A proposed approach for reviewing public comments
Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a ³test case² for the exercise. * As outlined on the call, a sub team will do a ³first pass² through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will ³collapse² (per James¹ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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
Hi all, considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively. That said, I volunteer for the first team. I support the sugestion to "collapse" yes and no responses. Best, Volker Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
_______________________________________________ Gnso-ppsai-pdp-wg mailing list 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@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@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.
All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
_______________________________________________ Gnso-ppsai-pdp-wg mailing list 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@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@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@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
_______________________________________________ Gnso-ppsai-pdp-wg mailing list 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@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@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@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
+1. Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com> wrote:
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy
---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it.
The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments.
Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright?
One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely.
Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need.
Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy
On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
*1. Use of Sub Teams for Specific Topics*:
- Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). - To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. - As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. - Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
*2. Full WG Review of Other Comments to Continue in Parallel*:
- Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
*3. Collated Information*:
- In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
_______________________________________________ Gnso-ppsai-pdp-wg mailing listGnso-ppsai-pdp-wg@icann.orghttps://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@key-systems.net
Web: www.key-systems.net / www.RRPproxy.netwww.domaindiscount24.com / www.BrandShelter.com
Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook:www.facebook.com/KeySystemswww.twitter.com/key_systems
Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534
Member of the KEYDRIVE GROUPwww.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@key-systems.net
Web: www.key-systems.net / www.RRPproxy.netwww.domaindiscount24.com / www.BrandShelter.com
Follow us on Twitter or join our fan community on Facebook and stay updated:www.facebook.com/KeySystemswww.twitter.com/key_systems
CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534
Member of the KEYDRIVE GROUPwww.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 listGnso-ppsai-pdp-wg@icann.orghttps://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
_______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process. Thank you, J. ____________ James Bladel GoDaddy On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com<mailto:carlton.samuels@gmail.com>> wrote: +1. Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Planning, Governance, Assessment & Turnaround ============================= On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com<mailto:kathy@kathykleiman.com>> wrote: Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote: Hi all, considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively. That said, I volunteer for the first team. I support the sugestion to "collapse" yes and no responses. Best, Volker Am 15.07.2015 um 00:50 schrieb Mary Wong: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889<tel:%2B1%20603%20574%204889> Email: mary.wong@icann.org<mailto:mary.wong@icann.org> _______________________________________________ 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 -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verf?gung. Mit freundlichen Gr??en, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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> Gesch?ftsf?hrer: 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 f?r den angegebenen Empf?nger bestimmt. Jede Form der Kenntnisgabe, Ver?ffentlichung oder Weitergabe an Dritte durch den Empf?nger ist unzul?ssig. Sollte diese Nachricht nicht f?r 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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments. This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw. Best, Volker Am 15.07.2015 um 17:58 schrieb James M. Bladel:
While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process.
Thank you,
J. ____________ James Bladel GoDaddy
On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com <mailto:carlton.samuels@gmail.com>> wrote:
+1.
Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate.
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 /Strategy, Planning, Governance, Assessment & Turnaround/ =============================
On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com <mailto:kathy@kathykleiman.com>> wrote:
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it.
The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments.
Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright?
One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely.
Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need.
Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy
On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
Thanks and cheers Mary
Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889 <tel:%2B1%20603%20574%204889> Email: mary.wong@icann.org <mailto:mary.wong@icann.org>
_______________________________________________ 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
-- 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 <tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.:+49 (0) 6894 - 9396 851 <tel:%2B49%20%280%29%206894%20-%209396%20851> Email:vgreimann@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 <tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.:+49 (0) 6894 - 9396 851 <tel:%2B49%20%280%29%206894%20-%209396%20851> Email:vgreimann@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@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
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-- 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@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@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.
+1 to Volker and Phil and James B, as well as of course all others looking for more time. Let's take this seriously, folks. Some of us who are are on other WGs are also all stretched beyond capacity. I expect staff are as well. Stephanie P On 2015-07-15 12:05, Volker Greimann wrote:
Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments.
This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw.
Best,
Volker
Am 15.07.2015 um 17:58 schrieb James M. Bladel:
While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process.
Thank you,
J. ____________ James Bladel GoDaddy
On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com <mailto:carlton.samuels@gmail.com>> wrote:
+1.
Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate.
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 /Strategy, Planning, Governance, Assessment & Turnaround/ =============================
On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com <mailto:kathy@kathykleiman.com>> wrote:
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it.
The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments.
Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright?
One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely.
Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need.
Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy
On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
Thanks and cheers Mary
Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889 <tel:%2B1%20603%20574%204889> Email: mary.wong@icann.org <mailto:mary.wong@icann.org>
_______________________________________________ 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
-- 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 <tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.:+49 (0) 6894 - 9396 851 <tel:%2B49%20%280%29%206894%20-%209396%20851> Email:vgreimann@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 <tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.:+49 (0) 6894 - 9396 851 <tel:%2B49%20%280%29%206894%20-%209396%20851> Email:vgreimann@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@icann.org <mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
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-- 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@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@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@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
Agree with all previous comments .. There’s no point trying to keep to an unreasonable timeline simply for the sake of it -- 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 Random Stuff: http://www.michele.irish ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: <gnso-ppsai-pdp-wg-bounces@icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org>> on behalf of Stephanie Perrin Date: Wednesday 15 July 2015 12:10 To: "gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>" Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation +1 to Volker and Phil and James B, as well as of course all others looking for more time. Let's take this seriously, folks. Some of us who are are on other WGs are also all stretched beyond capacity. I expect staff are as well. Stephanie P On 2015-07-15 12:05, Volker Greimann wrote: Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments. This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw. Best, Volker Am 15.07.2015 um 17:58 schrieb James M. Bladel: While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process. Thank you, J. ____________ James Bladel GoDaddy On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com<mailto:carlton.samuels@gmail.com>> wrote: +1. Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Planning, Governance, Assessment & Turnaround ============================= On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com<mailto:kathy@kathykleiman.com>> wrote: Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote: Hi all, considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively. That said, I volunteer for the first team. I support the sugestion to "collapse" yes and no responses. Best, Volker Am 15.07.2015 um 00:50 schrieb Mary Wong: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889<tel:%2B1%20603%20574%204889> Email: mary.wong@icann.org<mailto:mary.wong@icann.org> _______________________________________________ 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 -- 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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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@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@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@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@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@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org>https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
I agree with the extended timeline. I would also like to propose that prior to establishing sub-teams that further effort be expended on a technical solution for sorting the public comments. Thus far, I've pulled out 453 comments that state (and I'm sure there are hundreds more): "Regarding the proposed rules governing companies that provide WHOIS privacyservices (as set forth in the Privacy and Policy Services AccreditationIssues Policy document): I urge you to respect internet users rights toprivacy and due process.Everyone deserves the right to privacy. No one's personal informationshould be revealed without a court order, regardless of whether the requestcomes from a private individual or law enforcement agency.Private information should be kept private. Thank you." I am sure that the NameCheap "canned" submissions will net thousands, also. Perhaps we need to step back and consider the time we could save in the end by expending a little more time up front by developing an automated process to sort through at least some of these comments. Thanks for consideration. On Wed, Jul 15, 2015 at 12:25 PM, Michele Neylon - Blacknight < michele@blacknight.com> wrote:
Agree with all previous comments ..
There’s no point trying to keep to an unreasonable timeline simply for the sake of it
-- 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 Random Stuff: http://www.michele.irish ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845
From: <gnso-ppsai-pdp-wg-bounces@icann.org> on behalf of Stephanie Perrin Date: Wednesday 15 July 2015 12:10 To: "gnso-ppsai-pdp-wg@icann.org" Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation
+1 to Volker and Phil and James B, as well as of course all others looking for more time. Let's take this seriously, folks. Some of us who are are on other WGs are also all stretched beyond capacity. I expect staff are as well. Stephanie P
On 2015-07-15 12:05, Volker Greimann wrote:
Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments.
This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw.
Best,
Volker
Am 15.07.2015 um 17:58 schrieb James M. Bladel:
While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process.
Thank you,
J. ____________ James Bladel GoDaddy
On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com> wrote:
+1.
Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate.
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com> wrote:
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy
---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it.
The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments.
Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright?
One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely.
Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need.
Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy
On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
*1. Use of Sub Teams for Specific Topics*:
- Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). - To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. - As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. - Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
*2. Full WG Review of Other Comments to Continue in Parallel*:
- Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
*3. Collated Information*:
- In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
_______________________________________________ Gnso-ppsai-pdp-wg mailing listGnso-ppsai-pdp-wg@icann.orghttps://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@key-systems.net
Web: www.key-systems.net / www.RRPproxy.netwww.domaindiscount24.com / www.BrandShelter.com
Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook:www.facebook.com/KeySystemswww.twitter.com/key_systems
Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534
Member of the KEYDRIVE GROUPwww.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@key-systems.net
Web: www.key-systems.net / www.RRPproxy.netwww.domaindiscount24.com / www.BrandShelter.com
Follow us on Twitter or join our fan community on Facebook and stay updated:www.facebook.com/KeySystemswww.twitter.com/key_systems
CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534
Member of the KEYDRIVE GROUPwww.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 listGnso-ppsai-pdp-wg@icann.orghttps://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
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-- 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@key-systems.net
Web: www.key-systems.net / www.RRPproxy.netwww.domaindiscount24.com / www.BrandShelter.com
Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook:www.facebook.com/KeySystemswww.twitter.com/key_systems
Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534
Member of the KEYDRIVE GROUPwww.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@key-systems.net
Web: www.key-systems.net / www.RRPproxy.netwww.domaindiscount24.com / www.BrandShelter.com
Follow us on Twitter or join our fan community on Facebook and stay updated:www.facebook.com/KeySystemswww.twitter.com/key_systems
CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534
Member of the KEYDRIVE GROUPwww.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 listGnso-ppsai-pdp-wg@icann.orghttps://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
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-- *Terri Stumme* *Intelligence Analyst*
