Thanks so much for this feedback, Steve. I'll add this to the list of items to discuss on Tuesday. In the draft application, we eliminated that question thinking that the documentation requirement at the end could replace it-will make a note to clarify the documentation requirement in the next draft. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Metalitz, Steven Sent: Wednesday, May 24, 2017 4:44 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thanks for preparing these additional documents, Amy. One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant's standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a "business registration certificate" as a "required appendix" -so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in "documentation demonstrating that the Applicant entity is legally established and in good standing", to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities? I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://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> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, May 23, 2017 12:13 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday's Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require "implementation adjustment" (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week's meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don't hesitate to reply to the list or contact me directly.
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@icann.org<mailto:amy.bivins@icann.org<mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org>> www.icann.org<http://www.icann.org><http://www.icann.org>
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