Having served on the PPSAI WG, I am aligned with this view; this IRT signifies we are advancing the P/P policy perspectives established.

This aside and reflecting on the timeline, I am wondering whether on adoption of an Interim Registration Data Policy consistent with data protection and privacy principles, the privacy profile is not also established as the default for registration data compliance? And, if this is the case, whether the entire substructure for the P/P policy is not now grievously undermined?

If we accept that the privacy profile is now baseline for registration, then there could be consensus for acknowledging the current P/P policy is traumatised and on life support.

Carlton 

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Carlton A Samuels
Mobile: 876-818-1799
Strategy, Process, Governance, Assessment & Turnaround
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On Thu, 17 Oct 2024 at 14:05, Paul McGrady via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:

And for a third point of view on this, it doesn’t matter for purposes of implementing the policy if P/P services are sometimes/often/never used by bad actors or are a good/bad idea. The existential question of whether or not P/P services should allowed is not in scope for the IRT.  I hope that the IRT can get back on track and identify, with a basis beyond opinion or a desire to relitigate old issues lost during the PDP, anything that may need a fresh policy look due to changes in the technology, law, etc. since the policy was adopted.

 

Best,

Paul

 

 

 

From: Owen Smigelski via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org>
Sent: Thursday, October 17, 2024 12:01 PM
To: PPSAI IRT members, including observers <gdd-gnso-ppsai-impl@icann.org>
Cc: michael palage.com <michael@palage.com>; Owen Smigelski <owen.smigelski@namecheap.com>
Subject: [Gdd-gnso-ppsai-impl] Re: Factual Data for Our Consideration

 

I would like to highlight that this is anecdotal observations and not factual data. This is a very small subset of the likely hundred+ million domain names that use privacy/proxy services for legitimate purposes, including palage.com. 

 

The article also repeatedly highlights how the FBI thanked private partners who worked with the FBI to address this issue:

 

“This seizure is part of a coordinated response with our private sector partners to dismantle the infrastructure that cyber espionage actors use to attack U.S. and international targets,” said U.S. Attorney Ismail J. Ramsey for the Northern District of California. “We thank all of our private-sector partners for their diligence in analyzing, publicizing, and combating the threat posed by these illicit state-coordinated actions in the Northern District of California, across the United States, and around the world.” 

 

Again, I cannot comment on any involvement of Namecheap in this matter, but it appears that the FBI does not have any concerns with the use of privacy/proxy services for the seized domains. I am not sure what this intervention means to show. Are you implying that the bad actors only did the bad stuff because they were able to use a privacy or proxy service? 



On Oct 17, 2024, at 09:46, michael palage.com via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:

 

CAUTION: This email originated from outside the organization. Do not click links unless you can confirm the sender and know the content is safe.

Hello All,

 

Attached is the Public Whois information associated with the following domain names seized by the US Department of Justice, seehttps://www.justice.gov/opa/pr/justice-department-disrupts-russian-intelligence-spear-phishing-efforts

 

You will see that most of these domain names appear to have been using a privacy/proxy service.

 

Best regards,

 

Michael

 

 

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