Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
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>
Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable. Sara 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 Michele Neylon <michele@blacknight.com> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Wednesday, March 28, 2018 at 6:13 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 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>
Indeed We need to make sure the real costs are in line with the proposed fees. https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/ Theo On 28-3-2018 16:03, Sara Bockey wrote:
Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable.
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*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 Michele Neylon <michele@blacknight.com> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Wednesday, March 28, 2018 at 6:13 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
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
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>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hello All, Amy and I are currently working with our finance department to provide a detailed response regarding costs that support the proposed fee structure. Please keep in mind, this is a cost recovery effort. We anticipate the materials to be completed within the coming weeks. In the meantime, thank you in advance for your patience. Jennifer On Mar 28, 2018, at 10:49 AM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Indeed We need to make sure the real costs are in line with the proposed fees. https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/ Theo On 28-3-2018 16:03, Sara Bockey wrote: Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable. Sara 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><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Michele Neylon <michele@blacknight.com><mailto:michele@blacknight.com> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Wednesday, March 28, 2018 at 6:13 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 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><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Wednesday 28 March 2018 at 13:40 To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto: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> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Jenn, "Cost recovery" - sorry but this is what we are trying to gather - what costs are ICANN coming up with ? Lets be blunt - how many months have you had this on the table ? Clearly Jenn, this is really sounding like : 1. Lets pick a number - oh for a registrar its 4k a year - lets start there 2. Lets now *try* and justify it Its been in the document for **months**, we have requested those workings for **months** therefore please explain how you came up with 1 above then ? That should be a 5 minute reply :) I am open to answers of : i) Made it up ii) Based it on what we charge a registrar iii) Finance worked out the deficiency of the reserve kitty and we thought of the best way of plugging it - this being one of them Also as staff in compliance seem not to be expanding, this will be using existing resources, thats great, I like that, so please confirm in balance how much less you will be charging for yearly ICANN fees to registrars ? As clearly paying the same team to do the same job that they have already confirmed takes little to no time, means there is a saving somewhere. Kind regards, Chris From: "Jennifer Gore" <jennifer.gore@icann.org> To: gdd-gnso-ppsai-impl@icann.org Sent: Wednesday, 28 March, 2018 16:28:23 Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Hello All, Amy and I are currently working with our finance department to provide a detailed response regarding costs that support the proposed fee structure. Please keep in mind, this is a cost recovery effort. We anticipate the materials to be completed within the coming weeks. In the meantime, thank you in advance for your patience. Jennifer On Mar 28, 2018, at 10:49 AM, theo geurts < gtheo@xs4all.nl > wrote: Indeed We need to make sure the real costs are in line with the proposed fees. https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/ Theo On 28-3-2018 16:03, Sara Bockey wrote: BQ_BEGIN Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable. Sara sara bockey sr. policy manager | Go Daddy ™ 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 Michele Neylon <michele@blacknight.com> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Wednesday, March 28, 2018 at 6:13 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 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 www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END BQ_BEGIN _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Jen, ICANN's calculations assumed that each accreditation would cost ICANN the same amount of money (i.e., they would be creating the process anew each time). A more realistic projection would show the cost to set up the system/process, then the minimal cost of processing each application once the system is in place. Thanks, Greg From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Jennifer Gore Sent: Wednesday, March 28, 2018 8:28 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Hello All, Amy and I are currently working with our finance department to provide a detailed response regarding costs that support the proposed fee structure. Please keep in mind, this is a cost recovery effort. We anticipate the materials to be completed within the coming weeks. In the meantime, thank you in advance for your patience. Jennifer On Mar 28, 2018, at 10:49 AM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Indeed We need to make sure the real costs are in line with the proposed fees. https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/ Theo On 28-3-2018 16:03, Sara Bockey wrote: Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable. Sara sara bockey sr. policy manager | GoDaddy(tm) 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><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Michele Neylon <michele@blacknight.com><mailto:michele@blacknight.com> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Wednesday, March 28, 2018 at 6:13 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 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><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Wednesday 28 March 2018 at 13:40 To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto: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> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Cost recovery? I have heard that word too many times from ICANN to really believe in the concept, see also: NewGTLD Project. In the words of the immortal Inigo Montoya: "You *keep using that word*. I do not think it means what you think it means." Ultimately, by requiring providers to cough up these ridiculous fees, it is "setting sail for fail". Let those that want this system and that derive direct benefits pay for it by making this a part of the ICANN budget. Only then will you see widespread adoption and thereby a benefit arising from this policy. Sigh, I know why I suggested certification instead of accreditation back in the day... Volker Am 28.03.2018 um 17:28 schrieb Jennifer Gore:
Hello All,
Amy and I are currently working with our finance department to provide a detailed response regarding costs that support the proposed fee structure. Please keep in mind, this is a cost recovery effort. We anticipate the materials to be completed within the coming weeks. In the meantime, thank you in advance for your patience.
Jennifer
On Mar 28, 2018, at 10:49 AM, theo geurts <gtheo@xs4all.nl <mailto:gtheo@xs4all.nl>> wrote:
Indeed
We need to make sure the real costs are in line with the proposed fees. https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/
Theo
On 28-3-2018 16:03, Sara Bockey wrote:
Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable.
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*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 Michele Neylon <michele@blacknight.com> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Wednesday, March 28, 2018 at 6:13 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
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
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>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
I disagree, actually. Even if there were certain costs that were real, these should not be put on the shoulders of the providers. This is something the community wanted, so the costs should be borne by the community as well. A few funded travel slots less would take care of this issue. Volker Am 28.03.2018 um 16:49 schrieb theo geurts:
Indeed
We need to make sure the real costs are in line with the proposed fees. https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/
Theo
On 28-3-2018 16:03, Sara Bockey wrote:
Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable.
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*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 Michele Neylon <michele@blacknight.com> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Wednesday, March 28, 2018 at 6:13 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
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
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>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
The only explanation that makes sense is that real justification is the budget shortfall. Remember, the new gTLD program was on a cash recovery basis too, yet there are still significant funds remaining that are not paid back to the applicants. I don't feel very much inclined to agree to the contracted parties making up the shortfall. Volker Am 28.03.2018 um 16:03 schrieb Sara Bockey:
Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable.
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*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 Michele Neylon <michele@blacknight.com> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Wednesday, March 28, 2018 at 6:13 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
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
Intl. +353 (0) 59 9183072
Direct Dial: +353 (0)59 9183090
Personal blog: https://michele.blog/
Some thoughts: https://ceo.hosting/
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*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>
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-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
participants (7)
-
Chris Pelling -
DiBiase, Gregory -
Jennifer Gore -
Michele Neylon - Blacknight -
Sara Bockey -
theo geurts -
Volker Greimann