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

Re: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting
by Margie Milam Sept. 12, 2017

Sept. 12, 2017

Hi- I am sorry I cannot make today’s meeting. I’ll catch up on email, and listen to the recording. All the best, Margie From: <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: Friday, September 8, 2017 at 7:55 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting Dear Colleagues, Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it. On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you’ll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We’ve also added a fees proposal. Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list. 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<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMFAg&…>

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Re: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting
by Michele Neylon - Blacknight Sept. 11, 2017

Sept. 11, 2017

Amy Thanks for sharing this. I have several concerns. Firstly the fees that are being proposed. I cannot understand why or how ICANN can justify charging $4k / year for this to a provider. From our perspective this makes zero sense, as there is no value being provided by ICANN and the cost is very high – you’re essentially doubling how much I pay ICANN per year. Background screening – this seems to be complete overkill for an “affiliated” provider. In our case for example ICANN is going to be dealing with the same person you’ve always dealt with. If you insist on subjecting us to this kind of scrutiny I don’t mind, but I just see it as being a waste of resources. 6.5 – I thought there was no clear agreement on different labelling of whois privacy in whois? 8.3 – where on earth did that come from? 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-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: Friday 8 September 2017 at 14:55 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting Dear Colleagues, Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it. On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you’ll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We’ve also added a fees proposal. Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list. 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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Materials for 12 Sept PP IRT Meeting
by Amy Bivins Sept. 11, 2017

Sept. 11, 2017

Dear Colleagues, Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it. On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you'll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We've also added a fees proposal. Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list. 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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Materials, action items from today's Privacy/Proxy IRT call
by Amy Bivins Sept. 5, 2017

Sept. 5, 2017

Hi, All, Thanks for your attendance and participation on today's Privacy/Proxy IRT call. If you were unable to attend, I encourage you to review the recording and materials posted on the wiki, https://community.icann.org/display/IRT/5+September+2017 Please provide any additional input you have on the topics discussed today (summary provided below) no later than next Monday, 11 September. Also, please identify any additional PPAA sections that you would like to discuss. We are nearing the end of the PPAA issues list. Once we complete this, if no further topics are raised, we will move on to other unresolved items in preparation for proceeding to public comment. Summary of today's topics, questions and action items (updated issues list, with complete IRT input, attached): 1. 24/7 monitoring of abuse contact (See PPAA draft Section 3.13.1) * IRT member proposal: Remove requirement that abuse contact be monitored 24/7, as this was not in the Final Report * Background: this provision was modeled on the RAA; Section 3.13.2, provides that "Well-founded reports of Illegal Activity submitted to Provider's designated Abuse contact must be reviewed within 24 hours by an individual who is empowered by Provider to take necessary and appropriate actions in response to the report, including reports of Abuse submitted by Persons and their representatives pursuant to the Intellectual Property Disclosure Framework Specification." * IRT input received: Multiple IRT members supported deletion of the 24/7 monitoring requirement from Section 3.13.1. Some IRT members initially asked what the requirement would be instead, but upon consulting Section 3.13.2, said that this would be adequate so long as Section 3.13.2 does not change. * IRT action items: Please review sections 3.13.1 and 3.13.2 and provide any further input to the list. If no additional (or no contrary) input is received, the 24/7 monitoring requirement will be deleted from Section 3.13.1 in the next PPAA draft. 2. De-accreditation process proposal (attached) * Staff provided overview of this process proposal, which was modeled on registrar process, with modifications to accommodate Final Recommendations surrounding Customer notice and other factors. * Initial IRT feedback indicated that requiring terminating providers to notify customers may not be effective, as providers engaged in bad acts or that are out of business may not comply. * Alternative suggestions: i. Have ICANN access data escrow deposits for the purposes of identifying impacted customers (potential data protection issues here); ii. Have registrars attempt to notify customers with any information the registrar has available (issues surrounding unavailability of data); iii. Underlying issue-doing our best to notify customers vs absolute certainty that customers will be notified (may not be possible) * Additional IRT input is requested on all aspects of this proposal, particularly the issues raised on today's call, surrounding customer notices (and possible ICANN access to escrow data for that purpose). 1. Next steps on data retention * Staff provided summary of IRT input to date and proposed course of action-keep requirements in PPAA draft as-is, pending completion of community's work on GDPR issues, to avoid over-stepping or conflicts. Update PPAA requirements with anything new from GDPR work if GDPR work is completed prior to end of this IRT, or allow for amendments to PPAA immediately upon completion of GDPR work to account for results of community process. * IRT feedback: PPAA should ultimately incorporate results of GDPR work (apparent consensus here) i. Could language be added to PPAA in the meantime to allow for retention for longest period permitted under applicable law? ii. Could waivers previously granted to registrars under RAA be extended to PPs in same jurisdictions without need for new waiver applications? (1 IRT member was cautious about this approach) As always, if you would like to raise any other issues or feedback, please feel free to send to the list at anytime. I'll send an agenda and relevant materials for next week's meeting to the list by the end of this 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] Materials, Agenda for 5 Sept PP IRT Meeting
by Michele Neylon - Blacknight Sept. 4, 2017

