Amy, did the staff consider alternatives that would not involve any additional new fields -- for instance requiring certain words or characters in entries in existing fields? This would build upon the status quo in which a fairly reliable indication can be gleaned from the Whois record as to whether a proxy/privacy registration is involved.

Steve Metalitz

On behalf of Coalition for Online Accountability (COA) | www.onlineaccountability.net

Steven J. Metalitz | Partner, through his professional corporation

T: +1.202.355.7902 | met@msk.com

Mitchell Silberberg & Knupp LLP | www.msk.com

1818 N Street NW, 8th Floor, Washington, DC 20036

THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.

From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins
Sent: Friday, February 10, 2017 12:27 PM
To: gdd-gnso-ppsai-impl@icann.org
Subject: [Gdd-gnso-ppsai-impl] Privacy/Proxy RDDS labeling document attached for 14 Feb IRT call

Hello, All,

Attached is an initial discussion proposal for Tuesday’s IRT call, exploring how we could potentially implement the Final Report’s recommendation that, “To the extent that this is feasible, domain name registrations involving P/P service providers should be clearly labelled as such in WHOIS.” (See Final Report, p. 9)

To summarize, we have explored several possible alternatives for implementing this recommendation. The attached proposes to add four new fields, but also identifies the other possible alternatives that were considered.

We are seeking your feedback on any and all elements of this proposal, including (1) the specific fields to be added; (2) the location(s) of the new fields; and (3) ensuring that this can be implemented from an operational perspective (particularly if/when a provider is not affiliated with the registrar). Once we have discussed the new fields and the preferred locations for these fields, we will ensure the final product is consistent with the new CL&D requirements.

On Tuesday, I’ll run through the proposal briefly and also note the other alternatives that were considered but not included here. The rest of the call will be dedicated to your discussion and feedback on this. Please share any preliminary feedback on the list and I look forward to talking with you on Tuesday.

Best,
Amy

Amy E. Bivins

Registrar Policy Services 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@icann.org