October 2014 - Gnso-ppsai-pdp-wg

Compilation of P/P provider responses
by Mary Wong Sept. 15, 2015

Sept. 15, 2015

Dear WG members, Please find attached a document that staff has compiled of P/P provider responses to the 5 questions posed by the WG chairs to the group after the call last week, as follows: 1. What are provider practices regarding customer notification when a disclosure request is received, and is the customer given the opportunity to respond? 2. Does any provider offer its customer an option other than disclosure or publication, e.g. an opportunity to cancel the registration instead (i.e. what some WG members have mentioned as a ³takedown²)? 3. What are provider ³standards" for determining disclosure to third parties? 4. Can providers give the WG some general information about the percentage of requests for disclosure that are successful? 5. For Q4, do providers also have information about the type of claims those relate to e.g. If they are from LEA, 3P IP claim etc.? Please let me know if I have mischaracterized or omitted any response that you may have sent (for which I offer my apologies!). If you have not yet provided a response and are in a position to do so, or if you¹d like to add to a response you¹d provided previously, please send it along and I¹ll make sure it gets added to this document. Finally, please note that certain actual provider terms of service obtained from a sample of providers had previously been compiled as part of the draft template for this Category F, so that may also be helpful these are available on the WG wiki here: https://community.icann.org/x/QwbxAg. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4892 Email: mary.wong(a)icann.org

9 11

REMINDER: PLEASE RSVP Monthly GNSO WG Newcomer Open House Session
by Terri Agnew Dec. 9, 2014

Dec. 9, 2014

Reminder: Monthly GNSO WG Newcomer Open House Session These ongoing monthly sessions are for new GNSO WG participants to come together and discuss any questions they may have about GNSO Working Groups, procedures and/or processes. We know there is a lot of information to digest when you join a GNSO Working Group and these monthly meetings are an opportunity for newcomers and more experienced participants to meet in an informal setting without the pressure of "real work" that needs be done. The agenda is flexible. The presenters will be ready with a standard set of materials if people would like to discuss them. Feel free to submit questions, either in advance or at the beginning of the meeting, if there is a topic that you would like to explore in more depth . Providing useful answers to a wide range of questions is part of the reason why these meetings are Thursday 6 November at 20.00 UTC Thursday 4 December at 12.00 UTC To convert to your local time zone, please see http://www.timeanddate.com/worldclock/converter.html If you are interested to join the next meeting on 23 October or any of the future meetings, please let the GNSO Secretariat know ( <mailto:gnso-secs@icann.org> gnso-secs(a)icann.org) and we will send you the call details. If there are any specific questions you already have, or any overviews or introductions you think would be helpful (e.g. GNSO Policy Development Process or GNSO Working Group guidelines), please let us know in advance and we will prepare materials accordingly. Feel free to share this invitation with others that you think may be interested. We look forward to welcoming you at the next meeting! Nathalie Peregrine GNSO Secretariat

1 2

LE discussion
by Don Blumenthal Oct. 31, 2014

Oct. 31, 2014

All, Dick Leaning from Europol is joining our band. I have asked him to handle the LE discussion of our work, but to bring in others if needed since he is so late to the group,. I'll ask to see the list if he decides to take that route. Dick has been on vacation since LA and won't rejoin the working world until Monday. He promised to start getting up to speed that day on what we have worked. We are working on reach out to the DPA suggestions. Don

3 2

FW: Re: Fwd: What is content and what isn't
by Michele Neylon - Blacknight Oct. 30, 2014

Oct. 30, 2014

>From Eric .. -- Mr Michele Neylon Blacknight Solutions Hosting & Colocation, Domains http://www.blacknight.host/ http://www.blacknight.press/ - get all our latest media releases & coverage http://blog.blacknight.com/ http://www.technology.ie/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Social: http://mneylon.social ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: Eric Brunner-Williams [mailto:ebw@abenaki.wabanaki.net] Sent: Thursday, October 30, 2014 7:08 PM To: Michele Neylon - Blacknight Subject: Fwd: Re: [Gnso-ppsai-pdp-wg] Fwd: What is content and what isn't Michele, Again please. Thanks in advance. Eric -------- Original Message -------- Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: What is content and what isn't Date: Thu, 30 Oct 2014 07:12:57 -0700 From: Eric Brunner-Williams <ebw(a)abenaki.wabanaki.net><mailto:ebw@abenaki.wabanaki.net> To: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Colleges, My note of earlier today, which Michele was kind enough to forward, covered only two of the points I hoped to make -- a difference between what we know when we look at a string, whether or not it resolves (registrations, or blocks, without associated resource records), and what we know when we resolve a domain name (without necessarily pointing a browser at the domain name). Then there is "content", that is, something that happens when we take the next step after discovering, via the resolution process, the underlying resources, and actually use those resources. This last part is what I expect many here mean by "content". My point is that there is something between "string" and "content", and there are useful analytical steps for distinct interests for each of "string", "resolved resource records" and "resources". Again, thank you all for your patience, Eric I don't know if this will go to the list -- I haven't been active since January. I suggest that the terminal label in a dot-terminated sequence of labels, aka "the domain name", e.g., "example" in example.com<http://example.com>, and the resources associated with a dot-terminated sequence of labels, differ. The former may be discovered by several means, e.g., string search through bulk access, random poking on whois, payload in transport protocol data, etc. The later may only be discovered by resolution -- that is -- resources disclosed by the dns, or by direct access to the resources, usually hosts. Restated, as I'm sure everyone is aware, names, infringing or not, are not the same as resources, malign or not, associated with the names via the dns. What I suggest, because I don't think everyone agrees on what "content" might mean, is that the two flavors Steve referred to during yesterday's call: Abuse comes in two flavors: abuse that derives from registration of the domain name itself, and abuse that derives from how the domain name is used. really are quite different, and that "content" as I suspect most here intend does _not_ include properties of resource records that would interest, even alarm, network operators (nominally included in the ISPCP within the GNSO). Examples of non-"content" resource record properties of interest or alarm are correlations of A records (hosts), of NS records (nameservers) with blocks of addresses or nameservers previously known to be ... interesting or alarming, as well as the TTL (time to live) value of resource records (enabling FastFlux and friends). In lieu of "content", perhaps the clunkier but less vague term of "resolved resources" could be used. Then we would know when we are discussing a static property of a string (well, one likely to last a year or so in the current common registration model) or the dynamic properties of resolution of a FQDN. Thank for your patience, Eric _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg(a)icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg

