May 2015 - 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

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MP3 PPSAI WG Webinar- Thursday 28 May 2015 at 1400 UTC
by Nathalie Peregrine May 29, 2015

May 29, 2015

Dear All, Please find the MP3 recording for the Privacy and Proxy Services Accreditation Issues PDP Working group call held on Thursday 28 May 2015 at 14:00 UTC at: http://audio.icann.org/gnso/gnso-ppsa-28may15-en.mp3<http://mailer.samanage.com/wf/click?upn=NrFWbrBstcrPWP369qgbqlXiSKeL20xnUXz…> On page: <http://gnso.icann.org/en/group-activities/calendar>http://gnso.icann.org/en/group-activities/calendar#<http://gnso.icann.org/en/group-activities/calendar#may><http://gnso.icann.org/en/group-activities/calendar#apr>m<http://gnso.icann.org/en/group-activities/calendar#may>ay<http://gnso.icann.org/en/group-activities/calendar#may> The recordings and transcriptions of the calls are posted on the GNSO Master Calendar page: http://gnso.icann.org/calendar/ Please find webinar attendance in the AC room attached to this email ** Please let me know if your name has been left off the list ** Mailing list archives: http://mm.icann.org/pipermail/gnso-ppsai-pdp-wg/ Wiki page: https://community.icann.org/x/9iCfAg Thank you. Kind regards, Nathalie ------------------------------- Adobe Connect chat transcript for Thursday 28 May 2015 Nathalie Peregrine:Dear all, welcome to the Privacy & Proxy Services Accreditation Issues Working Group Webinar on the 28th May 2015 Nathalie Peregrine:Dear all, we will be streaming audio in the AC for the presentation. If you want to ask a question at the end of the webinar, please dial into the audio bridge, or type it in the chat Volker A. Greimann:audible, graeme Graeme Bunton:Double Stephanie Perrin's, how fun! Volker A. Greimann:i hear you stephanie Perrin 2:You know I can always argue both sides of an argument then, Graeme! Bladel:Hmm... no audio on this end. JUst me? Nathalie Peregrine:There is audio streaming in the AC room Nathalie Peregrine:VoIP mics are disabled for this session Bladel:No sound, will join the bridge. Nathalie Peregrine:to ask a question at the end of the call, please dial into the audio bridge, or feel free to type them here steve metalitz:Great to see Don here! steve metalitz:July 7 is correct as comment closing date Don Blumenthal:Thanks Steve, Graeme, and Mary. The timing is perfect for giving me a way to catch up.:) I wonder if I should find a deeper meaning to the fact that comments close on my birthday.. Mary Wong:@Don, I take that as an excellent sign of good things to come ... esp since we didn't know this additional significant fact when we published the report! Amr Elsadr:Has the WG reached any consensus on using the PICS/GAC safeguards as examples of malicious conduct? Mary Wong:@Amr, yes, to the extent that the WG suggests that these could be starting points for developing a list of such. Mary Wong:In this slide, and in the Initial Report, where the WG is still considering draft language for which it has not yet reached consensus, square brackets have been placed around the language still under discussion. Osvaldo Novoa:Sorry I am so late, I was delayed in a previous meeting Mary Wong:Welcome, Osvaldo! Jim Prendergast, The Galway Strategy Group:How is reasonable defined? Mary Wong:@Jim, the WG did not delve into a more specific definition. Jeff Neuman (Com Laude):Does the first question imply that law firms may not register names on behalf of their clients if their clients are financial service providers? Amr Elsadr:Does "financial transactions for commercial purposes" include banks? Jeff Neuman (Com Laude):Or more generally are law firms, designated agents and others considered proxy providers? Joyce Lin 2:commercial purpose ? All the sites with ads on are for commercial purpose. Jeff Neuman (Com Laude):Even more generally, what is the definition of a proxy/privacy registration? Stephanie Duchesneau (neustar):Is it anticipated that a P/P accreditation program would be implemented concurrent with the expiry of the interim spec. or is there another timeline in mind? Amr Elsadr:@Jeff: "Others" also include web developers who might unknowingly be categorized as privacy/proxy services, especially in developing countries. Mary Wong:Hi all - as there