Sept. 4, 2017

Amy et al Just browsing this quickly and I can see some serious gaps If ICANN is suspending a provider it’s due to any number of issues so relying on the same provider you’re suspending to send notices to anyone is simply not going to work. You’re probably suspending them for breaching the policies / contract etc., so I can’t imagine they’d be likely to start sending out notices at this juncture. All of the language around customer notification is linked to the provider co-operating and acting and to be frank I can’t see that happening in a lot of cases. 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-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: Friday 1 September 2017 at 15:46 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials, Agenda for 5 Sept PP IRT Meeting Hello, All, Attached is the first IRT discussion draft of the privacy/proxy provider suspension and de-accreditation procedure, which we will be discussing during Tuesday’s IRT meeting. Please review this document prior to our meeting on Tuesday. In addition, we plan to discuss the issue raised on-list by Sara Bockey, regarding the draft PPAA’s requirement for 24/7/365 monitoring of a provider’s abuse contact (modeled on the RAA). We are also planning to discuss next steps on data retention. As a reminder, please send any additional feedback you have regarding the issues discussed during Tuesday’s meeting to the list this week. 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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Materials, Agenda for 5 Sept PP IRT Meeting
by Amy Bivins Sept. 1, 2017

Sept. 1, 2017

Hello, All, Attached is the first IRT discussion draft of the privacy/proxy provider suspension and de-accreditation procedure, which we will be discussing during Tuesday's IRT meeting. Please review this document prior to our meeting on Tuesday. In addition, we plan to discuss the issue raised on-list by Sara Bockey, regarding the draft PPAA's requirement for 24/7/365 monitoring of a provider's abuse contact (modeled on the RAA). We are also planning to discuss next steps on data retention. As a reminder, please send any additional feedback you have regarding the issues discussed during Tuesday's meeting to the list this week. 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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Answer to Compliance-related question raised on Tuesday's IRT call
by Amy Bivins Aug. 31, 2017

Aug. 31, 2017

Hello, All, A question was raised on Tuesday's Privacy/Proxy IRT call about the auditing of PP data in registrar data escrow deposits (is there a check to conform that registrations listed as privacy-protected are included in the data escrow deposit, i.e., a completeness check?). I checked with the Compliance team and have a bit more information to share with you. Section 2.5 of the RAA Specification on Privacy and Proxy Registrations requires registrars to include P/P Customer contact information in Registration Data Escrow deposits, and the Registrar Data Escrow Specifications does allow for registrars to escrow both sets of data; but, there is nothing built into the existing DEA agreements that requires the DEA to follow a specific audit process that is unique to privacy and proxy registrations. The DEA does follow-up with registrars to fix any issues when there are audit failures due to discrepancies in data, and sometimes, these could be due to failure of registrars to escrow both sets of data. In the recent RFP that was published to identify one or more additional ICANN designated Registrar Data Escrow (RDE) agent(s), one of the requirements is that the proposals should account for privacy and proxy registration escrow requirements, https://www.icann.org/en/system/files/files/rfp-icann-agent-rde-services-17… I hope this helps, but please let me know if you have any other clarifying questions/concerns. 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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Notes, action items from today's Privacy/Proxy IRT call
by Amy Bivins Aug. 30, 2017