1 0

Re: [Gnso-ppsai-pdp-wg] moderate central course
by McGrady, Paul D. Oct. 30, 2014

Oct. 30, 2014

+1 Thanks Kathy. It is in everyone's best interest to find the moderate central course - P/P services, P/P customers, and the consumers who rely on brands to protect them from confusion and abuse in the marketplace. I've renamed the RE: line "moderate central course" to start a new string for those of us who want to use the list to work toward that effort. Best, Paul From: gnso-ppsai-pdp-wg-bounces(a)icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Kathy Kleiman Sent: Thursday, October 30, 2014 8:16 AM To: gnso-ppsai-pdp-wg(a)icann.org Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark Hi All, I feel the need to channel Maria Farrell in our discussion. Like Michele, I understand why Valeriya would like to see who the owner of a domain name is before she files a UDRP action. But I favor keeping some discretion with the Proxy/Privacy Service Providers because of the possibility of abuse. While the lawyers in our WG are acting in good faith and seek this information for their clients as part of due dilegence, not all lawyers and all people will (shocking, I know). When I hear about the death threats to Maria Farrell from her blogging and expression of legitimate and legal opinions, it is chilling. If we set up an express lane for those threatening her to get her private data, those making the threats will use it; if we have a checklist of requirements, without more/without discretion, they will check it off. There are those who will abuse any system we set into place: lawyers, individuals, others. So I think the only way to balance the clear rights, needs and legal protections on both sides is to stay in a moderate central course - of the type we were closing in on at our face to face meeting in LA. Best, Kathy : Valeriya I'm sorry, but just because we do not agree with your position does not mean that we do not understand why this proposal is attractive to you. We understand it. We do not agree with it. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains http://www.blacknight.host/ http://blog.blacknight.com/ http://www.technology.ie<http://www.technology.ie/> http://www.blacknight.press<http://www.blacknight.press/> for all our news & media Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Social: http://mneylon.social ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Valeriya Sherman Sent: Wednesday, October 29, 2014 8:45 PM To: Williams, Todd; Phil Corwin; Marika Konings; David Cake Cc: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark All, Respectfully, a few of the comments in response to my email miss the main point, which is that Disclosure helps the Requestor determine--before having to file a UDRP against the Provider-- whether or not the Customer has legitimate rights in the domain name or whether it has registered and used the domain name in bad faith. Based on our experience filing numerous UDRP complaints on behalf of IP owners, once the UDRP Complaint is filed, the arbitration service (NAF or WIPO) automatically directs that the Customer's identity be disclosed to the UDRP Complainant. This is not done by the UDRP panelist; it is done ministerially by a Case Coordinator. Then the Complainant's attorneys have to amend the UDRP Complaint to name the true registrant. Disclosing the true registrant's identity earlier helps the Requestor determine if the UDRP is warranted, in two ways. First, it helps determine if the true registrant has a legitimate interest in the domain name. For example, it would be useful for the owner of the U.S. trademark BUDWEISER to know if the registrant of DrinkBudweiserBeer.com<http://www.drinkbudweiserbeer.com/> is the brewery in the Czech Republic that also owns a BUDWEISER trademark before it files a UDRP against this registrant. Second, it helps determine if the domain name was registered and used in bad faith. The examples I gave were various indicia that have long been accepted in UDRP decisions as evidencing bad faith. * If a registrant has prior UDRP decisions against him. See, e.g. Intel Corporation v. Marcel Engenheiro / Pentium Capital, Case No. D2013-1745 (WIPO Jan. 21, 2014) (found that Respondent had engaged in a pattern of abusive registration of domain names based on two prior UDRP decisions issued against him); * If he stockpiles infringing domain names. See, e.g., TV Globo Ltda. v. Green Card Transportes e Eventos Ltda., Case No. D2000-0351 (WIPO July 17, 2001) (found that "existence of a long list of domain names ... is evidence that registration has been effected in bad faith."); * If he simply holds the infringing domain names for sale. See, e.g., Federal Cartridge Co. v. Madmouse Communications, Case No. D2001-0756 (WIPO July 24, 2001) (found use in bad faith when registrant held a domain name that incorporated another's protected mark without any effort to use it for any purpose). These and other indicia evidence bad faith, and are highly useful in determining if a UDRP is warranted. For all the reasons above, a limited disclosure to a single third party Requestor before a UDRP filing is better in the long run for Customers, P/P Providers, and Requestors alike. We look forward to further discussing these issues, but we still believe (as we did when this was first discussed in September) that disclosure should be attainable without the need to first file a UDRP or other legal proceeding. Best regards, Val Valeriya Sherman Silverberg, Goldman & Bikoff, L.L.P. 1101 30th Street, N.W. Suite 120 Washington, D.C. 20007 Tel 202.944.3300 Cell 303.589.7477 vsherman(a)sgbdc.com<mailto:vsherman@law.gwu.edu> ________________________________ From: Williams, Todd [Todd.Williams(a)turner.com<mailto:Todd.Williams@turner.com>] Sent: Wednesday, October 29, 2014 4:04 PM To: Phil Corwin; Marika Konings; David Cake; Valeriya Sherman Cc: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: RE: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark Thanks Philip. At least a partial answer to your question ("do we know how often that occurs") was included in the "compilation of p/p provider responses to specific WG questions" - which is attached to the attached email. In it, you'll see that for at least DBP and the "others," the default was to "publish" to the world (not just to "disclose" to the individual complainant) upon filing of a UDRP. Based at least in part on that, Kathy and I - and presumably the others in the WG (having received no objection to our email string) - agreed that an accreditation policy that intentionally funnels these types of complaints into UDRPs was less preferable for all parties involved: the registrant/beneficial user, the p/p provider, and the complainant. I don't want to speak for Kathy or the others, so I've attached the email string. But just to reiterate what we discussed there: * The registrant/beneficial user gets to avoid the more drastic result of publication to the world. If, as Michele and Chris and others