Pursuant to Mary’s request, I suggest the following additional issues raised in comments contained in the public comment tool document summarized, for possible consideration by the WG:

3.            Response to Question 3:   Should the proposed requirement to label p/p registrations as such be dispensed with because it reduces the benefit or value of such registration?  (Comments 18, 25, 31)

4.            Response to Question 8:  Should providers be required to forward all disclosure requests to customers, unless prohibited by law?  (Comments 17, 29)  (I.e., should this feature of Annex E be made applicable to all disclosure requests, not just those relating to intellectual property?)

5.            Response to Question 8:  Should the option of registration cancellation in lieu of disclosure be prohibited?  (Comments 24, 31)

In addition, with regard to issue #2 as summarized  below (“law enforcement authority” definition):  since the definition in our initial report was copied from the 2013 RAA, can any registrars in our group report on whether or not this definition has thus far caused difficulties in the RAA context (e.g., have there been problems in determining whether a complaint from a “quasi-governmental entity” should be handled under RAA section 3.18.2, with its 24-hour time limit, rather than under 3.18.1)?    

Steve Metalitz

From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Mary Wong
Sent: Tuesday, August 11, 2015 4:04 PM
To: gnso-ppsai-pdp-wg@icann.org
Subject: [Gnso-ppsai-pdp-wg] Issue-spotting for the WG's preliminary recommendations

Dear WG members,

As noted on the WG call earlier today, please send to this your suggestions for issues arising out of specific public comments received on the WG’s Preliminary Recommendations #1 through #9 that you think should be discussed by the broader WG. 

From the call today, two issues with Recommendation #1 were identified for WG consideration:

• Whether the definitions include lawyers and law firms that provide proxy registration services for their clients other than as a primary business offering;
• The possible breadth/vagueness of the proposed definition of “law enforcement authority” as including quasi-governmental and other entities

Since the WG Public Comment Review Tool for these nine recommendations have been in circulation since 20 July, please treat this email as a “last call” for issue-spotting concerning these nine recommendations – as such, please send any issues you spot to this list by Friday 14 August. Please also indicate in your email which comment(s)/commenter(s) you are referring to as raising the issue(s) you identify. Note that, as confirmed during the WG call today, this exercise is for purposes of issue-spotting only at the moment rather than final resolution, which will depend on further discussions, as appropriate.

Staff will compile the issues so identified for review by the WG on our next call.

Thanks and cheers

Mary

Mary Wong

Senior Policy Director

Internet Corporation for Assigned Names & Numbers (ICANN)

Telephone: +1 603 574 4889

Email: mary.wong@icann.org