is a series of questions typed into the chat, I will ask Graeme and Steve to answer them in turn during Q&A, if that's all right. Jeff Neuman (Com Laude):Please...not in a position to dial in right now, but on Adobe Mary Wong:No problem! Stephanie Duchesneau (neustar):that would be great mary Stephanie Duchesneau (neustar):thank you Amr Elsadr:Yes. Thanks Steve and Graeme. Amr Elsadr:<QUESTION>Wondering if the WG members have made a distinction between "financial transactions for a commercial purpose" vs. for a non-commercial purposes? Also, how is a p/p service provider meant to make this determination at the time of domain name registration?<QUESTION> Volker A. Greimann:short answer Steve: Probably yes. Susan Payne:Q: isnt a law firm which registers for use by a client a proxy? Susan Payne:I dont know any law firsm which would accept responsibility for their client's activities :) Jeff Neuman (Com Laude):I think that topic needs more work by the working group because I am not sure I see the differences as clearly as is being stated Bladel:If this is a regular part of their client services, then obtaining accreditation seems like a trivial matter. Jeff Neuman (Com Laude):But abiding by the accreditation standards may be in conflict with their legal obligations Jeff Neuman (Com Laude):and a violation of attorney client privilege Jeff Neuman (Com Laude):(maybe not the relay...but the reveal may be a violation of attorney client privilege) Amr Elsadr:A lot of independent web developers might be registering domain names for their clients, while being oblivious to p/p accreditation issues. Bladel:In this case, providers are volunteering to create an exception (client contact data), so why would this necessarily be privileged? Volker A. Greimann:question: what benefit does accreditation confer that would not be also provided by ICANN certification? Jeff Neuman (Com Laude):law firms are not "providers" Volker A. Greimann:i.e. is accreditation really necessary? Bladel:Not asking for communications between law firm and client, just idenification of client. How is that privileged? Volker A. Greimann:Jeff: If they provide a service, they are a service provider. Volker A. Greimann:provider of that service Nathalie Peregrine:@ Stephanie, your AC mic will not b enabled for this session. Please dial into the audio bridge if you wish to ask your question orally. Jeff Neuman (Com Laude):James.....the definition of what is in attorney client privilege is the subject of volumes of treatises and case law :) stephanie Perrin 2: I have dialed in. Am on the phone now. Nathalie Peregrine:excellent Amr Elsadr:@Steve: Thanks. The text on the slide earlier said "financial transaction for a commercial purpose". Was wondering if that was intentional to make a distinction to for non-commercial purposes. Bladel:Fine. But this can be waived in exchange for providing the serivce, correct? And how does this apply to providers outside the US? Amr Elsadr:@Graeme: Thanks. :) Stephanie Duchesneau (neustar):thanks Nathalie Peregrine:yes we can hear Amr Elsadr:@Stephanie: Thanks. That sort of addresses my earlier question. Bladel:On the flip side, Providers could just set up law firms. Jeff Neuman (Com Laude):or just "agents for service of process" Amr Elsadr:@James: ICANN accreditted law firms!! :) Joyce Lin 2:Who will be policing a domain name to see if it is a financial transaction type of domain? Bladel:Sure. Whatever they're calling it in the Cayman Islands these days. :) Don Blumenthal:@Amr Tjat stephanie Perrin 2:James, are you on the HR committee for the law societies? I know there are a lot of unemployed young lawyers in North America these days....:-) Don Blumenthal:@Amr That's truly sick Jeff Neuman (Com Laude):Thanks Steve and Graeme Amr Elsadr::) Holly Raiche:Thanks to Steve and Graeme Bladel:Thanks Steve, Graeme & Mary Jennifer Standiford:Thanks Everyone Amr Elsadr:Thanks Steve, Graeme and Mary. Sara Bockey:thank you all Susan Payne:thanks very much for this session Frank Michlick:thank you for attending Frank Michlick:and thank you for hosting :) Graeme Bunton:And another thx to Staff for putting the report together and he;ping with this webinar Mary Wong:Aww thanks stephanie Perrin 2:Thanks all! Stephanie Duchesneau (neustar):thanks all

