April 2018 - Gnso-newgtld-wg

Actions/Discussion Notes: New gTLD Subsequent Procedures PDP WG 16 April 2018
by Julie Hedlund April 16, 2018

April 16, 2018

Dear WG Members, Please see below the action items and discussion notes captured by staff from the meeting on 16 April 2018. These high-level notes are designed to help PDP WG members navigate through the content of the call and are not meant as a substitute for the transcript or recording. The MP3, transcript, and chat room notes will be provided separately. For reference see also the attached referenced documents. Best regards, Julie Julie Hedlund, Policy Director Action Items: WG members should review the Initial Report excerpts and provide comments/edits in email to the WG list, with references to the relevant sections. Staff will explore other possibilities for WG members to provide comments/edits. Notes: 1. Updates to Statements of Interest: No updates. 2. Initial Report Excerpts: -- Sent overarching issues. -- Goal is to get all sections out by 20 April. -- People have sent in comments, some of which are opinions on the substance in the report – ask that you make sure those go into the public comment forum. We aren’t changing the substance of the report, unless we missed something that was discussed. Discussion: -- May not be realistic to submit comments in email; wonder if it would be feasible to allow edits to be made in the Google doc. Putting the comments in the email allows others on the list to see it. But staff could handle it in another form. -- Concern about holding substantive comments to the public forum. -- All of these issues were discussed by Working Group members. They were debated. The work of the Work Tracks has resulted in this Initial Report, which isn’t arranged by Work Track but more logically. Each of these subjects have been thoroughly discussed, debated, and subject to comments by the Working Group. The Initial Report is a presentation to the public on the work we have been doing, preliminary recommendations, and questions. There may be yet another report for comment. It is not the Final Report. At this point we had to put the marker down and consider substantive comments in the Public Comment period. -- The Work Track leads have reviewed the content, and the WG member can help make sure we haven’t missed anything that was raised in the deliberations of the Work Tracks or WG. -- Could be helpful to include page numbers and also links to the work tracks. -- We are preparing a document under the PDP rules that must be called an “Initial Report”. It has to have a public comment period. We are asking WG member to look at this draft to make sure we have accurately and appropriately covered the material that the Work Tracks and WG have discussed. This is not closing an opportunity for input. Wanted everyone in the WG the opportunity to review and comment on the products from the Work Tracks. -- Were there was no consensus on certain topics we’ve included questions. Need WG members to help with these questions: are these clear, do they need more/less context, do we need to add questions? -- Should not appear that any recommendations or suggestions were rejected. -- May I suggest a path forward: To the extent that WG members are submitting substantive comments/answers to questions, would it be possible to have staff arrange for the submission of those comments/answers, with the commenter's permission, once the public comment period opens with the significant caveat that it's the commenter's responsibility to make sure her/his comments/answers are submitted during the public comment period? -- Procedurally the question will be whether Working Group members agree with the characterization of the document as an Initial Report. A lot depends on the introductory paragraph in this report. It may be wise to allow a dissenting statement to be made by those who object to this process. This is in addition to suggestions on individual sections. We all need to keep in mind that we have strongly encouraged early GAC participation in PDPs. Don’t know how we can get past these objections without allowing a dissenting statement on the process. -- Concern about using the phrase “the Working Group recommends”. Suggest "No member of the Working Group objected to the structuring of the next application process in a "round". This seemed to be the favored approach. Other options discussed were as follows:" -or- "The Working Group is leaning toward a recommendation that" - or give that explanation in the Intro. -- Don’t use recommends that often, but when we do it was the leaders/co-chair judgment that it was appropriate, but if there is other language to use let us know. Or if you disagree, speak up. -- The question is whether these are in fact "Recommendations of the WG" when the requirements in the PDP Manual for Initial Report require a Consensus Call". Approach will be to include a preamble in the document to explain that a consensus call was not taken, but will be in the Final Report. Comments on Excerpts: -- If there are sections that say “none” or “not applicable” that means that nothing came out of the deliberations, not that the information was somehow missed or deliberately not included. -- Can link the sections to the work track, but the material has been provided by a number of sources. -- 1.2.1 – Continuing Subsequent Procedures: In the options section, the WG didn’t come to any consensus. If we have a preliminary recommendation then you may not see the options under section c. -- On rounds, there was discussion of specific rounds/batches. Should be smaller, quicker, and focused. -- Predictability 1.2.2.1: process for application – discussion included that documents created after the CPE should never have been included. This is be reflected in the deliberations. Key difference is that this was additional guidelines that were used by the evaluating team. They were not published until after the application process. Makes it unfair for the applicant when the only expectation was that they would be evaluated on the Guidebook. This is a practice that shouldn’t happen as it does not align with goals around predictability. ACTION: Staff should revise the deliberations of that section. Helpful to get this in an email and note where it should be included. -- Predictability framework questions: WG members should consider whether there are questions to add (page 9 of the attached document). -- I cannot see whether specific reference is made to GNSO Input, GNSO Guidance, Expedited PDP. If not, it should be added. Also, reference the consensus policy adopted by the Board.