If we can agree as a WG to the extended timeline I’ve proposed then I’m sure we can look at how we are going to categorize the various comments before we move into the analysis phase. -James From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Terri Stumme Sent: Wednesday, July 15, 2015 5:54 PM To: Michele Neylon - Blacknight Cc: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation I agree with the extended timeline. I would also like to propose that prior to establishing sub-teams that further effort be expended on a technical solution for sorting the public comments. Thus far, I've pulled out 453 comments that state (and I'm sure there are hundreds more): "Regarding the proposed rules governing companies that provide WHOIS privacyservices (as set forth in the Privacy and Policy Services AccreditationIssues Policy document): I urge you to respect internet users rights toprivacy and due process.Everyone deserves the right to privacy. No one's personal informationshould be revealed without a court order, regardless of whether the requestcomes from a private individual or law enforcement agency.Private information should be kept private. Thank you." I am sure that the NameCheap "canned" submissions will net thousands, also. Perhaps we need to step back and consider the time we could save in the end by expending a little more time up front by developing an automated process to sort through at least some of these comments. Thanks for consideration. On Wed, Jul 15, 2015 at 12:25 PM, Michele Neylon - Blacknight <michele@blacknight.com<mailto:michele@blacknight.com>> wrote: Agree with all previous comments .. There’s no point trying to keep to an unreasonable timeline simply for the sake of it -- 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<tel:%2B353%20%280%29%2059%20%C2%A09183072> Direct Dial: +353 (0)59 9183090<tel:%2B353%20%280%2959%209183090> Social: http://mneylon.social Random Stuff: http://www.michele.irish ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: <gnso-ppsai-pdp-wg-bounces@icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org>> on behalf of Stephanie Perrin Date: Wednesday 15 July 2015 12:10 To: "gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>" Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation +1 to Volker and Phil and James B, as well as of course all others looking for more time. Let's take this seriously, folks. Some of us who are are on other WGs are also all stretched beyond capacity. I expect staff are as well. Stephanie P On 2015-07-15 12:05, Volker Greimann wrote: Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments. This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw. Best, Volker Am 15.07.2015 um 17:58 schrieb James M. Bladel: While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process. Thank you, J. ____________ James Bladel GoDaddy On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com<mailto:carlton.samuels@gmail.com>> wrote: +1. Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799<tel:876-818-1799> Strategy, Planning, Governance, Assessment & Turnaround ============================= On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com<mailto:kathy@kathykleiman.com>> wrote: Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote: Hi all, considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively. That said, I volunteer for the first team. I support the sugestion to "collapse" yes and no responses. Best, Volker Am 15.07.2015 um 00:50 schrieb Mary Wong: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889<tel:%2B1%20603%20574%204889> Email: mary.wong@icann.org<mailto:mary.wong@icann.org> _______________________________________________ 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 -- 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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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@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@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@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@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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg -- Terri Stumme Intelligence Analyst
Just reread that and it may have come across wrong, for clarity – or any other reasonable timeline proposed by the chairs or other WG members. -James From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of James Gannon Sent: Wednesday, July 15, 2015 6:03 PM To: Terri Stumme; Michele Neylon - Blacknight Cc: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation If we can agree as a WG to the extended timeline I’ve proposed then I’m sure we can look at how we are going to categorize the various comments before we move into the analysis phase. -James 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 Terri Stumme Sent: Wednesday, July 15, 2015 5:54 PM To: Michele Neylon - Blacknight Cc: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation I agree with the extended timeline. I would also like to propose that prior to establishing sub-teams that further effort be expended on a technical solution for sorting the public comments. Thus far, I've pulled out 453 comments that state (and I'm sure there are hundreds more): "Regarding the proposed rules governing companies that provide WHOIS privacyservices (as set forth in the Privacy and Policy Services AccreditationIssues Policy document): I urge you to respect internet users rights toprivacy and due process.Everyone deserves the right to privacy. No one's personal informationshould be revealed without a court order, regardless of whether the requestcomes from a private individual or law enforcement agency.Private information should be kept private. Thank you." I am sure that the NameCheap "canned" submissions will net thousands, also. Perhaps we need to step back and consider the time we could save in the end by expending a little more time up front by developing an automated process to sort through at least some of these comments. Thanks for consideration. On Wed, Jul 15, 2015 at 12:25 PM, Michele Neylon - Blacknight <michele@blacknight.com<mailto:michele@blacknight.com>> wrote: Agree with all previous comments .. There’s no point trying to keep to an unreasonable timeline simply for the sake of it -- 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<tel:%2B353%20%280%29%2059%20%C2%A09183072> Direct Dial: +353 (0)59 9183090<tel:%2B353%20%280%2959%209183090> Social: http://mneylon.social Random Stuff: http://www.michele.irish ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845 From: <gnso-ppsai-pdp-wg-bounces@icann.org<mailto:gnso-ppsai-pdp-wg-bounces@icann.org>> on behalf of Stephanie Perrin Date: Wednesday 15 July 2015 12:10 To: "gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>" Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation +1 to Volker and Phil and James B, as well as of course all others looking for more time. Let's take this seriously, folks. Some of us who are are on other WGs are also all stretched beyond capacity. I expect staff are as well. Stephanie P On 2015-07-15 12:05, Volker Greimann wrote: Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments. This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw. Best, Volker Am 15.07.2015 um 17:58 schrieb James M. Bladel: While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process. Thank you, J. ____________ James Bladel GoDaddy On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com<mailto:carlton.samuels@gmail.com>> wrote: +1. Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799<tel:876-818-1799> Strategy, Planning, Governance, Assessment & Turnaround ============================= On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com<mailto:kathy@kathykleiman.com>> wrote: Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote: Hi all, considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively. That said, I volunteer for the first team. I support the sugestion to "collapse" yes and no responses. Best, Volker Am 15.07.2015 um 00:50 schrieb Mary Wong: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. Thanks and cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889<tel:%2B1%20603%20574%204889> Email: mary.wong@icann.org<mailto:mary.wong@icann.org> _______________________________________________ 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 -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. 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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@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@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@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@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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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<tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851<tel:%2B49%20%280%29%206894%20-%209396%20851> Email: vgreimann@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg -- Terri Stumme Intelligence Analyst
I echo the sentiments of many previous commenters we have to give the substance of the comments due attention. Extending the work plan seems absolutely necessary. I think we should approach automation of comment filtering cautiously to ensure we are not filtering out comments that may not necessarily speak to the WG¹s specific recommendations but still express opinions about P/P services and accreditation in general. I will volunteer for sub-team 3 re Annex E (if we keep the 3 sub-team concepts in Mary¹s original email). Thanks, Darcy From: <gnso-ppsai-pdp-wg-bounces@icann.org> on behalf of James Gannon <james@cyberinvasion.net> Date: Wednesday, July 15, 2015 at 10:06 AM To: James Gannon <james@cyberinvasion.net>, Terri Stumme <terri.stumme@legitscript.com>, Michele Neylon <michele@blacknight.com> Cc: "gnso-ppsai-pdp-wg@icann.org" <gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation Just reread that and it may have come across wrong, for clarity or any other reasonable timeline proposed by the chairs or other WG members. -James From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of James Gannon Sent: Wednesday, July 15, 2015 6:03 PM To: Terri Stumme; Michele Neylon - Blacknight Cc: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation If we can agree as a WG to the extended timeline I¹ve proposed then I¹m sure we can look at how we are going to categorize the various comments before we move into the analysis phase. -James From:gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Terri Stumme Sent: Wednesday, July 15, 2015 5:54 PM To: Michele Neylon - Blacknight Cc: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation I agree with the extended timeline. I would also like to propose that prior to establishing sub-teams that further effort be expended on a technical solution for sorting the public comments. Thus far, I've pulled out 453 comments that state (and I'm sure there are hundreds more): "Regarding the proposed rules governing companies that provide WHOIS privacyservices (as set forth in the Privacy and Policy Services AccreditationIssues Policy document): I urge you to respect internet users rights toprivacy and due process.Everyone deserves the right to privacy. No one's personal informationshould be revealed without a court order, regardless of whether the requestcomes from a private individual or law enforcement agency.Private information should be kept private. Thank you." I am sure that the NameCheap "canned" submissions will net thousands, also. Perhaps we need to step back and consider the time we could save in the end by expending a little more time up front by developing an automated process to sort through at least some of these comments. Thanks for consideration. On Wed, Jul 15, 2015 at 12:25 PM, Michele Neylon - Blacknight <michele@blacknight.com> wrote:
Agree with all previous comments ..