have suggested, we need to be mindful of how our standards may impinge on privacy rights, then surely publication to the world is a much more severe impingement of that privacy right than disclosure to an individual complainant. * The p/p provider gets to avoid being named as a respondent in a UDRP proceeding (which James has noted can be problematic for the provider), and may get to keep a paying customer that it would otherwise lose once the UDRP is filed and the contact information is published to the world. * The complainant gets to save the money that it would otherwise spend on a UDRP, and may in fact choose to forgo the UDRP all together (as I mentioned, perhaps learning the beneficial user's identity will cause the complainant to question its original analysis that the domain name was being used in bad faith). Because of that, I can't really think of anybody who benefits from a system that intentionally pushes these types of matters into UDRPs (except perhaps for UDRP providers like NAF, or for attorneys who get paid to litigate UDRPs I suppose). Thanks. Todd. From: gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Phil Corwin Sent: Wednesday, October 29, 2014 11:56 AM To: Marika Konings; David Cake; Valeriya Sherman Cc: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark Marika: Thanks for the clarification. In regard to this - "the P/P service will publish the underlying customer information in Whois within two days of the UDDR being filed, unless the P/P service has no objection to being listed in the complaint/ruling as the registrant" --that seems to say that disclosure of the registrant data will not always automatically occur if the P/P service agrees to be listed as registrant. Do we know how often that occurs, or the basis on which the providers currently make that decision? At any rate, the argument for revelation to the requestor upon a mere allegation of an IP infringement (and more specifically, upon an allegation based solely upon the domain name as trademark infringing) was based on the assertion that it will be revealed to the world via the WHOIS record if the requestor has to escalate to a UDRP or URS. But it appears there is a major exception to that argument. Best, Philip Philip S. Corwin, Founding Principal Virtualaw LLC 1155 F Street, NW Suite 1050 Washington, DC 20004 202-559-8597/Direct 202-559-8750/Fax 202-255-6172/cell Twitter: @VlawDC "Luck is the residue of design" -- Branch Rickey From: gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Marika Konings Sent: Wednesday, October 29, 2014 4:53 AM To: David Cake; Valeriya Sherman Cc: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark All, in relation to this discussion, it may be worth pointing out that the current status quo, which will be further codified as a result of the locking of a domain name subject to UDRP Proceedings Policy Development Process, is that the P/P service will publish the underlying customer information in Whois within two days of the UDDR being filed, unless the P/P service has no objection to being listed in the complaint/ruling as the registrant. If I understand the current proposal under consideration correctly, the idea is that an intermediate step could be introduced which may provide potential benefits to both parties as it would provide the requestor with additional information that may be helpful in deciding whether a UDRP/URS or alternative approach would be best suited to address the issue while the P/P customer information would only be disclosed to the requestor instead of published in Whois (and presumably it would also offer another path for remediation to the P/P customer instead of having to go directly to a UDRP which might require hiring of a lawyer?). Obviously there are other issues that need to be considered in relation to such a possible intermediate step such as how to avoid misuse, but I thought it might be helpful to consider this in light of the status quo. Best regards, Marika From: David Cake <dave(a)difference.com.au<mailto:dave@difference.com.au>> Date: Wednesday 29 October 2014 08:57 To: Valeriya Sherman <VSherman(a)sgbdc.com<mailto:VSherman@sgbdc.com>> Cc: "gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>" <gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>> Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark On 29 Oct 2014, at 3:38 am, Valeriya Sherman <VSherman(a)sgbdc.com<mailto:VSherman@sgbdc.com>> wrote: Phil, With respect to Reveal in the context of allegations that a domain name is infringing, we advocate Disclosure (to the Requestor only) of information sufficient to help the Requestor determine if further action against the Customer is warranted. This is especially important in the context of IP rights enforcement. Allegations are not proof. If the domain name itself is regarded as possibly infringing, we have the UDRP and URS to determine it a domain name is actually infringing. Disclosure of the Customer's identity would help the Requestor determine, before having to file a URS or UDRP, whether or not the Customer: Sure. But being helpful to the Requestor is not, by itself, sufficient to justify disclosure. -has legitimate rights in the domain name; -is a cybersquatter; These are the exact questions the UDRP/URS are designed to answer. Wanting to know the answers to them before filing is putting the cart before the horse somewhat. -is stockpiling domain names, without adding any website content; or The UDRP ultimately should succeed or fail based on the use of the domain in question, not what the registrant does with their other domains. And as Michele notes, website content is not the only use for domain names. ( eg I have a few friends who have used the adorably geeky rcpt.to domain for email only for over a decade now). Also, if the domain owner is actively using sub-domains of their domain, it may not necessarily be obvious to the requester. -has prior UDRP decisions against him or her. Again, sure, helpful to know before filing your UDRP, but is helpful to potential filers sufficient to overrule the obvious desire of the registrant for privacy? A desire to disassociate particular domains used for specific purposes from their general domaining business may even be the reason for using a PPP. All of the foregoing indicate bad faith registration and use of the domain name. Your first two criteria are decisions that the UDRP/URS will rule on. Your second two criteria might indicate a general pattern of bad behaviour by the registrant, but do not mean that an individual domain is part of that pattern of behaviour. As Paul pointed out on today's call, the Requestor must be able to ascertain this information before it is obliged undergo the time and expense of bringing a UDRP or other legal proceeding. I do not think this follows at all. There is a big difference between the requestor would like to, and the Requestor must be able to. I absolutely think that the Requestor should be able to use relay to request relevant information from