Thanks for getting this out so promptly, Amy.

Apologies if I was not clear enough in what I was suggesting regarding re-organization of the receipt and processing provisions. I had in mind something like the following (attached, and pasted below). I’ve used brackets to indicate the unresolved issue of response deadline for High Priority requests.

3.2. Receipt and Processing: Standard Priority Request

3.2.1. Within two business days (as observed in the location of Provider’s principal place of business) of a Standard Priority disclosure request being submitted by a LEA Requestor, Provider will review the request and confirm to the LEA Requestor it has been received and contains the relevant information required to meet the minimum standard for acceptance. If the request does not meet the minimum standard for acceptance, Provider will notify the LEA Requestor.

3.2.2. Where the LEA Requestor is not known to Provider, Provider will verify the identity of the LEA Requestor.

3.2.3. Upon completion of the receipt process specified in Section 3.2.1 of this Specification, Provider will seek to action, in accordance with Sections 4.2 and 4.3 of this Specification, a Standard Disclosure request in accordance with the deadline specified in the request. If Provider cannot adhere to such deadline, Provider should notify the LEA Requestor and provide a reasonable timeframe for response.

3.3. Receipt and Processing: High Priority Request

3.3.1. The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority. Where a disclosure request has been categorized as High Priority, this must be actioned, in accordance with Section 4.2. and 4.3, within [24 hours] [one business day, as observed in the location of the Provider’s principal place of business] of receipt by Provider.

Steve

Steven J. Metalitz | Partner, through his professional corporation

T: 202.355.7902 | met@msk.com

Mitchell Silberberg & Knupp LLP | www.msk.com

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

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From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins
Sent: Tuesday, April 17, 2018 1:53 PM
To: 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