There¹s no point trying to keep to an unreasonable timeline simply for the sake of it
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From: <gnso-ppsai-pdp-wg-bounces@icann.org> on behalf of Stephanie Perrin Date: Wednesday 15 July 2015 12:10 To: "gnso-ppsai-pdp-wg@icann.org" Subject: Re: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation
+1 to Volker and Phil and James B, as well as of course all others looking for more time. Let's take this seriously, folks. Some of us who are are on other WGs are also all stretched beyond capacity. I expect staff are as well. Stephanie P
On 2015-07-15 12:05, Volker Greimann wrote:
Agreed. We should be extra careful to use this opportunity not just to look at the questions we asked, but put the entire first report to the test of the comments. If we did anything less, we would ignore the essence of the comments.
This includes the question of why an accreditation system is preferrable to any other method of achieving those goals, btw.
Best,
Volker
Am 15.07.2015 um 17:58 schrieb James M. Bladel:
While I agree with previous commenters, I'd like to point out that it isn't just the volume of comments received that will require more time to review, but rather the substantive "holes" or "gaps" identified during this process that we need to address. Whether these had come from thousands of comments or just a handful, I believe they will take more time to process.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 15, 2015, at 10:28, Carlton Samuels <carlton.samuels@gmail.com> wrote:
+1.
Kathy's arguments offered in favour of more time to usefully treat the comments are impatient of debate.
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 <tel:876-818-1799> Strategy, Planning, Governance, Assessment & Turnaround =============================
On Wed, Jul 15, 2015 at 10:20 AM, Kathy Kleiman <kathy@kathykleiman.com> wrote:
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy
-------------------------------------------------------------------------- -------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it.
The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments.
Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright?
One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely.
Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need.
Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy
On 7/15/2015 5:50 AM, Volker Greimann wrote:
Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong: > > Dear WG members, > > > > Following from the WG call earlier today, the co-chairs and staff after > some consultation would like to propose the following approach for your > consideration: > > > > 1. Use of Sub Teams for Specific Topics: > * Sub-teams comprising a few WG volunteers each can be formed to do the > initial review of public comments received on the three topics suggested > by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on > escalation of relay requests and the handling of disclosure/publication > requests from third parties other than IP rights holders); (2) Section > 1.3.3 (on the open question regarding online financial transactions); > and (3) Annex E (the Illustrative Disclosure Framework). > * To assist the WG evaluate the usefulness of sub teams, a sub team for > Section 1.3.2 can be formed first and serve as a ³test case² for the > exercise. > * As outlined on the call, a sub team will do a ³first pass² through a > template, based on the Public Comment Review Tool, that staff will > populate with all the input received on that particular issue. The sub > team will report back to the full WG in a timely fashion, including > suggesting a WG response and/or proposed action in relation to the > comments received. > * Sub teams may elect to do their work via email and online tools (e.g. > Google Docs or a wiki page), with or without supplemental conference > calls. Any calls will be recorded and transcribed for transparency > purposes, and drafts and other documents prepared using online tools > will also be made available to the full WG. (Do note, however, that > depending on call scheduling and timing, staff support may not be > available for all requested calls if several sub teams are used > concurrently.) > PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING > WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template > tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. > > > > 2. Full WG Review of Other Comments to Continue in Parallel: > * Staff will ³collapse² (per James¹ suggestion on the call) all those > template responses received that were simply a Yes or No answer to a > question, without any further comment added these will be reflected in > the Public Comment Review Tool accordingly, as a single collective > entry. The current Tool (covering Preliminary Recommendations 1 through > 9) will be updated in time for the WG to begin this review on the next > call. > > > 3. Collated Information: > * In addition to the updated spreadsheet just circulated by Graeme, we > can also send you archived mail files of the contributions received to > the public comment forum, should you or your group wish to conduct > searches through each comment yourselves. > > > We hope the above will be helpful in facilitating good progress on the > work to be done in preparation for the Final Report. > > > > Thanks and cheers > > Mary > > > > Mary Wong > > Senior Policy Director > > Internet Corporation for Assigned Names & Numbers (ICANN) > > Telephone: +1 603 574 4889 <tel:%2B1%20603%20574%204889> > > Email: mary.wong@icann.org > > > > > > > > > > > > > > > > > > > _______________________________________________ > Gnso-ppsai-pdp-wg mailing list > Gnso-ppsai-pdp-wg@icann.orghttps://mm.icann.org/mailman/listinfo/gnso-pp > sai-pdp-wg
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Mit freundlichen Grüßen,
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Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 <tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851 <tel:%2B49%20%280%29%206894%20-%209396%20851> Email: 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>
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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 <tel:%2B49%20%280%29%206894%20-%209396%20901> Fax.: +49 (0) 6894 - 9396 851 <tel:%2B49%20%280%29%206894%20-%209396%20851> Email: 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.
