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Re: [Gdd-gnso-ppsai-impl] [Ext] Re: PP fees proposal document attached
by Jennifer Gore June 13, 2018

June 13, 2018

Thanks Chris for your feedback. As a reminder the nature of ICANN staff role during the IRT phase greatly differs from the Working Group phase. ICANN has taken the concerns of IRT members into consideration. If you are seeking additional materials, I kindly as you to be very specific in the information you are seeking. Best Regards, Jennifer Gore From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Chris Pelling <chris(a)netearth.net> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Wednesday, June 13, 2018 at 3:07 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org>, gtheo <gtheo(a)xs4all.nl> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: PP fees proposal document attached Hi Amy, Its astounding that icann org have literally taken no notice of the concerns the IRT have about the representation of the fee structure. Is it no wonder half of us no longer bother to interact with giving feedback as icann simply do as they please anyway? If took months for icann to "back up" their fee structure and what was provided was simply third grade material. Sent by Chris on the move. -------- Original message -------- From: Amy Bivins <amy.bivins(a)icann.org> Date: 13/06/2018 19:12 (GMT+01:00) To: gtheo <gtheo(a)xs4all.nl>, gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: PP fees proposal document attached Dear Colleagues, Thank you for taking the time to review and provide feedback on the privacy and proxy service provider accreditation fees-related documentation, both on the list and during the meetings we have recently had on this topic. ICANN org has carefully considered the feedback of all IRT members in developing the proposed fee structure. Despite recommendations from some IRT members to reduce the proposed fees, ICANN org continues to believe that the fees proposed are reasonable and appropriate, for the reasons identified in the fees proposal documentation (attached). As noted in the fees proposal, ICANN org analyzed three relevant factors in reaching the fee structure that was proposed: relevant benchmarks; fees transparency, simplicity, stability and predictability; and anticipated program management costs. ICANN org understands that some IRT members disagree with this assessment, but did not find any of the arguments or suggestions raised by IRT members persuasive. If persuasive reasons are raised for revisiting the proposed fee structure during the public comment period, ICANN org commits to revisit the proposed fees. Please know that ICANN org sincerely appreciates the time and effort you committed to this exercise and the broader work of the IRT. Best, Amy -----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Wednesday, May 23, 2018 10:04 AM To: gdd-gnso-ppsai-impl(a)icann.org Cc: Amy Bivins <amy.bivins(a)icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] PP fees proposal document attached Thanks Amy, Am I reading this correctly? The program startup and application processing is going to cost; 1,117,390??? That is a huge amount of money for a program startup if only a few providers signup for this and the majority decides that the temporary spec or it's successor is enough privacy for registrants. But maybe I am reading it incorrectly. When I look at the Activity Relevant Department(s) Accredited Provider Account Management Services, it seems many of these activities already exist for Registrars. Can those activities not be handled by the same folks? I mean does it matter if a Registrar changes its name or a Privacy Provider? It's the same type of processing is it not? Also, a question about the PP Data Retention Waiver activity. What is this activity? Thanks, Theo Amy Bivins schreef op 2018-05-22 10:20 PM: > Dear Colleagues, > > Attached, you will find additional information related to the proposed > fees for the privacy and proxy service provider accreditation program. > Please review and send any comments/questions to the list. > > Thank you for your patience. > > 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 [1] > > > > Links: > ------ > [1] > https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw > ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T > plkjKTey9bgtdWrvLyZDu0mXuk&m=BJtpG8Olp_3NAmSVAsUTW_HmMsKblc3_3k59uUScn > vs&s=YBcBo-2U5vstASdpDcav-4W8w712XbFjerD180TrPRo&e= > _______________________________________________ > 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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Re: [Gdd-gnso-ppsai-impl] [Ext] Re: PP fees proposal document attached
by Chris Pelling June 13, 2018

