- Gdd-gnso-ppsai-impl - lists.icann.org

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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Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
by Darcy Southwell March 30, 2018

March 30, 2018

Amy, Given the edits and details below, and the March 30 deadline for further suggestions, what is staff’s expected timing for publishing for public comment? 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: Wednesday, March 28, 2018 at 5:40 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call. The fees information will not be ready for next week, but we will get it to you as soon as 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 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] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
by Michele Neylon - Blacknight March 29, 2018

March 29, 2018

Amy During a registrar specific meeting with Compliance in PR we asked specifically about their overall expected spend and the volume of complaints they currently handle related to privacy / proxy. Three things came out of this: 1 – Compliance does not see a large volume of complaints related to privacy / proxy 2 – Compliance has more staff budgeted for than they currently have 3 – they have no plans to increase their headcount Considering that the bulk of engagement from ICANN staff in relation to proxy / privacy is going to be around contractual enforcement I am really curious to see how ICANN intends to rationalise the proposed fees. 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: Wednesday 28 March 2018 at 13:40 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call. The fees information will not be ready for next week, but we will get it to you as soon as 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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Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
by Amy Bivins March 28, 2018

March 28, 2018

Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov't Agency [propose to change to "Law Enforcement Authority" here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of "subject to any additional requirements under applicable law or court order" in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I'm not sure whether the data escrow materials will be ready for next week or not. I'll update you before we meet. If we don't have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday's call. The fees information will not be ready for next week, but we will get it to you as soon as 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 reporting specification, per IRT feedback
by Amy Bivins March 26, 2018

March 26, 2018

Dear Colleagues, Attached is an updated version of the reporting specification. To summarize the changes that were made: 1. We updated the report frequency to quarterly (initial proposal was monthly) 2. We eliminated the per-TLD report requirement 3. We eliminated a few of the unnecessary fields (e.g., publication requests for IP and LEA, some of the "total" fields at the top) 4. We added a couple of fields for "other" requests (non-LEA or IP) We have considered the IRT's feedback on use of RRI. ICANN org believes that the use of RRI is preferable for both ICANN org and providers, as opposed to accepting emailed forms because: * The only difference on the provider side is using an API (the report format will be the same, and ICANN is providing a template to create the CSV file that will be submitted via the API); * Using the API will allow real-time confirmation that the report format is valid, eliminating the need for manual communications back and forth between ICANN org and the provider * ICANN org will provide training materials for using the API for providers who are unfamiliar with the process. If you have any further feedback on this, please send it to the list. 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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