April 30, 2015
3:56 p.m.
I agree, very sensible, assuming this means you will withdraw the proposed ancillary questions which have kicked off this debate. Kind regards Stephanie On 2015-05-01 0:42, James Gannon wrote: > > Steve, > > That seems like a logical compromise between both sides, it has my > full support. > > -James > > *From:*gnso-ppsai-pdp-wg-bounces@icann.org > [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *Metalitz, > Steven > *Sent:* Thursday, April 30, 2015 4:36 PM > *To:* 'Graeme Bunton'; gnso-ppsai-pdp-wg@icann.org > *Subject:* Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3 > > Graeme and I have asked staff to insert a footnote in this section, > providing links to the extensive discussions of the topic in WG > meetings (telephonic and face to face) and on the mailing list, as > background for the public. > > Steve > > *From:*gnso-ppsai-pdp-wg-bounces@icann.org > <mailto:gnso-ppsai-pdp-wg-bounces@icann.org> > [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *Graeme Bunton > *Sent:* Thursday, April 30, 2015 11:14 AM > *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> > *Subject:* Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3 > > Steve, myself and staff are discussing how to proceed while ensuring > that balance is maintained. > Thank you all for your contributions. > > Graeme > On 2015-04-30 11:02 AM, Stephanie Perrin wrote: > > So let me get this very very clear, as i am new to the process. > > 1. The research report you offered was sent to the list. > > 2. It has never been part of the record. > > 3. You wish to see it added now, April 30th, 23:58 KST. > > 4, You are telling me I could have done the same thing. > > 5. I have Exactly how much time to submit a minority report in order > > to comply with the deadline of April 30th? > > > > Thanks for the clarifications. > > Stephanie > > > > On 2015-04-30 23:52, Kiran Malancharuvil wrote: > >> Stephanie, > >> > >> You had ample opportunity to prepare and present a white paper of > >> your own. > >> > >> It was not unsolicited, as at any time, members of the group are > >> welcome and encouraged to present their views on the matter under > >> discussion. > >> > >> Are you really saying that a well researched policy position and a > >> presentation of that research is NOT meant to be a part of the PDP > >> process? I really do not think that it the case. > >> > >> I know that you object to the position that the white paper explains, > >> but unless there is a concrete prohibition on linking to it (staff?) > >> it needs to be included, as we have every right to present the > >> complex legal argument behind our position. > >> > >> Kiran Malancharuvil > >> Internet Policy Counselor > >> MarkMonitor > >> 415-419-9138 (m) > >> > >> Sent from my mobile, please excuse any typos. > >> > >>> On Apr 30, 2015, at 7:45 AM, Stephanie Perrin > >>> <stephanie.perrin@mail.utoronto.ca > <mailto:stephanie.perrin@mail.utoronto.ca>> wrote: > >>> > >>> With great respect to Kiran and to the law firm that compiled the > >>> "white paper", I objected at the time and there was no indication > >>> that we accepted the white paper in our discussions, other than to > >>> say thanks. I would object strenuously to it being included. That > >>> was a totally unsolicited contribution from parties wishing to > >>> advance their case. You cannot attach that paper, without giving > >>> those on the other side an opportunity to counter it with another > >>> white paper. Frankly, the PDP process is not supposed to be about > >>> dualling unsolicited white papers. IF we need to have research > >>> done, we have to agree on what needs to be done if it is to be > >>> attached to the official call for comments. I don't wish to be > >>> ungracious, but the paper should not be added. > >>> Stephanie Perrin > >>> > >>>> On 2015-04-30 23:34, Kiran Malancharuvil wrote: > >>>> It is a recommendation for a policy/best practice from a portion of > >>>> the group. > >>>> > >>>> K > >>>> > >>>> Kiran Malancharuvil > >>>> Internet Policy Counselor > >>>> MarkMonitor > >>>> 