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@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@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Tuesday, April 17, 2018 at 10:53 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>