the registrant. If the registrant wants to reply to a relayed request asserting their legitimate right to the domain, good. But it is not obvious to me that disclosure is necessary, and I can think of many cases in which it might be problematic. In that way, it can possibly avoid the need for a UDRP. And if it has to bring a UDRP, it can do so in good faith. That is why Disclosure is valuable in cases involving infringing domain names, not just infringing website content. To address another point that has come up in the past, Disclosure does not equate to a finding of guilt. Disclosure is not a remedy of the UDRP or the URS; it would occur before a case is decided on the merits. Of course - but avoiding disclosure is, presumably, often a major reason for retaining a PPP in the first place, so we should not let it happen just because it would be beneficial to the requestor. Regards David It is my understanding that once a UDRP is filed, one or both of the following generally happens: 1) registrar receives a request for information to confirm registrant, which it then sends to the Complainant to amend the Complaint; or 2) the P/P Provider named in the complaint discloses or publishes the information. So under the status quo, there generally is a Reveal before a decision on the merits, but only after the Requestor is forced to file a complaint, without essential information, at a high cost. As you correctly observed, not all allegations are successful -- we don't want to encourage more with a policy that requires premature legal actions. Best regards, Val Valeriya Sherman Silverberg, Goldman & Bikoff, L.L.P. 1101 30th Street, N.W. Suite 120 Washington, D.C. 20007 Tel 202.944.3300 Cell 303.589.7477 vsherman(a)sgbdc.com<mailto:vsherman@law.gwu.edu> ________________________________ From: gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> [gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org>] on behalf of Volker Greimann [vgreimann(a)key-systems.net<mailto:vgreimann@key-systems.net>] Sent: Tuesday, October 28, 2014 12:37 PM To: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark Hi Phil, I agree that a mere allegation is never enough for any form of required result. The bar needs to be set a lot higher, such as a sworn statement that includes legal consequences in case any part of it is incorrect that would allow the injured party and the provider to sue the pants off of the complainant. Also, the violation must be clear and obvious to an untrained third party observer, which is usually not the case in trademark violation due to the fact that trademark law is simply too complex for a layman to understand. And frankly, there also is no need for an immediate reveal as there are, as you point out, already sufficient means to deal with such cases. As for content, that is a hosting issue outside the realm of ICANN. Go to the hosting provider instead. Infringing content has nothing to do with the domain name whatsoever. Best, Volker Am 28.10.2014 17:30, schrieb Phil Corwin: I want to reiterate the concerns I raised during today's call about recommending a policy that would require a privacy/proxy provider (PPP) to reveal/disclose a registrant's identity and contact information based on a mere allegation that the domain name is infringing a trademark. ICANN has established the URDP and URS to deal with such allegations. And every day WIPO, NAF, and other providers deny complainant allegations. In fact, it appears that instances of attempted reverse domain hijacking are on the rise. A registrant who is targeted in a UDRP or URS has a choice of responding (in which case they will be revealing their identity) or to default and let the provider decide the allegation based solely upon the complaint. The proposed policy would compel disclosure of registrant data even when no UDRP, URS, or trademark infringement litigation was filed, or even if the allegation was subsequently found to fail to meet the required burden of proof. I am not convinced by arguments that such mandatory disclosure might facilitate resolution absent the filing of arbitration or litigation. That can be accomplished by requiring the PPP to relay a cease-and-desist letter or other communication to the registrant. Mandatory disclosure based on an unproven allegation does not further the claimed goal. Summing up, I believe that our WG should not create any new policy related to allegations of TM infringement by a domain name but should leave this issue to the new gTLD RPM and UDRP review that will be commencing next spring. As for allegations of trademark infringement based upon a website's content that is a separate matter. However, I believe our discussions should recognize that PPPs are unlikely to weigh the merits of an allegation and that their likely default position will be to reveal registrant data once a complaint addresses all the relevant points required by any new policy on this subject. Given that likelihood, we should certainly consider the extent to which such a policy might be abused by a private sector or governmental actor. Thank you for taking these views into account. Philip S. Corwin, Founding Principal Virtualaw LLC 1155 F Street, NW Suite 1050 Washington, DC 20004 202-559-8597/Direct 202-559-8750/Fax 202-255-6172/cell Twitter: @VlawDC "Luck is the residue of design" -- Branch Rickey _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg(a)icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org>https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg -- 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(a)key-systems.net<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net/> / www.RRPproxy.net<http://www.rrpproxy.net/>www.domaindiscount24.com<http://www.domaindiscount24.com/> / www.BrandShelter.com<http://www.brandshelter.com/> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems>www.twitter.com/key_systems<http://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<http://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(a)key-systems.net<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net/> / www.RRPproxy.net<http://www.rrpproxy.net/>www.domaindiscount24.com<http://www.domaindiscount24.com/> / www.BrandShelter.com<http://www.brandshelter.com/> Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems>www.twitter.com/key_systems<http://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<http://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. _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg(a)icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg ________________________________ No virus found in this message. Checked by AVG - www.avg.com<http://www.avg.com> Version: 2015.0.5315 / Virus Database: 4189/8462 - Release Date: 10/27/14 _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg(a)icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg The contents of this message may be privileged and confidential. Therefore, if this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author.