415-419-9138 (m) > >>>> > >>>> Sent from my mobile, please excuse any typos. > >>>> > >>>>> On Apr 30, 2015, at 7:33 AM, James Gannon > >>>>> <james@cyberinvasion.net <mailto:james@cyberinvasion.net>> wrote: > >>>>> > >>>>> Unless we are suggesting that the whitepaper is consensus policy > >>>>> or best practice it does not fall under that category. We are > >>>>> presenting our policy recommendation already, which is the work > >>>>> product of the group > >>>>> > >>>>> -James > >>>>> > >>>>> -----Original Message----- > >>>>> From: Kiran Malancharuvil > >>>>> [mailto:Kiran.Malancharuvil@markmonitor.com] > >>>>> Sent: Thursday, April 30, 2015 3:31 PM > >>>>> To: James Gannon > >>>>> Cc: Mary Wong; PPSAI > >>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section > >>>>> 1.3.3 > >>>>> > >>>>> Recommendations for policies, guidelines, best practices. > >>>>> > >>>>> Kiran Malancharuvil > >>>>> Internet Policy Counselor > >>>>> MarkMonitor > >>>>> 415-419-9138 (m) > >>>>> > >>>>> Sent from my mobile, please excuse any typos. > >>>>> > >>>>>> On Apr 30, 2015, at 7:29 AM, James Gannon > >>>>>> <james@cyberinvasion.net <mailto:james@cyberinvasion.net>> wrote: > >>>>>> > >>>>>> Quoting from the PDP Manual, there seems to be strong guidelines > >>>>>> of what goes out with the Initial Report: > >>>>>> > >>>>>>> After collection and review of information, the PDP Team and > >>>>>>> Staff are responsible for producing an Initial Report. The > >>>>>>> Initial Report should include the following elements: > >>>>>>> * Compilation of Stakeholder Group and Constituency Statements > >>>>>>> * Compilation of any statements received from any ICANN > >>>>>>> Supporting Organization or Advisory Committee > >>>>>>> * Recommendations for policies, guidelines, best practices or > >>>>>>> other proposals to address the issue > >>>>>>> * Statement of level of consensus for the recommendations > >>>>>>> presented in the Initial Report > >>>>>>> * Information regarding the members of the PDP Team, such as the > >>>>>>> attendance records, Statements of Interest, etc. > >>>>>>> * A statement on the WG discussion concerning impact of the > >>>>>>> proposed recommendations, could consider areas such as economic, > >>>>>>> competition, operations, privacy and other rights, scalability > >>>>>>> and feasibility > >>>>>> I don't see where in that framework the whitepaper would sit. I > >>>>>> would welcome others thoughts on this. > >>>>>> > >>>>>> -James > >>>>>> > >>>>>> -----Original Message----- > >>>>>> From: gnso-ppsai-pdp-wg-bounces@icann.org > <mailto:gnso-ppsai-pdp-wg-bounces@icann.org> > >>>>>> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Kiran > >>>>>> Malancharuvil > >>>>>> Sent: Thursday, April 30, 2015 3:09 PM > >>>>>> To: Mary Wong > >>>>>> Cc: PPSAI > >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section > >>>>>> 1.3.3 > >>>>>> > >>>>>> Mary, > >>>>>> > >>>>>> Since one side of this issue prepared a lengthy legal review to > >>>>>> address this question, I would request that that white paper be > >>>>>> included in the reference materials for the public comment. Since > >>>>>> public comment is meant to "resolve" this issue, commenters need > >>>>>> all of the information. > >>>>>> > >>>>>> It's not just down to feasibility of self-declaration at > >>>>>> registration (which frankly, many of us see as a cop out since > >>>>>> it's already done in some TLDs), but also legality. > >>>>>> Not trying to re-open the debate, but please, let's make sure the > >>>>>> community understands the various points and the background. > >>>>>> > >>>>>> K > >>>>>> > >>>>>> > >>>>>> Kiran Malancharuvil > >>>>>> Internet Policy Counselor > >>>>>> MarkMonitor > >>>>>> 415-419-9138 (m) > >>>>>> > >>>>>> Sent from my mobile, please excuse any typos. > >>>>>> > >>>>>> On Apr 30, 2015, at 6:58 AM, Mary Wong > >>>>>> <mary.wong@icann.org<mailto:mary.wong@icann.org > <mailto:mary.wong@icann.org%3cmailto:mary.wong@icann.org>>> wrote: > >>>>>> > >>>>>> To add to Stephanie's note that this specific issue - whether > >>>>>> registrants of domain names actively