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-- Terri Stumme Intelligence Analyst _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
Building on comments so far from Kathy, Volker, Carlton, James G, James B, and others - even discounting the flat "no" comments that were generated in volume by a somewhat one-sided and incomplete description of the initial Report, and assuming that WG members can devote some decent amount of time between calls to their own reviews and/or sub-team work, and that we also adopt some of the efficiency tools that are being proposed -- the volume of comments that have some meaningful substance and should be at least considered is quite substantial. And then reaching consensus on some of the issues raised by them will be a further challenge. While personally committed to fully engaging I am dubious that all this can be accomplished in the three calls set out for it, even if they are lengthened to 90 or 120 minutes. Also, whether we view them as right or wrong, how this WG handles the very large volume of comments will be seen by many as a test of the MSM when it receives substantial input from groups and individuals who are not usually engaged in ICANN activities. Finally, as our work coincides with the still incomplete job of designing IANA transition and ICANN accountability measures, and given the statements already made by some senior staff, we should presume that the Board will be very wary of generating any new controversy and will not be embracing recommendations in the proposed final Report for which we cannot demonstrate both adequate process in considering input as well as substantial consensus among us. Adding all these considerations together, I believe that this WG should act as expeditiously as possible but in a manner that gives adequate time to fully considering and dealing with all substantive comments. While that may push a final Report past Dublin it also may substantially increase the prospects for adoption of a broader array of final recommendations. 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@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Kathy Kleiman Sent: Wednesday, July 15, 2015 11:20 AM To: gnso-ppsai-pdp-wg@icann.org Subject: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it. The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments. Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright? One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely. Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need. Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy On 7/15/2015 5:50 AM, Volker Greimann wrote: Hi all, considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively. That said, I volunteer for the first team. I support the sugestion to "collapse" yes and no responses. Best, Volker Am 15.07.2015 um 00:50 schrieb Mary Wong: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> _______________________________________________ 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 -- 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@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@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@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: 2015.0.5961 / Virus Database: 4365/10125 - Release Date: 06/29/15 Internal Virus Database is out of date.
Very well said, Phil. +1 Thanks. Amr Sent from mobile
On Jul 15, 2015, at 6:04 PM, Phil Corwin <psc@vlaw-dc.com> wrote:
Building on comments so far from Kathy, Volker, Carlton, James G, James B, and others – even discounting the flat “no” comments that were generated in volume by a somewhat one-sided and incomplete description of the initial Report, and assuming that WG members can devote some decent amount of time between calls to their own reviews and/or sub-team work, and that we also adopt some of the efficiency tools that are being proposed -- the volume of comments that have some meaningful substance and should be at least considered is quite substantial. And then reaching consensus on some of the issues raised by them will be a further challenge.
While personally committed to fully engaging I am dubious that all this can be accomplished in the three calls set out for it, even if they are lengthened to 90 or 120 minutes.
Also, whether we view them as right or wrong, how this WG handles the very large volume of comments will be seen by many as a test of the MSM when it receives substantial input from groups and individuals who are not usually engaged in ICANN activities.
Finally, as our work coincides with the still incomplete job of designing IANA transition and ICANN accountability measures, and given the statements already made by some senior staff, we should presume that the Board will be very wary of generating any new controversy and will not be embracing recommendations in the proposed final Report for which we cannot demonstrate both adequate process in considering input as well as substantial consensus among us.
Adding all these considerations together, I believe that this WG should act as expeditiously as possible but in a manner that gives adequate time to fully considering and dealing with all substantive comments. While that may push a final Report past Dublin it also may substantially increase the prospects for adoption of a broader array of final recommendations.
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@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Kathy Kleiman Sent: Wednesday, July 15, 2015 11:20 AM To: gnso-ppsai-pdp-wg@icann.org Subject: [Gnso-ppsai-pdp-wg] Fwd: Re: A proposed approach for reviewing public comments - reasonable time for review and evaluation
Hi All, I posted this email earlier today, but have not seen it pop up the list. Resending... Best, Kathy ---------------------------------------------------------------------------------------------------------------------------------------------------- All, I agree with the emails of Volker and James G. that we have to do a thorough review of the comments. I also agree with the expansion of the time frame to do it.
The last time we had such an outpouring of comments at ICANN that I can remember was the Closed Generic proceeding and comments to the Board. Dozens of comments flowed in from parties who do not traditionally participate in ICANN processes. The Board took the time to read, evaluate and respond to the comments.
Here too we must take the time to read, evaluate and respond to the comments. As Volker points out, the issues before us are not only the questions we issued, but the consensus we presented. Do others agree with our consensus? Do they support our direction? Would they push it more in one direction or another or reject it outright?
One thing I have seen in my skimming of the comments is a lot of discussion of Due Process. There appears to be a good amount of commentary on this issue, and one we will need to read and evaluate closely.