2 1

Re: [Gnso-ppsai-pdp-wg] What is content and what isn't
by Chris Pelling Oct. 30, 2014

Oct. 30, 2014

Firstly my apologies to those that may have got this twice (first one missing a chunk) : Surely we are not going to re-inventing the wheel here? As per the Oxford English Dictionary : Disclosure : The action of making new or secret information known: ref : http://www.oxforddictionaries.com/definition/english/disclosure Relay *verb* : Receive and pass on (information or a message): ref : http://www.oxforddictionaries.com/definition/english/relay This whole point regarding "Breach of privacy" on mere speculation you are requesting that someones private information be made public - even if public to the requester, it is by definition still public. In Europe which ICANN has to appreciate there will be PP providers this is a breach/violation of a persons right. To do a relay - no breach/violation of privacy - thats how simple it is. No IP lawyer nor Brand protection company has the right to breach or violate a consumers right to privacy without due process - period. Kind Regards, Chris NetEarth One, inc ----- Original Message ----- From: "Kiran Malancharuvil" <Kiran.Malancharuvil(a)markmonitor.com> To: "Michele Neylon - Blacknight" <michele(a)blacknight.com> Cc: "PPSAI" <gnso-ppsai-pdp-wg(a)icann.org> Sent: Wednesday, 29 October, 2014 3:33:24 PM Subject: Re: [Gnso-ppsai-pdp-wg] What is content and what isn't This is a conclusion we have yet to reach. Kiran Malancharuvil Internet Policy Counselor MarkMonitor 415-419-9138 (m) Sent from my mobile, please excuse any typos. On Oct 29, 2014, at 7:28 AM, Michele Neylon - Blacknight <michele(a)blacknight.com<mailto:michele@blacknight.com>> wrote: Steve Disclosure = breach of privacy Relay = communication It's that simple. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains http://www.blacknight.host/ http://blog.blacknight.com/ http://www.technology.ie<http://www.technology.ie/> http://www.blacknight.press<http://www.blacknight.press/> for all our news & media Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Social: http://mneylon.social ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: Metalitz, Steven [mailto:met@msk.com] Sent: Wednesday, October 29, 2014 2:19 PM To: 'Don Blumenthal'; Michele Neylon - Blacknight; PPSAI Subject: RE: What is content and what isn't As this thread originated in a comment I made on yesterday’s call, let me return to the only point I am trying to make. Abuse comes in two flavors: abuse that derives from registration of the domain name itself, and abuse that derives from how the domain name is used. The first category (which happens to be the one that Phil Corwin wants to exclude from disclosure requirements, but that’s a different thread) requires looking at the domain name itself. The second category requires looking at the resource (such as but not necessarily limited to a website) associated with the domain name. Websites engaged in counterfeiting and piracy fall in the second category; so do websites used for distribution of malware. If you wish, you can call one of these content and the other something else, but they share the important characteristic that they require looking beyond the domain name to see the abuse. One can complain all one wishes about “regulating content,” but there are at least two problems with that. First, one should hesitate to do so if one has signed the 2013 RAA, which requires one to “investigate and respond appropriately” to any report of “conduct involving use of a Registered Name sponsored by Registrar that is prohibited by applicable law.” Second, nobody in this WG is talking about “regulating content.” Quite the opposite: the very purpose of disclosure is to enable a complainant to go directly to a registrant, so that registrars (or hosting providers for that matter) don’t have to step in and regulate. If registrars wish to accept responsibility for the conduct by their registrants, then there would be no need to seek disclosure of the contact details of registrants who use a service provided by registrar to keep those details secret. But as registrars do not wish to accept that responsibility, then a mechanism is needed to define when those details should be disclosed. If you are still with me to this point, then we are (as Volker has put it) in the same postal code, and we can roll up our sleeves to try to define that mechanism as best we can. If not, not. Steve Metalitz From: gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Don Blumenthal Sent: Tuesday, October 28, 2014 12:26 PM To: Michele Neylon - Blacknight; PPSAI Subject: Re: [Gnso-ppsai-pdp-wg] What is content and what isn't Michele, We’ve wandered into an area where the practical considerations for contracted parties and others in the infrastructure will be different from p/p providers. As for bit.ly<http://bit.ly>, it would be covered by our policy but we would not act blindly. To be accurate, we refer to registrars for action. They have the direct contractual relationships with registrants and are in a better position to investigate. From: Michele Blacknight <michele(a)blacknight.com<mailto:michele@blacknight.com>> Date: Tuesday, October 28, 2014 at 12:12 PM To: Don Blumenthal <dblumenthal(a)pir.org<mailto:dblumenthal@pir.org>>, PPSAI <gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>> Subject: RE: What is content and what isn't Don I'm not sure what the sanest way of framing this is. We'd see malware and phishing as being network abuse issues and treat them accordingly. While some registries may have provisions in their policies to deal with this, hosting providers, network providers and registrars may do so also. However the problem arises when there is a question of "judgement". But it's never that simple .. For example this weekend bitly was flagged for malware by Google. Sure, some links on bitly might have led to malware, but pulling down the entire domain would have been a really really bad idea. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains http://www.blacknight.host/ http://blog.blacknight.com/ http://www.technology.ie<http://www.technology.ie/> http://www.blacknight.press<http://www.blacknight.press/> for all our news & media Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Social: http://mneylon.social ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: gnso-ppsai-pdp-wg-bounces(a)icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Don Blumenthal Sent: Tuesday, October 28, 2014 4:07 PM To: PPSAI Subject: [Gnso-ppsai-pdp-wg] What is content and what isn't Good afternoon, My point about whether we need to definite content was based as I said on my experience with PIR. The considerations may be different in the context of p/p obligations and processes than they are for a contracted party when reviewing a complaint about a domain. However, I focused on Steve’s description of malware as a content issue. Our posted anti-abuse policy lists malware as something that could cause us to act against a domain. The basis is that it creates a threat to the security and stability of the Internet. Malware is not a content issue for purpose of our complaint analyses. I may be forgetting a question. Let me know. Don _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg(a)icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg(a)icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg