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Initial Report Sections (With References to Work Tracks)
by Steve Chan April 16, 2018

April 16, 2018

Dear WG Members, As discussed during the Working Group call, please find a document that illustrates how the Draft Initial Report will organize the topics being included in the Initial Report. As requested, this document will tell you which Work Track discussed the topic. The document is also available on the Wiki in the Latest News section on the Wiki here: https://community.icann.org/x/RgV1Aw Best, Steve Steven Chan  Policy Director, GNSO Support ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094-2536  steve.chan(a)icann.org mobile: +1.310.339.4410 office tel: +1.310.301.5800 office fax: +1.310.823.8649 Find out more about the GNSO by taking our interactive courses and visiting the GNSO Newcomer pages. Follow @GNSO on Twitter: https://twitter.com/ICANN_GNSO Follow the GNSO on Facebook: https://www.facebook.com/icanngnso/ http://gnso.icann.org/en/

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Section 1.12 - Comments/suggestions
by Rosette, Kristina April 16, 2018

April 16, 2018

All, I've listed below some additional comments and suggestions on Section 1.12. 1. 1.12.1.e, first bullet: Need citation to statement that delegation deadline put into place to avoid squatting and warehousing 2. 1.12.1.f, 3rd sentence: Even if terms aren't precisely defined, report should provide whatever definitions are being relied upon. 3. 1.12.1.f, para 2, 4th & 5th sentences: Confusing to have "use" in quotations. Juxtaposition of sentences 4 and 5 (not clear what use is, but use satisfied) is confusing. 4. 1.12.1.f, para 3, 3rd sentence: Need to explain what constitutes "actively used" - especially given statements in preceding paragraph. 5. 1.12.1.f, para 5, 2nd sentence: It's a stretch to refer to targeted deadlines as SLAs (although I wish they had been). 6. 1.12.1.f, para 6, 3rd sentence: "in relation to this issue" is unclear. Identify the issue (e.g., in relation to X). 7. 1.12.1.f, para 6, 4th sentence: words missing after support - the view that? 8. 1.12.3.b, para 2: need citations to RA provisions 9. 1.12.3.c, 2nd sentence: replace "granular" with "detailed" and/or "more specific" 10. 1.12.3.e, question 1: need to provide basis for referring to application statements as "representations and/or commitments"; also, second-to-last question should be revised to ask commenter to explain why they've identified any specific representations and/or commitments. 11. 1.12.3.e, question 2: Need to ask "How will the proposed mechanisms effectively address these issues"? 12. 1.12.3.f, para 1, 3rd sentence: Base Registry Agreement (for consistency) 13. 1.12.3.f, para 2: revise 4th bullet - Should representations made by the applicant be integrated into the Registry Agreement going forward and, if so, why and how? 14. 1.12.3.f, para 4, 2nd sentence: insert ", non-confidential" between "additional" and "data" Talk to everyone later. K Kristina Rosette Senior Corporate Counsel, IP - Domains rosettek(a)amazon.com<mailto:rosettek@amazon.com>

