass due process. Additionally, it is important to remember that this is an accreditation program for ALL Privacy/Proxy Providers around the globe. That means that LEA requests come from LEA in all sorts of countries, and the language in the accreditation agreement need to reflect that. We cannot take an American-centric view. We need to bolster the language in 4.2 to better protect the rights of the Provider and its customers. Therefore, if we are to consider/accept the current proposed high priority language, namely: “Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority.” Then the following amendments must be made to Section 4.2 (new language in bold below): 4.2. Disclosure: 4.2.1. Within the applicable timeframe for a request’s Priority Level, Provider will disclose to the LEA Requestor, using a secure mechanism (this must be defined), the Requested Information it holds [associated with] the account. 4.2.2. Disclosure can be reasonably refused by Provider for reasons consistent with the general policy stated herein, including without limitations any of the following: 4.2.2.1. The LEA Requestor failed to provide to Provider information to meet the minimum standard for acceptance as outlined in Section 2 of this Specification; 4.2.2.2. If disclosure would lead to a contravention of applicable law; or 4.2.2.3. Where the Customer has provided, or Provider has found, specific information, facts, or circumstances showing that disclosure will endanger the safety of the Customer. 4.2.2.4. Where Provider has requested a court order/warrant/subpoena and LEA Requestor was unable or unwilling to provide same. 4.2.2.5. Where Provider has not been able to verify the identity of the LEA Requestor. (We also need to determine how Providers can best verify the identity of the requestor in a timely fashion. This can at times be very time consuming.) 4.2.2.6. Where Provider has found, after investigation, that LEA Requestor’s request is not well founded. 4.2.3. If disclosure is refused by Provider, Provider must provide written notice (which may be by electronic communication) to the LEA Requestor setting for Provider’s specific reasons for refusing to disclose. Such notice must be provided by Provider to the LEA Requestor prior to any Customer notification by Provider, irrespective of the reason for refusal. 4.2.4. In exceptional circumstances, if Provider requires additional time to respond to the LEA Requestor, Provider shall inform the LEA Requestor of the cause of the delay and agree with the LEA Requestor on a new date by which it will provide its response under this Section. 4.2. 4.2.5. For all refusals made in accordance with the policy and requirements herein, Provider must accept and give due consideration to the LEA Requestor’s requests for reconsideration of the refusal to disclose. 4.2.6. Nothing in Section 4.2 above shall be interpreted nor is it intended to imply the Provider shall forego due process within its applicable jurisdiction to satisfy LEA Requestor’s request, regardless of Priority Level. Finally, I believe you were wanting to know if it was acceptable to have Escrow separate from the PPAA. I believe that is the case for the RAA, so I do not see an issue with having it separate from the PPAA. 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: Sunday, March 11, 2018 at 6:24 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins) Dear Colleagues, Attached you will find a document that a member of the finance team will be discussing during our session starting in a few minutes. In addition, you’ll be hearing an update about ongoing discussions between registrar and PSWG members of the IRT related to the draft LEA disclosure framework specification. This language was discussed informally among a smaller group this afternoon. Registrar and PSWG members of the IRT appear to be nearing agreement on a proposal for presentation to the IRT that would include a 24-hour time frame for provider responses to high priority LEA requests, with some additional requirements for documentation demonstrating that the request is high priority. The updated draft language for Section 4.1.2 for further discussion (deletions shown as strikeouts, additions in blue) is currently: * “Where a disclosure request has been categorized as High Priority, this must be actioned responded to within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority.” In addition, staff was asked to provide suggestions for additional details that can be specified about what goes into a High Priority requests. Staff has proposed the following as a starting point. * “For High Priority requests, in addition to the requirements specified in Section 2.1.*, LEA Requesters should provide specific information demonstrating that the request is necessary due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation”. (Note: Section 2.1 is the section that lists all the details currently needed for a request.) We will be discussing these during the session and soliciting further feedback on the list afterward. 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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No PP IRT meeting tomorrow
by Amy Bivins April 2, 2018

April 2, 2018

Dear Colleagues, As we are still working to finalize data escrow-related materials for you, we are cancelling tomorrow's IRT meeting. I'm hoping to be able to send the data escrow-related materials to you by mid-week, so that you have plenty of time to review before we discuss on our call next week. 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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