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Call Cancellation PPSAI WG 26 May 2014
by Nathalie Peregrine May 25, 2015

May 25, 2015

Dear all, Please be aware that there will be no PPSAI WG call tomorrow at 1400 UTC. Please all remember to join the PPSAI Webinar on Thursday 28 May 2015 at 14:00 UTC, announcement to be found below this email. Please email nathalie.peregrine(a)icann.org to receive the dial in details Kind regards Nathalie News Alert https://www.icann.org/news/announcement-2015-05-19-en ________________________________ Call for RSVPs | Privacy & Proxy Services Accreditation Issues Working Group Webinar | 28 May 2015 at 14:00 UTC 19 May 2015 Please RSVP to nathalie.peregrine(a)icann.org<mailto:nathalie.peregrine@icann.org>. Remote participation details will be sent the week of 25 May 2015. Please join the interim co-chairs of the Privacy & Proxy Services Accreditation Issues Working Group for a one-hour webinar on Thursday 28 May 2015 at 1400 UTC, to hear about the preliminary recommendations that have now been published for public comment by the Working Group. This Working Group (WG) was chartered<http://gnso.icann.org/en/drafts/raa-pp-charter-22oct13-en.pdf> [PDF, 463 KB] by the GNSO Council in October 2013 to conduct a Policy Development Process (PDP) with the aim of developing policy recommendations to guide ICANN's implementation of an Accreditation Program for privacy and proxy service providers. The topic of privacy and proxy registrations had been identified upon the conclusion of ICANN's negotiations with the Registrars Stakeholder Group for a new Registrar Accreditation Agreement (RAA) as an issue that remained unresolved and that would be suited for a PDP. The 2013 RAA<https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en> contains an interim Specification on Privacy & Proxy Registrations<https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#pri…> that is due to expire on 1 January 2017. The WG's Initial Report, containing a number of detailed preliminary recommendations and several open questions for which it is seeking community input, was published for public comment on 5 May 2015. The announcement, forum for submitting comments, and a copy of the WG's Initial Report can be found here: https://www.icann.org/public-comments/ppsai-initial-2015-05-05-en. The WG's preliminary recommendations include: (i) requiring that accredited providers expressly include certain mandatory provisions in their customer terms of service; (ii) an obligation to relay initial electronic requests seeking to contact a customer; (iii) an illustrative framework for the handling of requests from trademark and copyright owners for the disclosure of customer contact information; and (iv) steps regarding provider de-accreditation. Open questions on which the WG has yet to reach consensus include the escalation of relay requests, how to deal with disclosure requests received from law enforcement and other third parties other than intellectual property rights-holders, and whether domain names associated with online financial transactions should be able to use privacy or proxy registrations. This webinar will highlight the WG's preliminary recommendations and open questions, including an opportunity to ask questions of the interim co-chairs. All are welcome; please reply to nathalie.peregrine(a)icann.org<mailto:nathalie.peregrine@icann.org> if you wish to attend and to receive details about logging on to the webinar.

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Webinar and update to public comment forum
by Mary Wong May 20, 2015

May 20, 2015

Dear WG members, This is to let you know that Steve and Graeme will be presenting our initial recommendations and open questions to the community through a webinar on Thursday 28 May, at 1400 UTC: https://www.icann.org/news/announcement-2015-05-19-en. Please let your respective groups and members know that they should RSVP to Nathalie (nathalie.peregrine(a)icann.org) if they wish to attend so that we can send them the call-in and Adobe Connect details. I¹m pleased also to note that translations of the Executive Summary of our Initial Report have been posted to the public comment webpage, in Arabic, Chinese, French, Russian and Spanish (I.e. the six UN languages, including English): https://www.icann.org/public-comments/ppsai-initial-2015-05-05-en. We hope this will be helpful especially to community members and commenters for whom English is not their first language. As noted previously, we will send out a notice advising of our regrouping to begin our review of public comments received, once the chairs determine that a sufficient number have been submitted that will allow for constructive discussion. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889 Email: mary.wong(a)icann.org

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Re: [Gnso-ppsai-pdp-wg] Public Comment Forum is now open
by Michele Neylon - Blacknight May 6, 2015

May 6, 2015

What he said And thanks to you and your colleagues for all the work in getting this so far Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains http://www.blacknight.host/ http://blog.blacknight.com/ http://www.blacknight.press - get our latest news & media coverage 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: James Gannon Date: Tuesday 5 May 2015 21:24 To: Mary Wong, "gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>" Subject: Re: [Gnso-ppsai-pdp-wg] Public Comment Forum is now open Thanks Mary now the hard work of outreach begins! -James 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 Mary Wong Sent: Tuesday, May 05, 2015 9:21 PM To: gnso-ppsai-pdp-wg(a)icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] Public Comment Forum is now open Dear WG members, In accordance with the WG’s latest Work Plan, our Initial Report was submitted yesterday for publication and public comment. I’m pleased to inform you that the Public Comment Forum is now open on the ICANN website: https://www.icann.org/public-comments/ppsai-initial-2015-05-05-en. A link to the Forum has also been placed on ICANN’s Announcement page, so that anyone who accesses the ICANN website to follow recent developments will also see it: https://www.icann.org/news/announcements. As is the case with other GNSO Working Groups, staff will compile a Public Comment Review Tool to assist the WG with its analysis of all the public comments that come in. The WG chairs will discuss when it might be desirable to begin this analysis, and notice of the start of those meetings will be sent out accordingly. Following feedback received, the chairs have requested that staff clarify that the optional template being provided to assist commenters with structuring their input is an additional option only, and that comments submitted via the Forum are definitely very welcome. We have also added specific references throughout the template to correspond to specific Recommendations and Sections in the Initial Report, to facilitate easier review of the Initial Report. Please note also that as the suggested 60-day period would have ended on a weekend, the Forum has been set to close on a weekday following that original date, thus making for a full 63-day public comment period. Thank you all for your efforts, contributions and hard work in ensuring that a substantive report was completed and sent out for community input at this time. We look forward to continuing the work as the WG proceeds toward our Final Report! 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<mailto:mary.wong@icann.org>