June 13, 2018

Hi Amy, Its astounding that icann org have literally taken no notice of the concerns the IRT have about the representation of the fee structure. Is it no wonder half of us no longer bother to interact with giving feedback as icann simply do as they please anyway? If took months for icann to "back up" their fee structure and what was provided was simply third grade material. Sent by Chris on the move. -------- Original message --------From: Amy Bivins <amy.bivins(a)icann.org> Date: 13/06/2018 19:12 (GMT+01:00) To: gtheo <gtheo(a)xs4all.nl>, gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: PP fees proposal document attached Dear Colleagues, Thank you for taking the time to review and provide feedback on the privacy and proxy service provider accreditation fees-related documentation, both on the list and during the meetings we have recently had on this topic. ICANN org has carefully considered the feedback of all IRT members in developing the proposed fee structure. Despite recommendations from some IRT members to reduce the proposed fees, ICANN org continues to believe that the fees proposed are reasonable and appropriate, for the reasons identified in the fees proposal documentation (attached). As noted in the fees proposal, ICANN org analyzed three relevant factors in reaching the fee structure that was proposed: relevant benchmarks; fees transparency, simplicity, stability and predictability; and anticipated program management costs. ICANN org understands that some IRT members disagree with this assessment, but did not find any of the arguments or suggestions raised by IRT members persuasive. If persuasive reasons are raised for revisiting the proposed fee structure during the public comment period, ICANN org commits to revisit the proposed fees. Please know that ICANN org sincerely appreciates the time and effort you committed to this exercise and the broader work of the IRT. Best, Amy -----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Wednesday, May 23, 2018 10:04 AM To: gdd-gnso-ppsai-impl(a)icann.org Cc: Amy Bivins <amy.bivins(a)icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] PP fees proposal document attached Thanks Amy, Am I reading this correctly? The program startup and application processing is going to cost; 1,117,390??? That is a huge amount of money for a program startup if only a few providers signup for this and the majority decides that the temporary spec or it's successor is enough privacy for registrants. But maybe I am reading it incorrectly. When I look at the Activity Relevant Department(s) Accredited Provider Account Management Services, it seems many of these activities already exist for Registrars. Can those activities not be handled by the same folks? I mean does it matter if a Registrar changes its name or a Privacy Provider? It's the same type of processing is it not? Also, a question about the PP Data Retention Waiver activity. What is this activity? Thanks, Theo Amy Bivins schreef op 2018-05-22 10:20 PM: > Dear Colleagues, > > Attached, you will find additional information related to the proposed > fees for the privacy and proxy service provider accreditation program. > Please review and send any comments/questions to the list. > > Thank you for your patience. > > 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 [1] > > > > Links: > ------ > [1] > https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw > ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T > plkjKTey9bgtdWrvLyZDu0mXuk&m=BJtpG8Olp_3NAmSVAsUTW_HmMsKblc3_3k59uUScn > vs&s=YBcBo-2U5vstASdpDcav-4W8w712XbFjerD180TrPRo&e= > _______________________________________________ > 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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Re: [Gdd-gnso-ppsai-impl] No PP IRT Meeting on Tuesday
by Sara Bockey June 11, 2018

June 11, 2018

Thanks Amy. Can we get a copy of the latest PPAA for review? The last version I have is from February and I know several changes were made since that time. 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: Friday, June 8, 2018 at 9:36 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] No PP IRT Meeting on Tuesday Dear Colleagues, We will not have a PP IRT meeting on Tuesday, 12 June. I expect to be able to send you an updated data escrow specification, possibly with a couple of questions, toward the end of next week. Also, please note that ICANN org has published a response to the 4 May request to pause the work of this IRT. It is available on the ICANN correspondence page, https://www.icann.org/en/system/files/correspondence/atallah-to-bunton-06ju… 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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No PP IRT Meeting on Tuesday
by Amy Bivins June 8, 2018

June 8, 2018

Dear Colleagues, We will not have a PP IRT meeting on Tuesday, 12 June. I expect to be able to send you an updated data escrow specification, possibly with a couple of questions, toward the end of next week. Also, please note that ICANN org has published a response to the 4 May request to pause the work of this IRT. It is available on the ICANN correspondence page, https://www.icann.org/en/system/files/correspondence/atallah-to-bunton-06ju… 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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Agenda for Tuesday's PP IRT meeting
by Amy Bivins June 1, 2018

June 1, 2018

Dear Colleagues, We will have our regularly-scheduled Privacy/Proxy IRT meeting on Tuesday, but we aren't expecting it to be a long one. I will provide an update on the project status and timeline and will also provide an opportunity for any additional feedback you may have on the fees document that was recently distributed. As mentioned last week, ICANN is reviewing all of the proposed accreditation program materials, including against the Temporary Specification, and will bring any items that arise back to the IRT for discussion. If you have any practical examples you would like to share with the group of how PP services are operating now, in light of the approval of the Temporary Specification, please feel free to share them with the list (before our meeting or anytime) or come prepared to share on Tuesday. 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] Agenda for Tuesday's PP IRT meeting
by Sara Bockey June 1, 2018

June 1, 2018

I will not be able to attend Tuesday’s call. Please note my apologies. 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: Friday, June 1, 2018 at 12:44 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda for Tuesday's PP IRT meeting Dear Colleagues, We will have our regularly-scheduled Privacy/Proxy IRT meeting on Tuesday, but we aren’t expecting it to be a long one. I will provide an update on the project status and timeline and will also provide an opportunity for any additional feedback you may have on the fees document that was recently distributed. As mentioned last week, ICANN is reviewing all of the proposed accreditation program materials, including against the Temporary Specification, and will bring any items that arise back to the IRT for discussion. If you have any practical examples you would like to share with the group of how PP services are operating now, in light of the approval of the Temporary Specification, please feel free to share them with the list (before our meeting or anytime) or come prepared to share on Tuesday. 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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PP IRT canceled next week, status update
by Amy Bivins May 24, 2018

May 24, 2018

Dear Colleagues, The PP IRT meeting scheduled for 29 May is canceled. We expect to have an update/answer to the communications to ICANN org, requesting a pause of this group's work, to be published next week. In the interim, I can report that ICANN is reviewing all of the proposed accreditation program materials, including against the Temporary Specification, and will bring any issues that arise back to the IRT for discussion. Following any additional feedback from you on the proposed next steps on the data escrow specification (requested deadline of tomorrow, 25 May), we will finalize the data escrow-related materials for distribution and feedback. 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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PP IRT question, no meeting Tues, fees info to be distributed shortly
by Amy Bivins May 21, 2018

May 21, 2018

Dear Colleagues, This week's PP IRT meeting will be canceled, as the issues on our to-do list this week can be addressed without a call. We have one question for you, below. Please consider this issue and provide your comments on this no later than 28 May. I hope to be able to update you later this week on the status of the RrSG request (received by ICANN 4 May) to pause this IRT's work (and the COA's letter in opposition). I also expect to be able to send the fees-related documentation to you within the next couple of days. Background The IRT has recommended that, with respect to the data escrow specification, Privacy and Proxy service providers that are affiliated with an ICANN-accredited registrar should be able to meet their data escrow deposit obligations through the registrar (so the registrar would deposit the PP registration data and underlying customer data, similar to the process currently followed under the interim RAA specification). In order to achieve this result, ICANN would need to make slight updates to the Registrar Data Escrow specification, to add two required data elements for the deposit (the privacy/proxy service provider ID and the domain ID). Question: Is this an acceptable result (updating registrar data escrow specification for PP-affiliated registrars that wish to have combined data escrow deposits), or should ICANN revert to having a completely separate data escrow specification that all PPs must deposit under, regardless of whether the PP is affiliated with a registrar or not? Please note that, regardless of the answer to this question, there will be a separate PP data escrow specification for (a) third-party providers and (b) providers that work with more than 1 registrar. Based on discussions thus far, we believe the intent was the former (updating the registrar specification) but we wanted to confirm before finalizing that proposed update to the registrar specification and distributing it to the designated data escrow agents to alert them to the proposed update. 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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New Temp Spec reference
by Volker Greimann May 18, 2018

May 18, 2018

As the new Temporary Spec now contains a direct obligation with regard to privacy services: /in the case of a domain name registration where a privacy/proxy service used (e.g. where data associated with a natural person is masked), Registrar MUST return in response to any query full WHOIS data, including the existing proxy/proxy pseudonymized email./ Correctly interpreted, this means that ICANN must offer a complete and up-to-date machine readable list of privacy services along with a reference of how to automatically recognize them as part of the accreditation program because otherwise there will be no way for registries and registrars of automatically setting their records to "display". Just another point in case why the TempSpec is deeply flawed. // -- 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.

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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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