Aug. 30, 2017

Hi All, Thanks for your attendance and participation on today's Privacy/Proxy IRT call. If you couldn't attend, I encourage you to listen to the recording, which is available on the wiki, https://community.icann.org/display/IRT. We have several updates and action items today. Please review this list carefully. 1. Last week's IRT poll re: PSWG-proposed edit to PP disclosure framework. The poll results, attached as JPG screenshots, are similar to the feedback received on last week's IRT call. A few IRT members supported the adoption of the PSWG proposal, but most IRT members expressed a preference to keep the language in the current PPAA draft as-is. We have sent these results to the PSWG and asked whether the PSWG would like to discuss potential compromises any further. We'll determine next steps after hearing back from the PSWG. 2. The PPAA issues list (attached) has been updated to reflect all IRT input received on the list over the past week and today's IRT call. 3. Data Escrow: Any additional feedback on the issues raised on today's call should be sent to the list no later than this Friday, 1 September. In particular, please consider whether the proposed elements of the specification that Francisco presented seem to be going in the intended direction, or whether you believe changes are needed. 4. RDDS Labeling: Any additional feedback on the issues raised on today's call should be sent to the list no later than this Friday, 1 September. 5. Agenda for 5 Sept IRT call: De-accreditation process proposal (to be sent to the list this week); PPAA issue 26 (new! Suggested on-list by Sara Bockey, re 24/7 monitoring of abuse contact); next steps on data retention (possible) 6. Any IRT feedback on comments from list from Margie Milam re: IP framework (attached) should be sent to list no later than this Friday, 1 September. 7. Any IRT feedback on comments from list from Steve Metalitz on PPAA Sect. 3.5.4 should be sent to list no later than this Friday, 1 September. 8. Please note that draft PPAA_17July (attached) has not been updated to reflect IRT discussions to date (this is the original sent to the IRT). Once we have completed the issues list, we will distribute an updated draft v2 that reflects all changes made per the IRT's feedback, for the IRT's review. Finally, as many of you are probably aware, I am preparing to go out on maternity leave in about 3 weeks (for 12 weeks). I should be around through 22 Sept, but I wanted to alert you to this in case I'm unexpectedly out before then. Caitlin Tubergen will be providing backup support for this project while I'm away (thanks, Caitlin!), and every effort has been made to keep this project moving at the current pace in my absence. Thanks to all your hard work and dedication, this IRT's work should be ready to publish for public comment while I'm away, barring any unexpected developments. I'll be following your work while I'm out, and will be back either the week before the ICANN holiday break or the first week of 2018. Thanks for your understanding and please don't hesitate to contact me if you have 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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Off-List Re: Notes, action items from today's Privacy/Proxy IRT call
by Pam Little Aug. 29, 2017