Over the year of our work we have talked often about the month of August. How it is a time that many in certain countries take long vacations; how emails to business addresses are often unanswered until the person returns to her/his desk. I think a rush on this in the dead of summer is a) unnecessary b) will not result in full staffing of the teams that we are setting up and c) will not give us the time for the evaluation, analysis and incorporation that we need.
Analysis, evaluation, incorporation -- this is a very important task for us now. Best, Kathy
On 7/15/2015 5:50 AM, Volker Greimann wrote: Hi all,
considering the outpouring of comments, we should not limit ourselves to these three topics but rather try to see how the comments affect the entire work so far. It does make sense to check the comments for these issues, but not exclusively.
That said, I volunteer for the first team.
I support the sugestion to "collapse" yes and no responses.
Best,
Volker
Am 15.07.2015 um 00:50 schrieb Mary Wong: Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
1. Use of Sub Teams for Specific Topics: Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
2. Full WG Review of Other Comments to Continue in Parallel: Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
3. Collated Information: In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
_______________________________________________ Gnso-ppsai-pdp-wg mailing list 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@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@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@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
No virus found in this message. Checked by AVG - www.avg.com Version: 2015.0.5961 / Virus Database: 4365/10125 - Release Date: 06/29/15 Internal Virus Database is out of date. _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
Hi Mary. Please sign me up for sub team 1.3.2 Alex On Jul 14, 2015, at 3:50 PM, Mary Wong <mary.wong@icann.org<mailto:mary.wong@icann.org>> wrote: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> _______________________________________________ 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
I can work where needed, but probably best to put me on 1.3.3. Thanks, Kiran Kiran Malancharuvil Policy Counselor MarkMonitor 415-419-9138 (m) Sent from my mobile, please excuse any typos. On Jul 15, 2015, at 4:42 PM, Deacon, Alex <Alex_Deacon@mpaa.org<mailto:Alex_Deacon@mpaa.org>> wrote: Hi Mary. Please sign me up for sub team 1.3.2 Alex On Jul 14, 2015, at 3:50 PM, Mary Wong <mary.wong@icann.org<mailto:mary.wong@icann.org>> wrote: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> _______________________________________________ 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 _______________________________________________ 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
If this is the initial structure then put me on #3. Thanks. Sent from my BlackBerry 10 smartphone. 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: Deacon, Alex Sent: Wednesday, July 15, 2015 7:41 PM To: Mary Wong Cc: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Hi Mary. Please sign me up for sub team 1.3.2 Alex On Jul 14, 2015, at 3:50 PM, Mary Wong <mary.wong@icann.org<mailto:mary.wong@icann.org>> wrote: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> _______________________________________________ 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 ________________________________ No virus found in this message. Checked by AVG - www.avg.com<http://www.avg.com> Version: 2015.0.5961 / Virus Database: 4365/10125 - Release Date: 06/29/15 Internal Virus Database is out of date.
I'm happy to join Phil on #3 Holly ----- Original Message ----- From: "Phil Corwin" To:"Deacon Alex" , "Mary Wong" Cc:"gnso-ppsai-pdp-wg@icann.org" Sent:Wed, 15 Jul 2015 23:45:59 +0000 Subject:Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments If this is the initial structure then put me on #3. Thanks. Sent from my BlackBerry 10 smartphone. 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: Deacon, Alex SENT: Wednesday, July 15, 2015 7:41 PM TO: Mary Wong CC: gnso-ppsai-pdp-wg@icann.org SUBJECT: Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Hi Mary. Please sign me up for sub team 1.3.2 Alex On Jul 14, 2015, at 3:50 PM, Mary Wong wrote: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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 [2] _______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg@icann.org [3] https://mm.icannorg/mailman/listinfo/gnso-ppsai-pdp-wg ------------------------- No virus found in this message. Checked by AVG - www.avg.com [4] Version: 2015.0.5961 / Virus Database: 4365/10125 - Release Date: 06/29/15 Internal Virus Database is out of date. Links: ------ [1] mailto:mary.wong@icann.org [2] mailto:mary.wong@icann.org [3] mailto:Gnso-ppsai-pdp-wg@icann.org [4] http://www.avg.com
I’d also like to join on #3 Annex E. Thanks. From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of h.raiche@internode.on.net Sent: Thursday, July 16, 2015 8:14 AM To: Phil Corwin; Deacon Alex; Mary Wong Cc: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewingpubliccomments I'm happy to join Phil on #3 Holly ----- Original Message ----- From: "Phil Corwin" <psc@vlaw-dc.com<mailto:psc@vlaw-dc.com>> To: "Deacon Alex" <Alex_Deacon@mpaa.org<mailto:Alex_Deacon@mpaa.org>>, "Mary Wong" <mary.wong@icann.org<mailto:mary.wong@icann.org>> Cc: "gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>" <gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org>> Sent: Wed, 15 Jul 2015 23:45:59 +0000 Subject: Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments If this is the initial structure then put me on #3. Thanks. Sent from my BlackBerry 10 smartphone. 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: Deacon, Alex Sent: Wednesday, July 15, 2015 7:41 PM To: Mary Wong Cc: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Hi Mary. Please sign me up for sub team 1.3.2 Alex On Jul 14, 2015, at 3:50 PM, Mary Wong <mary.wong@icann.org<mailto:mary.wong@icann.org>> wrote: Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework) * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> _______________________________________________ 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 ________________________________ No virus found in this message. Checked by AVG - www.avg.com<http://www.avg.com> Version: 2015.0.5961 / Virus Database: 4365/10125 - Release Date: 06/29/15 Internal Virus Database is out of date.
Hi Mary I agree we need an extended timeline. I am happy to volunteer for sub-team 1.3.2. Thanks Lindsay Lindsay Hamilton-Reid Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid@1and1.co.uk<mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk<http://www.fasthosts.co.uk/> www.1and1.co.uk<http://www.1and1.co.uk/> [fh-1and1] (c) 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. If you are not the intended recipient, you should not disclose, copy or use any part of it - please delete all copies immediately and notify 1&1 on 0844 335 1211 or Fasthosts on 0333 0142 700. Any statements, opinions or information in this message are provided by the author, not on behalf of 1&1 and/or Fasthosts, unless subsequently confirmed by an individual who is authorised to represent 1&1 and/or Fasthosts. From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org>
Hi Mary, I can also help on Section 1.3.2. Thanks! Val Valeriya Sherman<http://www.sgrlaw.com/attorneys/profiles/sherman-valeriya/> | Attorney at Law 202-973-2611 phone 202-263-4326 fax www.sgrlaw.com<http://www.sgrlaw.com> vsherman@sgrlaw.com<mailto:vsherman@sgrlaw.com> 1055 Thomas Jefferson Street, N.W. Suite 400 Washington, D.C. 20007 Ms. Sherman's practice is limited to matters before federal courts and before the United States Patent and Trademark Office. She is not admitted in the District of Columbia. [cid:image5f17f6.JPG@683e37b6.4d8fe76e]<http://www.sgrlaw.com> Smith, Gambrell & Russell, LLP From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Lindsay Hamilton-Reid Sent: Thursday, July 16, 2015 9:16 AM To: Mary Wong; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Hi Mary I agree we need an extended timeline. I am happy to volunteer for sub-team 1.3.2. Thanks Lindsay Lindsay Hamilton-Reid Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid@1and1.co.uk<mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk<http://www.fasthosts.co.uk/> www.1and1.co.uk<http://www.1and1.co.uk/> [fh-1and1] © 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. If you are not the intended recipient, you should not disclose, copy or use any part of it - please delete all copies immediately and notify 1&1 on 0844 335 1211 or Fasthosts on 0333 0142 700. Any statements, opinions or information in this message are provided by the author, not on behalf of 1&1 and/or Fasthosts, unless subsequently confirmed by an individual who is authorised to represent 1&1 and/or Fasthosts. 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy *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 *Mary Wong
*Sent:* 14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
------------------------------------------------------------------------ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.
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Hi Kathy: Yours - IMO - is in line with the proposal from James Gannon; first attempt categorization - the [Ironic: (Objective/Subjective)] and [NonIronic: Objective/Subjective] business via tech tools - then forming the sub teams to dig deeper. It makes good sense. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Thu, Jul 16, 2015 at 5:34 PM, Kathy Kleiman <kathy@kathykleiman.com> wrote:
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*From:* gnso-ppsai-pdp-wg-bounces@icann.org [ mailto:gnso-ppsai-pdp-wg-bounces@icann.org <gnso-ppsai-pdp-wg-bounces@icann.org>] *On Behalf Of *Mary Wong
*Sent:* 14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
*1. Use of Sub Teams for Specific Topics*:
- Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). - To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. - As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. - Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
*2. Full WG Review of Other Comments to Continue in Parallel*:
- Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
*3. Collated Information*:
- In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
------------------------------ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.
_______________________________________________ Gnso-ppsai-pdp-wg mailing listGnso-ppsai-pdp-wg@icann.orghttps://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
_______________________________________________ Gnso-ppsai-pdp-wg mailing list Gnso-ppsai-pdp-wg@icann.org https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. Steve From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg>
Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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
No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg> _______________________________________________ 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://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg>
Hi Steve, According to ICANN's Public Comment website, we did invite comment not only on our questions, but on our preliminary recommendations (please see language below). We also promised "analysis of all public comments received." ==> "The WG's preliminary recommendations cover all aspects of its Chartered questions, and include specific recommendations concerning "relay and "reveal". Some of these preliminary recommendations cover only certain aspects of a Charter topic, with the WG yet to reach consensus on the remaining aspects and open questions. In some instances, a preliminary recommendation or an open question may include bracketed language indicating alternative versions still under consideration by the WG and for which they would particularly welcome community input. ==> Following analysis of all public comments received, the WG will finalize its recommendations and prepare a Final Report for delivery to the GNSO Council, for its review and action." https://www.icann.org/public-comments/ppsai-initial-2015-05-05-en So yes, I think we have do have to deal with the concerns as voiced in these comments. If a lot of those concerns were about "due process" and the way we (the WG) handle "due process," that is going to be an issue we need to discuss.. What I fear you might have done below is to a) take an issue presented in many comments (hundreds? thousands?), analyze it and dismiss it. I think (with a sigh because it is a lot of work), we have to review it, analyze it and confront it -- whatever final decision we (the WG) choose to make. Best, Kathy On 7/17/2015 3:42 PM, Metalitz, Steven wrote:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
------------------------------------------------------------------------
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Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
------------------------------------------------------------------------
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-- 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@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@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.
Agreed Volker I would put my analysis in set A aswell. -James From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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.
Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of "The name and postal address of the Registered Name Holder." What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others. Even if abolishing 3.3.1.6 were a possibility and the DNS wasn't built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected - even if they have not contributed financially to the system by purchasing a domain name. I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance. Regards, Paul From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of James Gannon Sent: Monday, July 20, 2015 5:51 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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. 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.
Privacy or proxy services do not conflict with section 3.3.1.6 of the RAA (nor RA) as formally, the service provider is the RNH in a proxy form. Volker Am 20.07.2015 um 14:25 schrieb McGrady, Paul D.:
Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of “The name and postal address of the Registered Name Holder.” What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others.
Even if abolishing 3.3.1.6 were a possibility and the DNS wasn’t built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected – even if they have not contributed financially to the system by purchasing a domain name.