11 20

Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark
by Phil Corwin Oct. 30, 2014

Oct. 30, 2014

I want to reiterate the concerns I raised during today's call about recommending a policy that would require a privacy/proxy provider (PPP) to reveal/disclose a registrant's identity and contact information based on a mere allegation that the domain name is infringing a trademark. ICANN has established the URDP and URS to deal with such allegations. And every day WIPO, NAF, and other providers deny complainant allegations. In fact, it appears that instances of attempted reverse domain hijacking are on the rise. A registrant who is targeted in a UDRP or URS has a choice of responding (in which case they will be revealing their identity) or to default and let the provider decide the allegation based solely upon the complaint. The proposed policy would compel disclosure of registrant data even when no UDRP, URS, or trademark infringement litigation was filed, or even if the allegation was subsequently found to fail to meet the required burden of proof. I am not convinced by arguments that such mandatory disclosure might facilitate resolution absent the filing of arbitration or litigation. That can be accomplished by requiring the PPP to relay a cease-and-desist letter or other communication to the registrant. Mandatory disclosure based on an unproven allegation does not further the claimed goal. Summing up, I believe that our WG should not create any new policy related to allegations of TM infringement by a domain name but should leave this issue to the new gTLD RPM and UDRP review that will be commencing next spring. As for allegations of trademark infringement based upon a website's content that is a separate matter. However, I believe our discussions should recognize that PPPs are unlikely to weigh the merits of an allegation and that their likely default position will be to reveal registrant data once a complaint addresses all the relevant points required by any new policy on this subject. Given that likelihood, we should certainly consider the extent to which such a policy might be abused by a private sector or governmental actor. Thank you for taking these views into account. Philip S. Corwin, Founding Principal Virtualaw LLC 1155 F Street, NW Suite 1050 Washington, DC 20004 202-559-8597/Direct 202-559-8750/Fax 202-255-6172/cell Twitter: @VlawDC "Luck is the residue of design" -- Branch Rickey