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Test Message
by Aslam Mohamed April 10, 2018

April 10, 2018

Please ack receipt

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Recordings, attendance & Webex Chat | New gTLD Subsequent Procedures Working Group Call | Monday, 09 April 2018 15:00 UTC
by Julie Bisland April 9, 2018

April 9, 2018

Dear All, Please find the attendance and Webex chat of the call attached to this email, and the MP3 recording below for the New gTLD Subsequent Procedures Working Group call held on Monday, 09 April 2018 at 15:00 UTC. Attendance of the calls is also posted on the agenda wiki page: https://community.icann.org/x/TC68B MP3: https://audio.icann.org/gnso/gnso-new-gtld-subsequent-09apr18-en.mp3 The recordings and transcriptions of the calls are posted on the GNSO Master Calendar page:http://gnso.icann.org/en/group-activities/calendar[gnso.icann.org]<https://urldefense.proofpoint.com/v2/url?u=http-3A__gnso.icann.org_en_group…> ** Please let me know if your name has been left off the list ** Mailing list archives: http://mm.icann.org/pipermail/gnso-newgtld-wg/ Main wiki page for the working group: https://community.icann.org/x/RgV1Aw Thank you. Kind regards, Julie

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Actions/Discussion Notes: New gTLD Subsequent Procedures PDP WG 09 April 2018
by Julie Hedlund April 9, 2018

