Amy During a registrar specific meeting with Compliance in PR we asked specifically about their overall expected spend and the volume of complaints they currently handle related to privacy / proxy. Three things came out of this: 1 – Compliance does not see a large volume of complaints related to privacy / proxy 2 – Compliance has more staff budgeted for than they currently have 3 – they have no plans to increase their headcount Considering that the bulk of engagement from ICANN staff in relation to proxy / privacy is going to be around contractual enforcement I am really curious to see how ICANN intends to rationalise the proposed fees. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 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: Wednesday 28 March 2018 at 13:40 To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call. The fees information will not be ready for next week, but we will get it to you as soon as possible. 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>