Hello All, 

I have given more thought about  the discussion concerning  accredited proxy vendors versus all other unaccredited proxy vendors, including lawyers.   It seems to me that we are never going to be able to capture each variation of the unaccredited proxy vendor and James brought up a point that I think we should consider.  

If accredited proxy vendors adhere to all the requirements we are describing they will have the benefit of not being considered the registrant of the domain name.  

Any other type of unaccredited proxy service should simply not exist and they should always be considered the registrant with all the rights and liabilities that go along with being the registrant.  We simply would not recognize any other existing relationship.  

We could make this very clear Accredited proxy or registrant and not delve into all the grey areas.    

The unaccredited proxy provider would be considered the Registrant in all actions including the URS and UDRP.  

I am hoping we can discuss further on the call tomorrow. 

Best, 

Susan Kawaguchi

Facebook, Inc. 

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