April 9, 2018

Dear WG Members, Please see below the action items and discussion notes captured by staff from the meeting on 09 April 2018. These high-level notes are designed to help PDP WG members navigate through the content of the call and are not meant as a substitute for the transcript or recording. The MP3, transcript, and chat room notes will be provided separately. For reference see also the attached referenced document. Best regards, Julie Julie Hedlund, Policy Director Action Items: The WG Chairs will address the point that we are not using level of consensus in this Initial Report. Staff will add a column to the report structure chart to indicate the Work Track. Notes: 1. Recap of ICANN61 -- Had a session for the full WG and a session on Work Track 5. -- Meeting later this week on Work Track 5. 2. Initial Report Timeline and Approach: -- Goal is to get the Initial Report out by the end of this month, but will adjust the schedule. -- Aware of timeline issues and will make sure there is ample time for the full WG to review the draft. -- Re: whether we should call the Initial Report something different. There is one report that is required in Annex A of the Bylaws/PDP Manual/GNSO Operating Procedures: Initial Report/Final Report. But, you can have additional items, such as Community Comments. Can have something that comes out that has more concrete recommendations, if that is something the WG wants to do. For now we are keeping the title “Initial Report” since that report is required by the Bylaws/PDP Manual. We can have other outputs. -- Was there a request for statements from the SOs/ACs? Yes, that was Community Comment 1 and 2. -- The Initial Report will go out and there may be issues raised by the community that need more clarification, so there is nothing preventing an Initial Report version 2. As long as we have the option to go back to the community to get clarification that is important. -- We can either do version 2 or call it something different, or we can put out parts of it if we have areas where we have questions. The PDP Manual is flexible but that we have to have something called an Initial Report and something called a Final Report. Initial Report Format: -- The meat of the report will be sections that look like this – recommendations and deliberations. -- It is structured in chronological order as if you were applying for a top-level domain. Overall issues, application, post-application, etc. The number 12 corresponds to the post-delegation process. -- Each section will be broken down into subsections: a) what is the relevant implementation guidance from the 2007 GNSO Final Report on gTLDs, approved by the Board in 2008; b) how it was implemented in the 2012 round; c) what are the preliminary recommendations if any; d) what are the other options under consideration with benefits or drawbacks; e) specific questions seeking feedback on; f) deliberations that took place (work tracks or full WG); g) any other activities in the community that would service as dependencies or input. -- During each of the work tracks we summarized the current thinking. -- The sections in the Initial Report should be updated to include other comments received and may not be recommendations, but only listed in the deliberations. Asking WG members to keep us honest to make sure we are accurately reflecting the current thinking, and any questions we want to ask. -- Our goal is not to introduce new arguments or to talk about the merits of the questions we are asking for feedback on. -- The goal is to make sure we have not left anything out and that the questions are concisely stated and cover all the areas where we want to ask questions. -- The intent is not to engage in substantive discussion on what should or should not be a recommendations, but to make sure we accurately reflected the deliberations. -- It’s important that issues that were outstanding in the discussions are highlighted in the Initial Report so that these can be reviewed by the community and commented on. I agree with you that issues should be raised for further discussion and comment. As long as the issues are raised in the Initial Report, I'm comfortable. Would not want to see something referred to as "preliminary recommendation" if it was not supported as such in the Work Track. -- Staff are working on other sections of the report, such as the executive summary, appendices, etc., but in the meantime we want to get the sections out to the WG to review by the end of the week. -- There will be one executive summary for the entire report. It will pull out elements but not be a complete restatement of all of the sections. -- Question: Will the executive summary have a (suggested / proposed) timeline to launch? -- Should address why we are not using level of consensus for this report. Might do it as a cover letter to the report. This should be addressed in the introduction because it's a required element of the Initial Report in the PDP Manual pursuant to Section 11. We are varying that procedure so we need to say why we are doing that if we feel it is justified. See page 71 of the current version of the PDP Manual re "Initial Report". -- Do not change something just for change. -- When WG members are providing comments, please note the section in the header of the email and send a separate email for each section. Maybe we could have an email title format so we can easily distinguish these document comments from other communications? And if it we could somehow have a consolidated way to view comments sent through email so that we don't have to review and re-review all emails. Comments on Initial Report Excerpt: Section 1.12 Post-Delegation: -- Section 1.12.1.e, bullet 1: I think we should, for clarity, revise the first question to: "Is this reason still applicable and/or relevant?" Also, should add follow up question after "Are other measures needed?" and that should be "If so, what measures and how will these measures address the issue?" -- The above point could apply to the next bullet point as well to further clarify comments, i.e. "Is the definition of "use" of a TLD from the 2012 round still appropriate or are adjustments needed? If so, what adjustments are necessary and why?" -- I think the "if so why" element that Kristina suggested for bullet 1 is important on all of the questions we ask - we want and need reasoned input rather than unsupported opinion -- Question: Will Staff be inserting citations (and links) to all statements that are either quotations (e.g., Implementation Guideline I) or purport/appear to be (e.g., "one of the reasons the delegation deadline was put into place was to prevent incidence of squatting/warehousing" in first bullet of 1.12.1.e)? If not, I recommend/request that citations be added. -- In section C – preliminary recommendations -- What do we mean by “more granular” or “more meaningful”? There were statistics in the aggregate on overall compliance, but ICANN did not provide more detail, i.e., what was the complaint, how it was resolved, etc. ACTION: Change “granular” to “more detailed” and see if there was a specific example in the deliberations in the Work Track.

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Proposed agenda - New gTLD Subsequent Procedures PDP WG - 9 April 2018 at 15:00 UTC
by Steve Chan April 9, 2018

April 9, 2018

Dear WG Members, Below, please find the proposed agenda for the New gTLD Subsequent Procedures WG meeting scheduled for Monday 9 April 2018 at 15:00 UTC, for 90 minutes. Agenda Review Roll Call/SOIs Recap of ICANN61 Introduction to the Initial Report AOB For item 4 of the agenda, we will be reviewing one section of the draft Initial Report. Attached, please find an extract of the section on Post-Delegation, which includes three topics. Those signed up as Members to this PDP WG should have received meeting information from the SOAC Support team. If you did not receive these participation details or if you would like to send your apologies, please contact the SOAC Support team (gnso-secs(a)icann.org) Best, Steve Steven Chan  Policy Director, GNSO Support ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094-2536  steve.chan(a)icann.org mobile: +1.310.339.4410 office tel: +1.310.301.5800 office fax: +1.310.823.8649 Find out more about the GNSO by taking our interactive courses and visiting the GNSO Newcomer pages. Follow @GNSO on Twitter: https://twitter.com/ICANN_GNSO Follow the GNSO on Facebook: https://www.facebook.com/icanngnso/ http://gnso.icann.org/en/