Aug. 29, 2017

Hi Amy I have not been able to join these calls due to time zone issue (the meeting time is midnight in Sydney) but try to keep an eye on the developments. Thank you for the "notice" on your maternality leave. I thought that was very considerate of you and I hope everything goes well. All the best to you and your family! Kind regards, Pam ------------------------------------------------------------------From:Amy Bivins <amy.bivins(a)icann.org>Time:2017 Aug 30 (Wed) 02:12To:gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl(a)icann.org>; Caitlin Tubergen <caitlin.tubergen(a)icann.org>Subject:[Gdd-gnso-ppsai-impl] Notes, action items from today's Privacy/Proxy IRT call Hi All, Thanks for your attendance and participation on today’s Privacy/Proxy IRT call. If you couldn’t attend, I encourage you to listen to the recording, which is available on the wiki, https://community.icann.org/display/IRT. We have several updates and action items today. Please review this list carefully. Last week’s IRT poll re: PSWG-proposed edit to PP disclosure framework. The poll results, attached as JPG screenshots, are similar to the feedback received on last week’s IRT call. A few IRT members supported the adoption of the PSWG proposal, but most IRT members expressed a preference to keep the language in the current PPAA draft as-is. We have sent these results to the PSWG and asked whether the PSWG would like to discuss potential compromises any further. We’ll determine next steps after hearing back from the PSWG.The PPAA issues list (attached) has been updated to reflect all IRT input received on the list over the past week and today’s IRT call.Data Escrow: Any additional feedback on the issues raised on today’s call should be sent to the list no later than this Friday, 1 September. In particular, please consider whether the proposed elements of the specification that Francisco presented seem to be going in the intended direction, or whether you believe changes are needed.RDDS Labeling: Any additional feedback on the issues raised on today’s call should be sent to the list no later than this Friday, 1 September. Agenda for 5 Sept IRT call: De-accreditation process proposal (to be sent to the list this week); PPAA issue 26 (new! Suggested on-list by Sara Bockey, re 24/7 monitoring of abuse contact); next steps on data retention (possible)Any IRT feedback on comments from list from Margie Milam re: IP framework (attached) should be sent to list no later than this Friday, 1 September.Any IRT feedback on comments from list from Steve Metalitz on PPAA Sect. 3.5.4 should be sent to list no later than this Friday, 1 September. Please note that draft PPAA_17July (attached) has not been updated to reflect IRT discussions to date (this is the original sent to the IRT). Once we have completed the issues list, we will distribute an updated draft v2 that reflects all changes made per the IRT’s feedback, for the IRT’s review. Finally, as many of you are probably aware, I am preparing to go out on maternity leave in about 3 weeks (for 12 weeks). I should be around through 22 Sept, but I wanted to alert you to this in case I’m unexpectedly out before then. Caitlin Tubergen will be providing backup support for this project while I’m away (thanks, Caitlin!), and every effort has been made to keep this project moving at the current pace in my absence. Thanks to all your hard work and dedication, this IRT’s work should be ready to publish for public comment while I’m away, barring any unexpected developments. I’ll be following your work while I’m out, and will be back either the week before the ICANN holiday break or the first week of 2018. Thanks for your understanding and please don’t hesitate to contact me if you have questions. Best,Amy Amy E. BivinsRegistrar Services and Engagement Senior ManagerRegistrar Services and Industry RelationsInternet Corporation for Assigned Names and Numbers (ICANN)Direct: +1 (202) 249-7551Fax: +1 (202) 789-0104Email: amy.bivins(a)icann.orgwww.icann.org

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Re: [Gdd-gnso-ppsai-impl] Notes, Action Items from 22 August PP IRT Call [PLEASE complete poll]
by Darcy Southwell Aug. 29, 2017

Aug. 29, 2017

My apologies, but I won’t be able to make today’s meeting. Best, Darcy ---------------- Darcy Southwell | Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart From: <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, August 23, 2017 at 7:00 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 22 August PP IRT Call [PLEASE complete poll] Hello, All, Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. For those of you would could not attend, I encourage you to please listen to the recording, available on the wiki, https://community.icann.org/display/IRT/22+August+2017. Several action items resulted from this meeting: IRT: Please complete this linked poll regarding the proposed edit to the LEA framework, specification 4 of the draft PPAA, https://www.surveymonkey.com/r/2F5BGBG, no later than next Monday, 28 August. Please read the background before the first question carefully. The IRT discussion on this topic yesterday continued to demonstrate a division among the group regarding this proposed edit. The results of this poll will not be counted as a vote but are intended to ensure that we have a complete record and understanding of all IRT participants’ opinions on this topic. This is important. Please participate. There are only two substantive questions. IRT: Please provide any additional feedback no later than Monday, 28 August, on the “record-keeping” topic, issue 24 on the issues list. IRT: Please provide any additional feedback you have no later than Monday, 28 August, on the IP framework (issue 20 on the issues list), particularly the issue raised on the call, regarding the proposed addition of language from the framework’s introduction in the Final Report. IRT: Please provide any additional feedback you have no later than Monday, 28 August, on the “business dealings” section of the PPAA draft (issue 25 on the issues list). ICANN will review the “business dealings” section of the PPAA draft, per IRT feedback, to ensure that the language (when read in consultation with the rest of the contract) will not result in duplicative notice requirements (ie, customers should receive one notice (e.g. data accuracy notices), either from the provider or registrar—not both). Finally, you will notice that we are moving fairly quickly to the end of the issues list (albeit with many action items to follow up on). Please send any additional points related to the PPAA draft that you would like to discuss to the list. Once we reach the end of the issues list, if we have no further suggestions from you, we will move on to other topics. For next week’s call, we are planning to discuss data escrow and RDDS labeling. I will confirm this by Monday morning Eastern Time at the latest (we are currently working to finalize an updated draft specification for your review). 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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