used for commercial > >>>>>> transactions ought to be disallowed from using P/P services - had > >>>>>> been discussed at some length by the WG: > >>>>>> > >>>>>> Please note that this part of the Initial Report draws heavily on > >>>>>> the detailed WG template for Charter Category C that was the > >>>>>> basis for the WG's deliberations on this topic. That template > >>>>>> contains lengthy descriptions of what had previously been termed > >>>>>> the majority and minority positions on the WG's answer to this > >>>>>> specific issue. As part of the WG's deliberations - which took > >>>>>> place primarily between April and June 2014 - the more specific > >>>>>> formulation of "transactional" to describe the sort of commercial > >>>>>> (i.e. Involving financial transactions) activities that were > >>>>>> being discussed was included in the language. All the templates > >>>>>> and suggested formulations discussed by the WG are recorded and > >>>>>> published on the WG wiki. > >>>>>> > >>>>>> The WG ultimately agreed to retain the two positions in the > >>>>>> Initial Report and to revisit the question during its review of > >>>>>> the public comments received. As noted previously, the WG's views > >>>>>> were presented to the community in London in June 2014 and again > >>>>>> in Los Angeles in October 2014. > >>>>>> > >>>>>> Therefore, the three questions in Section 1.3.3 of the Executive > >>>>>> Summary only go toward soliciting community input on this single > >>>>>> issue. They were not intended to represent a view of any "side" > >>>>>> in the WG with regard to this matter. If the WG prefers, we can > >>>>>> add a sentence to clarify and specify the reason for the > >>>>>> questions in Section 1.3.3. Fundamentally, the idea is that > >>>>>> public comments will facilitate the WG's eventual resolution of > >>>>>> this issue as part of its preparation of the Final Report. > >>>>>> > >>>>>> We hope this reminder of the background is of assistance. > >>>>>> > >>>>>> Cheers > >>>>>> Mary > >>>>>> > >>>>>> Mary Wong > >>>>>> Senior Policy Director > >>>>>> Internet Corporation for Assigned Names & Numbers (ICANN) > >>>>>> Telephone: +1 603 574 4892 > >>>>>> Email: mary.wong@icann.org<mailto:mary.wong@icann.org > <mailto:mary.wong@icann.org%3cmailto:mary.wong@icann.org>> > >>>>>> > >>>>>> > >>>>>> > >>>>>> From: Stephanie Perrin > >>>>>> > <stephanie.perrin@mail.utoronto.ca<mailto:stephanie.perrin@mail.utoronto.ca > <mailto:stephanie.perrin@mail.utoronto.ca%3cmailto:stephanie.perrin@mail.utoronto.ca>>> > >>>>>> Date: Thursday, April 30, 2015 at 09:20 > >>>>>> To: > >>>>>> > "gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> > <mailto:gnso-ppsai-pdp-wg@icann.org%3cmailto:gnso-ppsai-pdp-wg@icann.org%3e>" > > >>>>>> <gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org > <mailto:gnso-ppsai-pdp-wg@icann.org%3cmailto:gnso-ppsai-pdp-wg@icann.org>>>, > James > >>>>>> Gannon <james@cyberinvasion.net<mailto:james@cyberinvasion.net > <mailto:james@cyberinvasion.net%3cmailto:james@cyberinvasion.net>>>, > >>>>>> Michele Blacknight > >>>>>> <michele@blacknight.com<mailto:michele@blacknight.com > <mailto:michele@blacknight.com%3cmailto:michele@blacknight.com>>> > >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section > >>>>>> 1.3.3 > >>>>>> > >>>>>> James, prior to you joining the group, we had discussed this at > >>>>>> some length. IN fact, I really thought that the many reasons why > >>>>>> sorting out the purpose of a registration is problematic had > >>>>>> buried this debate, but apparently not. Some of the issues > >>>>>> raised, according to my recollection were the following: > >>>>>> > >>>>>> * names are registered prior to decisions about content > >>>>>> * content changes over time > >>>>>> * most countries regulate e-commerce in some fashion, so that > >>>>>> website commercial activity does not have to be regulated by ICANN > >>>>>> * ICANN should not be in the business of regulating content in > >>>>>> the first place (and sorting out who is extracting a material > >>>>>> consideration from a website in order