I’ve been chewing on Volker’s suggestion.  Grateful for the proposal - I’d like to hear more about how it might work in practice.

 

"Registrars must ensure that registrants using their services who register domain names for the sole use of, on behalf of or for the benefit of third parties agree to... ."

 

Reactions/questions:

  1. This language would seem to cover all categories of commercial service registrants, such as p/p services, as well as resellers and ‘geographical service providers’, or any other category that might be invented in the future.  (good)
  2. Can this requirement be recursive? (I.e., assume there is a reseller who sells to another reseller – can this language be written to include passthrough obligations down the chain, nomatter how many layers of reseller may exist?)  
  3. To be explicit, this proposed text does NOT expect the registrant to “agree to” enter into a contractual relationship with ICANN, correct?
    1. If no contractual relationship, what role would ICANN Compliance have if a registrant failed to live up to their “agree to” obligations?
  4. Can this “agree to” language include a requirement both i) to notify the layer above you as to whether/not you are registering the domain name on behalf of (etc etc) another party, and ii) to pass through any such notifications you receive from the layer below you to the layer above?

<<Why do I ask this?   Simply, there is an additional goal beyond those Volker listed, though perhaps this goal is specific to Public Safety / Law Enforcement;  we also have the goal of clearly identifying the lowest layer of legitimate business closest to the end customer.   This is because that legitimate business will have important records that no one else in the registration chain will have;  knowing who this legitimate business is, and where they are (thus which nation’s LE must engage them) is important.  When registration data lacks this information (e.g. a reseller was used but not listed, or it is unclear whether/not the registrant is a p/p service), then a great deal of wasted effort and misrouted court orders may result.>>

 

Cheers,
G

 

From: Alan Greenberg via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org>
Sent: Tuesday, July 22, 2025 8:32 PM
To: PPSAI IRT members, including observers <gdd-gnso-ppsai-impl@icann.org>
Cc: Volker Greimann <volker.greimann@centralnic.com>; Jason Kean <jason.kean@icann.org>; Alan Greenberg <greenberg.alan@gmail.com>
Subject: [EXTERNAL EMAIL] - [Gdd-gnso-ppsai-impl] Re: Request for clarification on proposal | 24 July IRT Meeting Reminder

 

I can't see why it could not apply to both.

 

Alan

 

On Tue, Jul 22, 2025 at 7:20 PM Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:

Hello IRT, 

 

Thank you to Volker for his proposed alternative implementation model (proposal in email below) and to all other IRT members who have contributed to this on-list discussion. 

 

Regarding this proposal, the ICANN org team wanted to clarify whether the proposed text is referring to proxy service providers rather than privacy service providers or both.

 

Once this is clarified, subject to the group’s agreement, we suggest including this point as an alternative model for implementation under TQ.B.

 

Reminder: In preparation for the IRT session on Thursday, 24 July at 15:30 UTC, please make comments within the draft PPSAI IRT Threshold Question document on any aspect of the document that you cannot live with and provide text that you could support in your comment(s).

 

Your comments will be used to guide the session’s discussion as we work to finalize the Threshold Question document for the GNSO Council. 

 

IRT input is needed by the end of the day Friday, 25 July. 

 

We look forward to seeing everyone on Thursday!

 

 

Best,

Jason

 

Jason Kean

Sr. Manager, Reviews and Stakeholder Support

Internet Corporation for Assigned Names and Numbers (ICANN)

 

www.icann.org

 

 

From: Volker Greimann <volker.greimann@centralnic.com>
Date: Thursday, July 17, 2025 at 7:41 PM
To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org>
Cc: Jason Kean <jason.kean@icann.org>
Subject: [Ext] Re: Meeting follow-up | Scheduling of 24 July Meeting

 

Hi all,

 

one thought: Would we not be able to circumvent all the issues with whether or not (and if so how) to accredit  pp providers with one simple hack?

 

The goal ultimately is to hold privacy providers accountable and ensure they fall (essentially) under the same rules for data disclosure as registrars do already, e.g ensuring that registrants are bound by terms that we understand pp providers should follow. This would cleanly avoid all bureaucratic overhead, avoid having to differentiate between affiliated or non-affiliated providers, etc. This can be done by a simple policy requirement that would require registrars to pass along certain terms to all registrants  through their agreements, gTAC, policies or otherwise.

 

Essentially it boils down to the essence of the matter that privacy service providers are just another type of registrants.

 

"Registrars must ensure that registrants using their services who register domain names for the sole use of, on behalf of or for the benefit of third parties agree to... ." should do nicely as a starting point as there is already precedent for such requirements in other policies. 

 

Maybe this could also be brought to the GNSO as an option when they address our concerns regarding the issues with the non-community developed accreditation models proposed by ICANN staff. 

 

Yes, this may require a rewrite of the existing policy recommendations, but the general principles stated above that were mostly agreed would form a basis that would allow quick progress. 

 

 

 

Sincerely,

Volker Greimann
General Counsel & Head of Policy and Compliance - Online Division

volker.greimann@centralnic.com
Office: +49-172-6367025
Web: www.teaminternet.com

Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358.

 

From: Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org>
Sent: 17 July 2025 11:28 PM
To: gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl@icann.org>
Cc: Jason Kean <jason.kean@icann.org>
Subject: [Gdd-gnso-ppsai-impl] Meeting follow-up | Scheduling of 24 July Meeting

 

Hello IRT, 

 

Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document [docs.google.com].

 

As promised, we are sending out invitations for a meeting next Thursday, 24 July at 15:30 UTC to continue the discussion. Reminder: IRT input is needed by the end of the day Friday, 25 July. 

 

To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s).

 

We will use your comments to guide the discussion.

 

We look forward to seeing everyone next Thursday!

 

Best,

Jason

 

Jason Kean

Sr. Manager, Reviews and Stakeholder Support

Internet Corporation for Assigned Names and Numbers (ICANN)

 

www.icann.org

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