This strikes me as a apples / oranges type situation. 

James' suggestion was for the ORG field, and was a concession as it represents a relatively low risk, this does not flow to Registrant data. There is a chasm of difference in consent for an ORG field and Consent for the publication of all registrant data. 

 I shall be blunt, it worries me that this distinction is not even contemplated in the suggestion. 

So, that would be a no for me. This simply ignores the serious concerns of those parties bearing the risks, which have now been stated on the record, umpteen times. 

Alan

Alan Woods Senior Compliance & Policy Manager, Donuts Inc. The Victorians,  15-18 Earlsfort Terrace Dublin 2, County Dublin Ireland

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On Wed, Feb 6, 2019 at 5:24 PM Marika Konings <marika.konings@icann.org> wrote:

Margie, James, all,

 

In relation to the BC comment:

 

“RECOMMENTATION  REGARDING CONSENT Page 19 – Line 549  please delete  “as soon as commercially reasonable”.  Instead, this recommendation should track the dates for implementation under the transition plan that James and the registrars proposed in Toronto.”

 

Could you please provide further details in relation to what is referred to with ‘the transition plan that James and the registrars proposed’ and how that would affect the recommendation?

 

As a reminder, this new recommendation (modelled on the existing Temp Spec language) currently reads as follows:

 

“The EPDP Team recommends that, as soon as commercially reasonable, Registrar must provide the opportunity for the Registered Name Holder to provide its Consent to publish additional contact information”.

 

Best regards,

 

Caitlin, Berry and Marika

 

Marika Konings

Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN) 

Email: marika.konings@icann.org  

 

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