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Public Comment Forum is now open
by Mary Wong May 5, 2015

May 5, 2015

Dear WG members, In accordance with the WG¹s latest Work Plan, our Initial Report was submitted yesterday for publication and public comment. I¹m pleased to inform you that the Public Comment Forum is now open on the ICANN website: https://www.icann.org/public-comments/ppsai-initial-2015-05-05-en. A link to the Forum has also been placed on ICANN¹s Announcement page, so that anyone who accesses the ICANN website to follow recent developments will also see it: https://www.icann.org/news/announcements. As is the case with other GNSO Working Groups, staff will compile a Public Comment Review Tool to assist the WG with its analysis of all the public comments that come in. The WG chairs will discuss when it might be desirable to begin this analysis, and notice of the start of those meetings will be sent out accordingly. Following feedback received, the chairs have requested that staff clarify that the optional template being provided to assist commenters with structuring their input is an additional option only, and that comments submitted via the Forum are definitely very welcome. We have also added specific references throughout the template to correspond to specific Recommendations and Sections in the Initial Report, to facilitate easier review of the Initial Report. Please note also that as the suggested 60-day period would have ended on a weekend, the Forum has been set to close on a weekday following that original date, thus making for a full 63-day public comment period. Thank you all for your efforts, contributions and hard work in ensuring that a substantive report was completed and sent out for community input at this time. We look forward to continuing the work as the WG proceeds toward our Final Report! 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

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Case barring revealing identities by Yelp
by Kathy Kleiman May 4, 2015

May 4, 2015

Hi All, This is a case I have been meaning to share -- a decision of my state court (the Virginia Supreme Court) ruling that a judge did not have the authority to compel Yelp to reveal the identities of anonymous users who panned an Alexandria, Virginia carpet-cleaning company called Hadeed. As the Washington Post noted, this is "a case closely watched by free-speech advocates and businesses alike." The case does not mean that there is no ability to access the identity of the speakers (criticizers, in this case, of Hadeed), but under what laws does the request have to be evaluated? Paul Alan Levy, a well known attorney working for the advocacy group Public Citizen and representing Yelp (and its Customers), "welcomed the ruling, saying Hadeed would have to pursue the reviewers’ identities in California courts, which set a higher bar for revealing the identities of people making anonymous speech." The issues that the Virginia Supreme Court debated will sound very familiar -- "Hadeed subpoenaed the reviewers’ identities from Yelp, and an Alexandria Circuit Court judge ordered that the information be turned over. Yelp refused to comply with the ruling, saying it would appeal to protect its users’ First Amendment right to speak anonymously. Yelp and free-speech advocates said revealing the names of the reviewers would have a chilling effect on anonymous speech on the Web."* Happy reading -- http://www.washingtonpost.com/local/crime/yelp-wont-have-to-turn-over-names… Kathy *All quotes from the Washington Post article...

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Our Statement
by Kathy Kleiman May 3, 2015

