Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report. Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation. As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose). It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules. Accordingly, the Initial Report must include a new Recommendation: Recommendation The Phase 1 Recommendation 13 should be amended to include: Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant. Alan & Mark
Hi, I think it is not appropriate to introduce a new recommendation at the last minute that has not been deliberated and seems to me to be out of scope of this WG. While I have no objection to the content of this recommendation, and KS has already implemented its webforms in a similar manner, I think the process concern must prevail here. Best, -- Volker A. Greimann General Counsel and Policy Manager *KEY-SYSTEMS GMBH* T: +49 6894 9396901 M: +49 6894 9396851 F: +49 6894 9396851 W: www.key-systems.net Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835 CEO: Oliver Fries and Robert Birkner Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358. This email and any files transmitted are confidential and intended only for the person(s) directly addressed. If you are not the intended recipient, any use, copying, transmission, distribution, or other forms of dissemination is strictly prohibited. If you have received this email in error, please notify the sender immediately and permanently delete this email with any files that may be attached. <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> Virus-free. www.avast.com <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> <#DAB4FAD8-2DD7-40BB-A1B8-4E2AA1F9FDF2> On Tue, May 25, 2021 at 2:45 AM Alan Greenberg via Gnso-epdp-team < gnso-epdp-team@icann.org> wrote:
Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report.
Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation.
As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose).
It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules.
Accordingly, the Initial Report must include a new Recommendation:
*Recommendation The Phase 1 Recommendation 13 should be amended to include: Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant. *Alan & Mark _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
To be fair, this issue has been discussed many times during our meetings. This recommendation merely captures what has already been proposed by certain SGs. Hence I suggest that it be included for the purpose of soliciting public comments. Laureen Kapin Acting Assistant Director Division of Consumer Response and Operations Bureau of Consumer Protection Federal Trade Commission From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Volker Greimann via Gnso-epdp-team Sent: Tuesday, May 25, 2021 11:56 AM To: Alan Greenberg <alan.greenberg@mcgill.ca> Cc: EPDP <gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] Recommendation on Web Forms Hi, I think it is not appropriate to introduce a new recommendation at the last minute that has not been deliberated and seems to me to be out of scope of this WG. While I have no objection to the content of this recommendation, and KS has already implemented its webforms in a similar manner, I think the process concern must prevail here. Best, -- Volker A. Greimann General Counsel and Policy Manager KEY-SYSTEMS GMBH T: +49 6894 9396901 M: +49 6894 9396851 F: +49 6894 9396851 W: www.key-systems.net<http://www.key-systems.net/> Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835 CEO: Oliver Fries and Robert Birkner Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358. This email and any files transmitted are confidential and intended only for the person(s) directly addressed. If you are not the intended recipient, any use, copying, transmission, distribution, or other forms of dissemination is strictly prohibited. If you have received this email in error, please notify the sender immediately and permanently delete this email with any files that may be attached. [https://ipmcdn.avast.com/images/icons/icon-envelope-tick-round-orange-animated-no-repeat-v1.gif]<https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> Virus-free. www.avast.com<https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> On Tue, May 25, 2021 at 2:45 AM Alan Greenberg via Gnso-epdp-team <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>> wrote: Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report. Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation. As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose). It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules. Accordingly, the Initial Report must include a new Recommendation: Recommendation The Phase 1 Recommendation 13 should be amended to include: Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant. Alan & Mark _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org<mailto:Gnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Hi Laureen, yes, we did discuss it and always returned to the point that it was out of scope for our group. While I understand the desire to have something on webforms included, discussion was rather one-sided due to the scope. I understand from other registrars that there are many issues with input fields as part of the webforms and they have chosen the format of their forms for a reason. Best, -- Volker A. Greimann General Counsel and Policy Manager *KEY-SYSTEMS GMBH* T: +49 6894 9396901 M: +49 6894 9396851 F: +49 6894 9396851 W: www.key-systems.net Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835 CEO: Oliver Fries and Robert Birkner Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358. This email and any files transmitted are confidential and intended only for the person(s) directly addressed. If you are not the intended recipient, any use, copying, transmission, distribution, or other forms of dissemination is strictly prohibited. If you have received this email in error, please notify the sender immediately and permanently delete this email with any files that may be attached. <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> Virus-free. www.avast.com <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> <#DAB4FAD8-2DD7-40BB-A1B8-4E2AA1F9FDF2> On Tue, May 25, 2021 at 6:17 PM Kapin, Laureen <LKAPIN@ftc.gov> wrote:
To be fair, this issue has been discussed many times during our meetings. This recommendation merely captures what has already been proposed by certain SGs. Hence I suggest that it be included for the purpose of soliciting public comments.
Laureen Kapin
*Acting Assistant Director*
*Division of Consumer Response and Operations*
*Bureau of Consumer Protection*
*Federal Trade Commission*
*From:* Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> *On Behalf Of *Volker Greimann via Gnso-epdp-team *Sent:* Tuesday, May 25, 2021 11:56 AM *To:* Alan Greenberg <alan.greenberg@mcgill.ca> *Cc:* EPDP <gnso-epdp-team@icann.org> *Subject:* Re: [Gnso-epdp-team] Recommendation on Web Forms
Hi,
I think it is not appropriate to introduce a new recommendation at the last minute that has not been deliberated and seems to me to be out of scope of this WG. While I have no objection to the content of this recommendation, and KS has already implemented its webforms in a similar manner, I think the process concern must prevail here.
Best,
-- Volker A. Greimann General Counsel and Policy Manager *KEY-SYSTEMS GMBH*
T: +49 6894 9396901 M: +49 6894 9396851 F: +49 6894 9396851 W: www.key-systems.net
Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835 CEO: Oliver Fries and Robert Birkner
Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
This email and any files transmitted are confidential and intended only for the person(s) directly addressed. If you are not the intended recipient, any use, copying, transmission, distribution, or other forms of dissemination is strictly prohibited. If you have received this email in error, please notify the sender immediately and permanently delete this email with any files that may be attached.
Virus-free. www.avast.com <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>
On Tue, May 25, 2021 at 2:45 AM Alan Greenberg via Gnso-epdp-team < gnso-epdp-team@icann.org> wrote:
Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report.
Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation.
As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose).
It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules.
Accordingly, the Initial Report must include a new Recommendation:
*Recommendation The Phase 1 Recommendation 13 should be amended to include: Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant. *Alan & Mark
_______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Hi Alan - Given the absurd level of spam and abuse currently taking place on web forms, we could not support this recommendation. J. On May 24, 2021, at 17:45, Alan Greenberg via Gnso-epdp-team <gnso-epdp-team@icann.org> wrote: Caution: This email is from an external sender. Please do not click links or open attachments unless you recognize the sender and know the content is safe. Forward suspicious emails to isitbad@. Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report. Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation. As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose). It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules. Accordingly, the Initial Report must include a new Recommendation: Recommendation The Phase 1 Recommendation 13 should be amended to include: Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant. Alan & Mark _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
participants (4)
-
Alan Greenberg -
James M. Bladel -
Kapin, Laureen -
Volker Greimann