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Re: [Gnso-newgtld-wg] [Ext] Re: Working Group Newsletter - April 2018
by Emily Barabas April 5, 2018

April 5, 2018

Dear Dev, Thanks very much for reporting this issue. The file has been updated and should work correctly using the same link provided below (http://go.icann.org/SubPro) Note that you may need to clear your browser cache to access the updated file. Please get in touch if you experience any additional issues. Kind regards, Emily On 05/04/18 18:08, "Dev Anand Teelucksingh" <devtee(a)gmail.com> wrote: Hello, thanks for this. However, I note that for me (Win10 using Adobe Acrobat Reader DC 2018 to view the file) that I'm unable to click on any of the blue underlines throughout the document except for the blue coloured "More Information" box at the end of the document. Dev Anand Teelucksingh At-Large member, Trinidad and Tobago Computer Society, https://urldefense.proofpoint.com/v2/url?u=http-3A__ttcs.tt_&d=DwIFaQ&c=FmY… On Thu, Apr 5, 2018 at 11:38 AM, Emily Barabas <emily.barabas(a)icann.org> wrote: > Dear Working Group and Work Track 5 members, > > > > The April edition of the New gTLD Subsequent Procedures PDP Working Group > newsletter is now available: https://urldefense.proofpoint.com/v2/url?u=http-3A__go.icann.org_SubPro&d=D…. > > > > Please feel free to share this newsletter with individuals and groups who > may be interested in the Working Group’s activities. An archive of previous > editions of the newsletter is available on the WG wiki and on the GNSO > website. > > > > Kind regards, > > Emily > > > > > > Emily Barabas | Senior Policy Specialist > > ICANN | Internet Corporation for Assigned Names and Numbers > > Email: emily.barabas(a)icann.org | Phone: +31 (0)6 84507976 > > > > > _______________________________________________ > Gnso-newgtld-wg mailing list > Gnso-newgtld-wg(a)icann.org > https://mm.icann.org/mailman/listinfo/gnso-newgtld-wg

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Working Group Newsletter - April 2018
by Emily Barabas April 5, 2018

April 5, 2018

Dear Working Group and Work Track 5 members, The April edition of the New gTLD Subsequent Procedures PDP Working Group newsletter is now available: http://go.icann.org/SubPro. Please feel free to share this newsletter with individuals and groups who may be interested in the Working Group’s activities. An archive of previous editions of the newsletter is available on the WG wiki<https://community.icann.org/pages/viewpage.action?pageId=58001970> and on the GNSO website<https://gnso.icann.org/en/news/working-group-newsletters>. Kind regards, Emily Emily Barabas | Senior Policy Specialist ICANN | Internet Corporation for Assigned Names and Numbers Email: emily.barabas(a)icann.org | Phone: +31 (0)6 84507976

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FW: [Gnso-next-gen-rds-lead] FW: URGENT REQUEST - Community Input re Accreditation Model Draft
by Terri Agnew April 2, 2018