11 22

Fwd: What is content and what isn't
by Michele Neylon - Blacknight Oct. 29, 2014

Oct. 29, 2014

Forwarding on behalf of Eric Mr Michele Neylon Blacknight Hosting & Domains http://www.blacknight.host/ http://www.mneylon.social Begin forwarded message: From: Eric Brunner-Williams <ebw(a)abenaki.wabanaki.net<mailto:ebw@abenaki.wabanaki.net>> Date: 29 October 2014 21:14:32 GMT To: Michele Neylon - Blacknight <michele(a)blacknight.com<mailto:michele@blacknight.com>> Subject: Fwd: Re: [Gnso-ppsai-pdp-wg] What is content and what isn't Michele, Apparently I'm not (yet) able to contribute to the list. Would you be so kind as to forward this? Eric -------- Original Message -------- Subject: Re: [Gnso-ppsai-pdp-wg] What is content and what isn't Date: Wed, 29 Oct 2014 12:35:53 -0700 From: Eric Brunner-Williams <ebw(a)abenaki.wabanaki.net><mailto:ebw@abenaki.wabanaki.net> To: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> CC: Glen de Saint Géry <Glen(a)icann.org><mailto:Glen@icann.org> I don't know if this will go to the list -- I haven't been active since January. I suggest that the terminal label in a dot-terminated sequence of labels, aka "the domain name", e.g., "example" in example.com<http://example.com>, and the resources associated with a dot-terminated sequence of labels, differ. The former may be discovered by several means, e.g., string search through bulk access, random poking on whois, payload in transport protocol data, etc. The later may only be discovered by resolution -- that is -- resources disclosed by the dns, or by direct access to the resources, usually hosts. Restated, as I'm sure everyone is aware, names, infringing or not, are not the same as resources, malign or not, associated with the names via the dns. What I suggest, because I don't think everyone agrees on what "content" might mean, is that the two flavors Steve referred to during yesterday's call: Abuse comes in two flavors: abuse that derives from registration of the domain name itself, and abuse that derives from how the domain name is used. really are quite different, and that "content" as I suspect most here intend does _not_ include properties of resource records that would interest, even alarm, network operators (nominally included in the ISPCP within the GNSO). Examples of non-"content" resource record properties of interest or alarm are correlations of A records (hosts), of NS records (nameservers) with blocks of addresses or nameservers previously known to be ... interesting or alarming, as well as the TTL (time to live) value of resource records (enabling FastFlux and friends). In lieu of "content", perhaps the clunkier but less vague term of "resolved resources" could be used. Then we would know when we are discussing a static property of a string (well, one likely to last a year or so in the current common registration model) or the dynamic properties of resolution of a FQDN. Thank for your patience, Eric

1 0

What is content and what isn't
by Don Blumenthal Oct. 29, 2014

Oct. 29, 2014

Good afternoon, My point about whether we need to definite content was based as I said on my experience with PIR. The considerations may be different in the context of p/p obligations and processes than they are for a contracted party when reviewing a complaint about a domain. However, I focused on Steve’s description of malware as a content issue. Our posted anti-abuse policy lists malware as something that could cause us to act against a domain. The basis is that it creates a threat to the security and stability of the Internet. Malware is not a content issue for purpose of our complaint analyses. I may be forgetting a question. Let me know. Don

6 8

Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark
by Kiran Malancharuvil Oct. 29, 2014