May 3, 2015

Dear Graeme, Steve, Mary and All, Attached please find our supplemental statement for inclusion in the Interim Report. Mary, could you please use the attached Word version as it has the formatting and highlights we seek to show in the published version. I include a pasted version below for easy reading. Best, Kathy --------------------------------------------------------------------------------- Statement of Kathy Kleiman, James Gannon and Stephanie Perrin, Members of the Noncommercial Stakeholders Group We respectfully submit that Section 1.3.3, 1.3.3, *Specific Topics on which there is currently no consensus within the WG*, of this PPSAI Executive Summary and Interim Report is incomplete.There are a number of topics on which there is currently no consensus within the WG and which need considerable work. These are issues well known and deeply discussed. For the purposes of clarity and to lend depth to the comments and discussion to come, we submit this statement of how we would like to see Section 1.3.3 written. --------------------------------------------------------------------------------------------------------------------- 1.3.3, *Specific Topics on which there is currently no consensus within the WG* 1.3.3.1 REVEAL The WG’s has not yet reached final preliminary conclusions on key details of its “Reveal” recommendations (See Annex E of the Interim Report). There are many details still under discussion and for which the WG has not reached consensus. These include: -What remedies should a Customer be allowed in the event that a Reveal Request was falsely made or the data was improperly used (current recommendations provide mechanism only for Provider action)? -Should Requestors be allowed to escalate each and every rejection of a Reveal Request to a 3^rd party forum, or should the WG seek to adopt reasonable standards and thresholds for such appeals to avoid unnecessary and time-consuming appeals?(Note: a Request for Reconsideration is already a part of the recommended process the WG has agreed to by consensus.) -What rights and protections should a Customer be allowed and encouraged to forth in her/his/its own defense to provide a reasonable defense for maintaining her/his/its privacy, even in the face of a copyright or trademark infringement allegation? -How can Customers be protected from extraterritorial requests from Law Enforcement from outside their country, when the use of their domain name is for legal purposes in their own country, but perhaps purposes deemed illegal in other countries [Note: even Interpol refuses to act across national lines in matters of political, military, religious and racial issues because of the enormous differences of law. Article 3, Interpol Constitution] Input and comments would be helpful on these issues. 1.3.3.2 THE COMPLEXITIES OF INTRUDING INTO NATIONAL LAW Although the WG agreed that the mere fact that a domain name is registered by a commercial entity or by anyone conducting commercial activity should not preclude the use of P/P services[1] <#_ftn1>[1], there was disagreement over whether domain names that are actively used for commercial transactions (e.g. the sale or exchange of goods or services) should be prohibited from using P/P services. While *most WG members *did not believe such a prohibition is necessary or practical, some members believed that registrants of such domain names should not be able to use or continue using proxy or privacy services. [1] *Other members of the WG noted that fundraising and membership drives are often performed by the very groups and organizations seeking privacy/proxy registration for protection, including minority political groups, minority religious organizations, ethnic groups, organizations committed to change of racial policies, gender orientation groups, and publications engaged in freedom of expression. These groups and their representatives note that, in the laws of their countries, the mere collection of a donation or membership fee does not change their status from “non-commercial” to commercial. Others noted that “non-profit” status is limited to only a few countries. * *Further, many of organizations, small businesses, home-based businesses (including those run by mothers and seniors) conduct their financial transactions through 3^rd party e-commerce companies, such as PayPal, and thus /are not processing the financial transactions directly/. Accordingly, many members in the WG submit there is no reason to breach the proxy/privacy of organizations and businesses purely and solely for this reason. * *Many members many in the WG submit that content regulation is far beyond the scope of ICANN and properly the scope of national laws – some of which has taken initiatives in this area which are clearly defined and properly limited in scope and application (e.g., Germany).*** For those that argued that it is necessary and practical to limit access to P/P services to exclude commercial entities, the following text was proposed to clarify and define their position: “domains used for online financial transactions for commercial purpose should be ineligible for privacy and proxy registrations.” This suggestion has been debated strongly by the members of the WG and has not reached consensus as others submitted that: "Attempting to distinguish the end purposes of a domain registration is not practicable for the purposes of determining eligibility for privacy/proxy services, and will unfairly discriminate against vulnerable groups, entrepreneurs, small businesses and organizations who wish to exercise their rights of freedom of expression rights on the Internet. Input requested on the full issues, including questions below: ·Should registrants of domain names associated with commercial activities and which are used for online financial transactions be prohibited from using, or continuing to use, privacy and proxy services? ·Is this type of content regulation outside of ICANN's scope and mandate and the proper province of national law? ------------------------------------------------------------------------ <#_ftnref1>[1]The WG notes that the WHOIS RT had specifically acknowledged that P/P services can be and are used to address legitimate interests, both commercial and non-commercial.

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Additional name to our Statement
by Kathy Kleiman May 1, 2015

May 1, 2015

Hi Mary, Could you please add Holly Raiche to our statement. The line would now read: Statement of Kathy Kleiman, James Gannon, Stephanie Perrin and David Cake, Members of the Noncommercial Stakeholders Group, and Holly Raiche, Member of the At-Large Advisory Committee. Tx! Kathy

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Additional signatory to our Statement
by Kathy Kleiman May 1, 2015

May 1, 2015

Hi Steve, Graeme and Mary, David Cake has asked to join our statement. Mary, could you kindly add him to our opening line? Tx, Kathy

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