April 2, 2018

FYI From: Brian Winterfeldt <Brian(a)Winterfeldt.law <mailto:Brian@Winterfeldt.law> > Date: Monday, April 2, 2018 at 15:07 To: "so-ac-sg-cleaders(a)icann.org <mailto:so-ac-sg-cleaders@icann.org> " <so-ac-sg-cleaders(a)icann.org <mailto:so-ac-sg-cleaders@icann.org> > Cc: "internet(a)winterfeldt.law <mailto:internet@winterfeldt.law> " <internet(a)winterfeldt.law <mailto:internet@winterfeldt.law> > Subject: RE: URGENT REQUEST - Community Input re Accreditation Model Draft Dear ICANN Community Leadership Colleagues: I write to follow up on my prior communication below to provide you with a formal invitation from the IPC and the BC to participate in a community-wide discussion regarding the proposed accreditation and access model for non-public WHOIS data, which was first circulated to the community during ICANN 61. The discussion will take place via ICANN-supported remote participation and/or audio bridge this Friday April 6, 2018 from 1400-1600 UTC. Please find the formal invitation attached with the pertinent participation details. Please distribute the invitation to your respective stakeholders and encourage broad distribution to encourage as much participation as possible in the discussion. Of course, please continue to channel written comments on the accreditation model proposal to <mailto:3amcomments@gmail.com> 3amcomments(a)gmail.com, with a copy to <mailto:internet@winterfeldt.law> internet(a)winterfeldt.law. Thank you very much for your assistance and engagement with respect to this ongoing effort. Best regards, Brian _____ <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> [winterfeldt.law] Brian J. Winterfeldt Principal Winterfeldt IP Group <x-apple-data-detectors://12/1> 1200 17 <x-apple-data-detectors://12/1> th <x-apple-data-detectors://12/1> St NW, <x-apple-data-detectors://12/1> Ste 501 <x-apple-data-detectors://12/1> Washington, DC 20036 <mailto:brian@winterfeldt.law> brian(a)winterfeldt.law +1 202 903 4422 From: Brian Winterfeldt Sent: Thursday, March 29, 2018 7:24 PM To: <mailto:so-ac-sg-cleaders@icann.org> so-ac-sg-cleaders(a)icann.org Cc: <mailto:internet@winterfeldt.law> internet(a)winterfeldt.law Subject: URGENT REQUEST - Community Input re Accreditation Model Draft Importance: High Dear ICANN Community Leadership Colleagues: As a follow-up to my statement on behalf of the IPC during Public Forum II at ICANN 61 in Puerto Rico with Steve DelBianco (from the BC), I am writing to again request your stakeholders' input and collaboration on the proposed Accreditation Model for access to non-public WHOIS data (Version 1.3). Our sincere hope is that this model will be implemented alongside the ICANN-developed Proposed Interim Model for GDPR Compliance. The Accreditation Model can be found here: <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ipconstituency.org_ assets_docs_WHOIS-2520Access-2520Accreditation-2520Process-25201.3-255b1-255 d.pdf&d=DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhp AMF1nu2x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ &s=ZVAEQxooXzT86rLVPfHTxmzU0WSDnjHfiAcifwTNcmk&e=> http://www.ipconstituency.org/assets/docs/WHOIS%20Access%20Accreditation%20P rocess%201.3[1].pdf[ipconstituency.org]. We welcome any questions or feedback on the proposed Accreditation Model, put forward as a strawman to facilitate broader community-wide efforts to develop an accreditation system proposal. We had hoped to convene a community-wide call swiftly after ICANN 61, but the absence of Adobe Connect has made facilitating community discussion and input difficult. However, with the stop-gap solutions being put into place, we hope to convene a call to discuss Accreditation Model development within the next week or so. Developing an Accreditation Model for access to non-public WHOIS data is a critical yet-to-be-developed element of the interim GDPR compliance model, and as Goran noted in his letter to DPAs, the community has achieved consensus that something must be finalized and implemented to assure the appropriate functioning of a gated/tiered/layered access WHOIS system. Again, we hope that the Accreditation Model proposal we are sharing can act as a starting point for the community to make quick progress in this respect. Please send any input on this matter to <mailto:3amcomments@gmail.com> 3amcomments(a)gmail.com as soon as possible, with a copy to <mailto:internet@winterfeldt.law> internet(a)winterfeldt.law. This will help us make sure all the input provided is received and appropriately captured. Again, we hope to convene a community call to facilitate continued discussion on this issue next week, so we would love to receive your feedback ideally before the community session! Thank you for your input and timely engagement in this vital aspect of our ongoing work around GDPR and WHOIS! Best regards, Brian _____ <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> [winterfeldt.law] Brian J. Winterfeldt Principal Winterfeldt IP Group <x-apple-data-detectors://12/1> 1200 17 <x-apple-data-detectors://12/1> th <x-apple-data-detectors://12/1> St NW, <x-apple-data-detectors://12/1> Ste 501 <x-apple-data-detectors://12/1> Washington, DC 20036 <mailto:brian@winterfeldt.law> brian(a)winterfeldt.law +1 202 903 4422

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