Oct. 29, 2014

Chris, I'm not sure what you're asking me to clarify, your second paragraph makes very little sense to me. Are you saying that, in cases where we confirm that a third party is the registrant of the domain name in question, we would be able to automatically assume that they don't have a legitimate interest in the name? TM law is fairly more complicated than that, which I'm sure you know, so I must be missing your point. Thanks for clarifying, Kiran Kiran Malancharuvil Internet Policy Counselor MarkMonitor 415-419-9138 (m) Sent from my mobile, please excuse any typos. > On Oct 29, 2014, at 6:58 AM, Chris Pelling <chris(a)netearthone.com> wrote: > > In the case that the requester is obviously working for the TM/copyright owner, the tm/copyright owner is asked if they have this domain in their portfolio - obviously it might not be with the requester (in your part as a registrar holding the customers domains) but surely you ask that question to them before you decide to send emails out to the registrar of record / pp provider? > > I am assuming there Kiran, so, if you can confirm that MarkMonitor before sending out complaints to registrars / pp providers checks with their customer first that the domain they are alleging is in fact NOT owned by your customer ?? (with your registrar and brand protection hat on) > > Kind regards, > > Chris > > NetEarth One, inc > >> On 29/10/2014 11:37 AM, Kiran Malancharuvil wrote: >> How would the requestor determine I the registrant has legitimate rights of they don't know who/what they are? >> >> Kiran Malancharuvil >> Internet Policy Counselor >> MarkMonitor >> 415-419-9138 (m) >> >> Sent from my mobile, please excuse any typos. >> >>> On Oct 29, 2014, at 4:27 AM, Volker Greimann <vgreimann(a)key-systems.net> wrote: >>> >>> Hi Valeriya, >>> >>> you do not seem to realize that disclosure already constitutes a violation of the privacy rights of the customer. >>> >>>> Disclosure of the Customer's identity would help the Requestor determine, before having to file a URS or UDRP, whether or not the Customer: >>>> >>>> -has legitimate rights in the domain name; >>> Frankly, the requestor should try to figure this out before making the request. >>>> All of the foregoing indicate bad faith registration and use of the domain name. As Paul pointed out on today's call, the Requestor must be able to ascertain this information before it is obliged undergo the time and expense of bringing a UDRP or other legal proceeding. In that way, it can possibly avoid the need for a UDRP. And if it has to bring a UDRP, it can do so in good faith. That is why Disclosure is valuable in cases involving infringing domain names, not just infringing website content. >>> All of the foregoing? Even having legitimate rights? >>>> To address another point that has come up in the past, Disclosure does not equate to a finding of guilt. Disclosure is not a remedy of the UDRP or the URS; it would occur before a case is decided on the merits. It is my understanding that once a UDRP is filed, one or both of the following generally happens: 1) registrar receives a request for information to confirm registrant, which it then sends to the Complainant to amend the Complaint; or 2) the P/P Provider named in the complaint discloses or publishes the information. So under the status quo, there generally is a Reveal before a decision on the merits, but only after the Requestor is forced to file a complaint, without essential information, at a high cost. As you correctly observed, not all allegations are successful -- we don't want to encourage more with a policy that requires premature legal actions. >>> Disclosure may not equate a finding of guilt, but it does equate a violation of privacy. >>> >>> Best regards, >>> >>> Volker >>> >>>> >>>> Valeriya Sherman >>>> Silverberg, Goldman & Bikoff, L.L.P. >>>> 1101 30th Street, N.W. >>>> Suite 120 >>>> Washington, D.C. 20007 >>>> Tel 202.944.3300 >>>> Cell 303.589.7477 >>>> vsherman(a)sgbdc.com<mailto:vsherman@law.gwu.edu> >>>> ________________________________ >>>> From: gnso-ppsai-pdp-wg-bounces(a)icann.org [gnso-ppsai-pdp-wg-bounces(a)icann.org] on behalf of Volker Greimann [vgreimann(a)key-systems.net] >>>> Sent: Tuesday, October 28, 2014 12:37 PM >>>> To: gnso-ppsai-pdp-wg(a)icann.org >>>> Subject: Re: [Gnso-ppsai-pdp-wg] Mandatory Reveal in Context of Allegations that a Domain Name is Infringing Trademark >>>> >>>> Hi Phil, >>>> >>>> I agree that a mere allegation is never enough for any form of required result. The bar needs to be set a lot higher, such as a sworn statement that includes legal consequences in case any part of it is incorrect that would allow the injured party and the provider to sue the pants off of the complainant. >>>> >>>> Also, the violation must be clear and obvious to an untrained third party observer, which is usually not the case in trademark violation due to the fact that trademark law is simply too complex for a layman to understand. And frankly, there also is no need for an immediate reveal as there are, as you point out, already sufficient means to deal with such cases. >>>> >>>> As for content, that is a hosting issue outside the realm of ICANN. Go to the hosting provider instead. Infringing content has nothing to do with the domain name whatsoever. >>>> >>>> Best, >>>> >>>> Volker >>>> >>>> >>>> Am 28.10.2014 17:30, schrieb Phil Corwin: >>>> >>>> I want to reiterate the concerns I raised during today's call about recommending a policy that would require a privacy/proxy provider (PPP) to reveal/disclose a registrant's identity and contact information based on a mere allegation that the domain name is infringing a trademark. >>>> >>>> ICANN has established the URDP and URS to deal with such allegations. And every day WIPO, NAF, and other providers deny complainant allegations. In fact, it appears that instances of attempted reverse domain hijacking are on the rise. >>>> >>>> A registrant who is targeted in a UDRP or URS has a choice of responding (in which case they will be revealing their identity) or to default and let the provider decide the allegation based solely upon the complaint. The proposed policy would compel disclosure of registrant data even when no UDRP, URS, or trademark infringement litigation was filed, or even if the allegation was subsequently found to fail to meet the required burden of proof. >>>> >>>> I am not convinced by arguments that such mandatory disclosure might facilitate resolution absent the filing of arbitration or litigation. That can be accomplished by requiring the PPP to relay a cease-and-desist letter or other communication to the registrant. Mandatory disclosure based on an unproven allegation does not further the claimed goal. >>>> >>>> Summing up, I believe that our WG should not create any new policy related to allegations of TM infringement by a domain name but should leave this issue to the new gTLD RPM and UDRP review that will be commencing next spring. >>>> >>>> As for allegations of trademark infringement based upon a website's content that is a separate matter. However, I believe our discussions should recognize that PPPs are unlikely to weigh the merits of an allegation and that their likely default position will be to reveal registrant data once a complaint addresses all the relevant points required by any new policy on this subject. Given that likelihood, we should certainly consider the extent to which such a policy might be abused by a private sector or governmental actor. >>>> >>>> Thank you for taking these views into account. >>>> >>>> Philip S. Corwin, Founding Principal >>>> Virtualaw LLC >>>> 1155 F Street, NW >>>> Suite 1050 >>>> Washington, DC 20004 >>>> 202-559-8597/Direct >>>> 202-559-8750/Fax >>>> 202-255-6172/cell >>>> >>>> Twitter: @VlawDC >>>> >>>> "Luck is the residue of design" -- Branch Rickey >>>> >>>> >>>> >>>> >>>> >>>> >>>> _______________________________________________ >>>> Gnso-ppsai-pdp-wg mailing list >>>> Gnso-ppsai-pdp-wg(a)icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> >>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg >>>> >>>> >>>> -- >>>> 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(a)key-systems.net<mailto:vgreimann@key-systems.net> >>>> >>>> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> >>>> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> >>>> >>>> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: >>>> www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> >>>> www.twitter.com/key_systems<http://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<http://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(a)key-systems.net<mailto:vgreimann@key-systems.net> >>>> >>>> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> >>>> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> >>>> >>>> Follow us on Twitter or join our fan community on Facebook and stay updated: >>>> www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> >>>> www.twitter.com/key_systems<http://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<http://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. >>> -- >>> 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(a)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(a)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. >>> >>> >>> >>> _______________________________________________ >>> Gnso-ppsai-pdp-wg mailing list >>> Gnso-ppsai-pdp-wg(a)icann.org >>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg >> _______________________________________________ >> Gnso-ppsai-pdp-wg mailing list >> Gnso-ppsai-pdp-wg(a)icann.org >> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg >

1 0