to deny them the ability to > >>>>>> use a proxy registration is certainly a form of regulation) > >>>>>> * definitions of commercial activity vary widely around the world > >>>>>> * bad actors will not declare, registrars cannot police this > >>>>>> matter > >>>>>> * criminal prosecution is not dependent on WHOIS information > >>>>>> * if this is really about the ability to detect market > >>>>>> information, ICANN should not be in the business of making > >>>>>> registrant information available for market purposes, it does it > >>>>>> for security and stability. > >>>>>> * contactability remains, regardless of which registrant info > >>>>>> appears in WHOIS > >>>>>> > >>>>>> I am planning to reformulate these into questions to match the > >>>>>> questions on the other side, suggestions welcome. > >>>>>> > >>>>>> Stephanie Perrin > >>>>>> On 2015-04-30 16:24, James Gannon wrote: > >>>>>> I don't see this as asking providers to enforce anything similar > >>>>>> to other questions when registering a domain, it's a > >>>>>> self-reported assessment. All it does is add an additional branch > >>>>>> to the decision tree for eligibility, which will already be there > >>>>>> to determine eligibility due to the other reasons listed below. > >>>>>> The registrant is asked will you be processing financial > >>>>>> transactions. > >>>>>> > >>>>>> > >>>>>> * Yes-->Will you be using a 3rd party>No>Not eligible for > >>>>>> P/P. > >>>>>> > >>>>>> * Yes-->Will you be using a 3rd party>Yes>Eligible for P/P. > >>>>>> > >>>>>> > >>>>>> I'm not asking registrars to enforce law but to see if a more > >>>>>> finely grained eligibility process can be enacted. Or at least is > >>>>>> there is public support for more granularity. > >>>>>> > >>>>>> -James > >>>>>> From: Michele Neylon - Blacknight [mailto:michele@blacknight.com] > >>>>>> Sent: Thursday, April 30, 2015 8:17 AM > >>>>>> To: James Gannon; Graeme Bunton; PPSAI > >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section > >>>>>> 1.3.3 > >>>>>> > >>>>>> James > >>>>>> > >>>>>> As a registrar or PP service provider how am I meant to assess > this? > >>>>>> > >>>>>> It doesn't scale > >>>>>> > >>>>>> Seriously. > >>>>>> > >>>>>> If, for example, there is an Irish operated website that is not > >>>>>> complying with Irish law then it would be up to the ODCE > >>>>>> (http://www.odce.ie/ > <https://protect-us.mimecast.com/r/IqfLPS2xhmx-5GDCPCM4mLmlw-jOPQHGmhpzAjWDKActStEmX7ndjfqnEIgUMkdhXCAGe_aALVo69T0irIiCOftGW0RRkFeeJXP_SQ_bxxN5c9ZWrJzjnfSpDUeI4UjuT2dsrtgXox-JsiUyGsBvbDhSHcf2gH3gqSI2YwvUnORJuOhanPP2uCSQp3bey2BqQKbirhovyP6hDiunUi2Ilg>) > to enforce whatever needs enforcing, as it > >>>>>> would be up to the DPA to enforce any issues around data privacy > >>>>>> etc., etc., > >>>>>> > >>>>>> Attempting to force registrars and PP providers to make these > >>>>>> kind of evaluations is not going to work. > >>>>>> > >>>>>> Issues like PCI-DSS compliance are matters that should be dealt > >>>>>> with by the DPA and the banks. > >>>>>> > >>>>>> Forcing registrars and PP providers to start getting involved in > >>>>>> that kind of assessment isn't viable > >>>>>> > >>>>>> Regards > >>>>>> > >>>>>> Michele > >>>>>> > >>>>>> -- > >>>>>> Mr Michele Neylon > >>>>>> Blacknight Solutions > >>>>>> Hosting, Colocation & Domains > >>>>>> http://www.blacknight.host/ > <https://protect-us.mimecast.com/r/r0QiXaZk72F7OmWKc9_pO3HAiIAvI3h06-RcgETJh-J4kMLvQtMGZn5lKnoQO8ikZnQiTNL6FLbYD67s4dF-tWj2IbgtPVbZIrmLhFiT8cZvRoXUKLem6cyG8n3JE6-tis8tEkBPwKkOuqFU7azbPzFSZPBE0XjNt1o6W5MAy5yWOEr-3QLGcTYMC5oDDDwuftYuz9pHDOyvEieReE36N1UxTeWXBI__3g1_xmHN4S0> > >>>>>> http://blog.blacknight.com/ > <https://protect-us.mimecast.com/r/wl1MfvJ8aWTxnqz6FCsjG4QE5Lt8k3OKgMWheA8wVhCgpAj6NRi9Y8zMxa9MvTN2vhD-EWNpvAhObo3t9Jl-Kh7ki557bXwOMPGhz-Up4X8e1Q8UR-DF0d4jYhrGpb0LrotD50UduC3QQRYUJ24nEnbyayh-GPs3hk77LhEpDwYrSf4v_RqmohacWFuO-pMc6Ap8I9JulleUf0h9FbW-MHMc1xlq8F7WXPVnekaa_Tg> > >>>>>> http://www.blacknight.press > <https://protect-us.mimecast.com/r/-MRGGedz53TF8UWq3rKo8GI39ai_ismqN0UYggzFnhsCzIT83jwX24BSxN_VMtJYpUgkSGF-Qst71LuBVQLY87bs-vewJiEDX8p5ABHKofJc69pmthPRFaowH9cz7b4wBdr45nD9yW3n5wmmAGAorNORPO2oD8fx1b7Ch4UucRtocG7TVoD8q8xePkXjqmELFjL3powas7Q8SOSYQE947lLpZzCcGrOwqu7wogrVuvk> > - get our latest news & media > >>>>>> coverage http://www.technology.ie > <https://protect-us.mimecast.com/r/suwZNIiJfrdSpqE4iC56mMY3x3S91aHmdyA2bCRS-Fmr9Q1_uNxFISl4UXNQGJAa4ABDSoMKKJoH4LBI6dPDpw1IcPIW2UD6KmY-khZffkUgGyGTLPU0VW-nWld8z7P0H2Ru_lA2gyfCIuoaN7WmFU6IRQ9AVVBKNMpsRsxQkxp27qp4b1vr0Nu7xAxlXjinmqCYcWDyv6BlIGk1JID86YB5QMhEW98wyZ5sollRXTc> > Intl. +353 (0) 59 9183072 > >>>>>> Direct Dial: +353 (0)59 9183090 > >>>>>> Social: http://mneylon.social > <https://protect-us.mimecast.com/r/c9ciyb99CMvSHLw2MJX2WYjWAGojFAv6abNbJNSbdh-ZFyKYiMOesCOSW0IbP_Hk74wcQMPR4LFdtPIo3qwpdVxkGjxnPEF73YlWOioKWfm0ASY6v7enF3zKmqddqH2G4dXIbPg_PVqGwzzZzhWQxKSK2MKPyc4QXazyYJjS7H_X2JdIq2B8eAZeCDmgPBWH09Ix-VujUi5pHJeE_GXWIlFrE4TTH0hP08WIPWYQvhY> > >>>>>> ------------------------------- > >>>>>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business > >>>>>> Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 > >>>>>> > >>>>>> From: James Gannon > >>>>>> Date: Thursday 30 April 2015 07:45 > >>>>>> To: Graeme Bunton, > >>>>>> > "gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> > <mailto:gnso-ppsai-pdp-wg@icann.org%3cmailto:gnso-ppsai-pdp-wg@icann.org%3e>" > >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section > >>>>>> 1.3.3 > >>>>>> > >>>>>> I would personally like to see if there is public traction for > >>>>>> distinguishing between sites directly processing financial > >>>>>> truncations and sites who use 3rd parties for processing > >>>>>> financial transactions as this is a very important distinction. A > >>>>>> simple and I hope non-controversial additional question to the > >>>>>> ones below: > >>>>>> If so, should domains which use a third party to process > >>>>>> financial transactions (i.e Paypal, Stripe), and thus do not > >>>>>> directly process financial information, be subject to the same > >>>>>> restrictions? > >>>>>> There are strong existing distinctions both in national laws and > >>>>>> in regulations such as PCI-DSS between these two forms. > >>>>>> > >>>>>> -James Gannon > >>>>>> > From:gnso-ppsai-pdp-wg-bounces@icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org> > > >>>>>> [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Graeme > >>>>>> Bunton > >>>>>> Sent: Tuesday, April 28, 2015 10:17 PM > >>>>>> To: PPSAI > >>>>>> Subject: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3 > >>>>>> > >>>>>> Thanks to all WG members for a very productive call earlier > >>>>>> today(and to Steve for his chairing acumen). The co-chairs and > >>>>>> staff met this afternoon to tie down two loose ends from the call. > >>>>>> > >>>>>> Regarding the deadline for public comments on the Initial Report, > >>>>>> we recognize there is considerable support for extending the > >>>>>> public comment period to 60 days instead of the standard 40 days > >>>>>> on which we have all been planning. We are prepared to agree to > >>>>>> this, but with the caveat that this will have repercussions on > >>>>>> the pace and intensity of our work once public comments have been > >>>>>> received. Specifically, if the public comment deadline is > >>>>>> extended until July 3 (60 days after our publication date of May > >>>>>> 4), we will need to plan on at least weekly calls throughout July > >>>>>> and August, some of which may need to be more than an hour in > >>>>>> length, to review these comments and move toward a Final Report. > >>>>>> Otherwise, we jeopardize the prospects for getting the Final > >>>>>> Report in front of the GNSO council no later than the Dublin > >>>>>> ICANN meeting. As was noted on the call today, many additional > >>>>>> steps need to take place even after this WG issues its Final > >>>>>> Report before any new accreditati > > on > >>>> system can be implemented, so the time pressure imposed by the > >>>> expiration of the Interim Specification at the end of next year is > >>>> already real. > >>>>>> Also, as previously announced over the past few weeks, if any WG > >>>>>> members (or group of members) wish to submit a brief separate or > >>>>>> additional statement for inclusion in the package posted for > >>>>>> public comment next Monday, such statements need to be received > >>>>>> by staff no later than Thursday, April 30. > >>>>>> > >>>>>> Lastly, the other loose end involves proposed revisions to > >>>>>> section 1.3.3 of the Initial Report, which were presented on the > >>>>>> call earlier today but which we did not have time to discuss > >>>>>> fully. We agree that this section could benefit from some > >>>>>> revision, but believe it should take the form of greater > >>>>>> concision, not additional presentation of arguments for the > >>>>>> divergent positions. Thus we suggest that section 1.3.3 be > >>>>>> revised to read as follows: > >>>>>> > >>>>>> --- > >>>>>> 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 , > >>>>>> 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. > >>>>>> > >>>>>> 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." > >>>>>> > >>>>>> Public comment is therefore specifically invited on the following > >>>>>> questions: > >>>>>> > >>>>>> * 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? > >>>>>> * If so, will it be useful to adopt a definition of > >>>>>> "commercial" or "transactional" to define those domains for which > >>>>>> P/P service registrations should be disallowed? And if so, what > >>>>>> should the definition(s) be?" > >>>>>> * Will it be necessary to make a distinction in the WHOIS data > >>>>>> fields to be displayed as a result? > >>>>>> --- > >>>>>> Thanks, > >>>>>> > >>>>>> Graeme Bunton & Steve Metalitz > >>>>>> > >>>>>> > >>>>>> > >>>>>> > >>>>>> -- > >>>>>> > >>>>>> _________________________ > >>>>>> > >>>>>> Graeme Bunton > >>>>>> > >>>>>> Manager, Management Information Systems > >>>>>> > >>>>>> Manager, Public Policy > >>>>>> > >>>>>> Tucows Inc. > >>>>>> > >>>>>> PH: 416 535 0123 ext 1634 > >>>>>> > >>>>>> > >>>>>> > >>>>>> _______________________________________________ > >>>>>> Gnso-ppsai-pdp-wg mailing list > >>>>>> > Gnso-ppsai-pdp-wg@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org>https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > > >>>>>> > >>>>>> > >>>>>> _______________________________________________ > >>>>>> Gnso-ppsai-pdp-wg mailing list > >>>>>> Gnso-ppsai-pdp-wg@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org > <mailto:Gnso-ppsai-pdp-wg@icann.org%3cmailto:Gnso-ppsai-pdp-wg@icann.org>> > >>>>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > >>>>>> _______________________________________________ > >>>>>> Gnso-ppsai-pdp-wg mailing list > >>>>>> Gnso-ppsai-pdp-wg@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> > >>>>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > >>>> _______________________________________________ > >>>> Gnso-ppsai-pdp-wg mailing list > >>>> Gnso-ppsai-pdp-wg@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> > >>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > >>> > >>> _______________________________________________ > >>> Gnso-ppsai-pdp-wg mailing list > >>> Gnso-ppsai-pdp-wg@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> > >>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > > > > > > _______________________________________________ > > Gnso-ppsai-pdp-wg mailing list > > Gnso-ppsai-pdp-wg@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> > > https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > > -- > _________________________ > Graeme Bunton > Manager, Management Information Systems > Manager, Public Policy > Tucows Inc. > PH: 416 535 0123 ext 1634 > > _______________________________________________ > Gnso-ppsai-pdp-wg mailing list > Gnso-ppsai-pdp-wg@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> > https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg > <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> > > > > _______________________________________________ > Gnso-ppsai-pdp-wg mailing list > Gnso-ppsai-pdp-wg@icann.org > https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg