This message was supposed to have gone to the entire list. My apologies for not catching it earlier. Alan

Date: Fri, 02 Nov 2018 22:51:15 -0400 To: Matt Serlin <matt@brandsight.com> From: Alan Greenberg <alan.greenberg@mcgill.ca> Subject: Re: [Gnso-epdp-team] Small Team #1

Good questions.

As a first approximation (and without taking the time to fully analyze this), one could use the Organization field to determine status (as I believe some registrars do now) serving notice to the registrant (through the registrar contact) just as you would of there is a renewal without a credit card on file or if the credit card had expired. If there is no contact established using the registrar's best contact details, on renewal use the presumed status based on Org field, having fully tract the attempts to contact registrant without any reply. I presume you would in parallel change your terms and conditions (as all registration agreements allow) to advise of how you will be treating this.

Registrars have in the last weeks suggesting that we completely eliminate some fields such as admin or tech contact. Surely if we were to do that the registrar would have to contact a registrant who had unique values in those fields asking for direction on how to proceed. Or would you just arbitrarily make changes without the registrant knowing??

Alan

At 02/11/2018 10:22 PM, you wrote:

...

Thanks Alan for the perspective...may I ask what you envision would happen if a registrant of an existing domain name does not provide information about whether they are a natural or legal person by the “hard deadline” you describe below? Would the domain name then be revoked? Would the registrar be expected to make that determination in the absence of a response from the registrant?

Thank you for the clarification.

Regards, Matt

...

On Nov 2, 2018, at 8:13 PM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:

There are sufficient competing redline versions that I will not contribute another. We support the edits recently proposed by the GAC.

However, I wish to make it clear that in the view of the ALAC, the end-point must be that the WHOIS/RDS record distinguish between natural and legal persons. It is fine to defer the implementation plan, but that plan must end with all every gTLD record be flagged as to whether the registrant is a legal or natural person. It is appreciated that this cannot happen overnight, but at worst, the implementation must set a hard deadline, preferably no later than the next registration renewal.

Alan

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