I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance.
Regards,
Paul
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *James Gannon *Sent:* Monday, July 20, 2015 5:51 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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-- 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@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@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.
Lets be clear here: if we accredit proxy providers, they are obliged to act if they have credible evidence (in the form of a warrant, notice of investigation, or other perfectly normal instrument of due process presented to them. Is that not correct? So can we walk through the case studies of the human traffickers, cyberbullies, and other nefarious types who have got away with hiding behind proxy services that will remain unreachable under our new accreditation process? I am having trouble imagining these situations, case studies would be very useful to assist our discussions. It was my understanding that ISPS are a fruitful avenue for these kinds of investigations....gives one much more data that the WHOIS. kind regards, Stephanie Perrin On 2015-07-20 8:25, McGrady, Paul D. wrote:
Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of “The name and postal address of the Registered Name Holder.” What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others.
Even if abolishing 3.3.1.6 were a possibility and the DNS wasn’t built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected – even if they have not contributed financially to the system by purchasing a domain name.
I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance.
Regards,
Paul
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *James Gannon *Sent:* Monday, July 20, 2015 5:51 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email:vgreimann@key-systems.net <mailto:vgreimann@key-systems.net>
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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@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>
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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.
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Hi Stephanie, actually, no accreditation is needed for that. Consensus policy binding on registrars requiring them to only knowingly accept registrations using privacy service providers that fulfill certain requirements is just as effective, and produces less cost, less bureaucratic hassle, less structural problems for ICANN, etc. Best, Volker Am 20.07.2015 um 19:16 schrieb Stephanie Perrin:
Lets be clear here: if we accredit proxy providers, they are obliged to act if they have credible evidence (in the form of a warrant, notice of investigation, or other perfectly normal instrument of due process presented to them. Is that not correct? So can we walk through the case studies of the human traffickers, cyberbullies, and other nefarious types who have got away with hiding behind proxy services that will remain unreachable under our new accreditation process? I am having trouble imagining these situations, case studies would be very useful to assist our discussions. It was my understanding that ISPS are a fruitful avenue for these kinds of investigations....gives one much more data that the WHOIS. kind regards, Stephanie Perrin
On 2015-07-20 8:25, McGrady, Paul D. wrote:
Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of “The name and postal address of the Registered Name Holder.” What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others.
Even if abolishing 3.3.1.6 were a possibility and the DNS wasn’t built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected – even if they have not contributed financially to the system by purchasing a domain name.
I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance.
Regards,
Paul
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *James Gannon *Sent:* Monday, July 20, 2015 5:51 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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-- 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@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@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.
That is great, and much easier as you point out! SP On 2015-07-20 13:23, Volker Greimann wrote:
Hi Stephanie,
actually, no accreditation is needed for that. Consensus policy binding on registrars requiring them to only knowingly accept registrations using privacy service providers that fulfill certain requirements is just as effective, and produces less cost, less bureaucratic hassle, less structural problems for ICANN, etc.
Best,
Volker
Am 20.07.2015 um 19:16 schrieb Stephanie Perrin:
Lets be clear here: if we accredit proxy providers, they are obliged to act if they have credible evidence (in the form of a warrant, notice of investigation, or other perfectly normal instrument of due process presented to them. Is that not correct? So can we walk through the case studies of the human traffickers, cyberbullies, and other nefarious types who have got away with hiding behind proxy services that will remain unreachable under our new accreditation process? I am having trouble imagining these situations, case studies would be very useful to assist our discussions. It was my understanding that ISPS are a fruitful avenue for these kinds of investigations....gives one much more data that the WHOIS. kind regards, Stephanie Perrin
On 2015-07-20 8:25, McGrady, Paul D. wrote:
Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of “The name and postal address of the Registered Name Holder.” What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others.
Even if abolishing 3.3.1.6 were a possibility and the DNS wasn’t built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected – even if they have not contributed financially to the system by purchasing a domain name.
I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance.
Regards,
Paul
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *James Gannon *Sent:* Monday, July 20, 2015 5:51 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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Hi Stephanie, Your post confused me. We were discussing Volker's newly proposed "litigation only" approach not accreditation along the lines that the Team has been discussing for months. Which paradigm were you meaning to invoke? Best, Paul From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Stephanie Perrin Sent: Monday, July 20, 2015 12:18 PM To: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Lets be clear here: if we accredit proxy providers, they are obliged to act if they have credible evidence (in the form of a warrant, notice of investigation, or other perfectly normal instrument of due process presented to them. Is that not correct? So can we walk through the case studies of the human traffickers, cyberbullies, and other nefarious types who have got away with hiding behind proxy services that will remain unreachable under our new accreditation process? I am having trouble imagining these situations, case studies would be very useful to assist our discussions. It was my understanding that ISPS are a fruitful avenue for these kinds of investigations....gives one much more data that the WHOIS. kind regards, Stephanie Perrin On 2015-07-20 8:25, McGrady, Paul D. wrote: Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of "The name and postal address of the Registered Name Holder." What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others. Even if abolishing 3.3.1.6 were a possibility and the DNS wasn't built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected - even if they have not contributed financially to the system by purchasing a domain name. I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance. Regards, Paul 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 James Gannon Sent: Monday, July 20, 2015 5:51 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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. 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. _______________________________________________ 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 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.
I am sorry for sowing confusion. Not sure what to call this new thread, but I guess it is not a revised approach to reviewing comments. I was responding to your "how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others." I was honestly just trying to walk through a case study of the situation you describe. SP On 2015-07-20 14:32, McGrady, Paul D. wrote:
Hi Stephanie,
Your post confused me. We were discussing Volker’s newly proposed “litigation only” approach not accreditation along the lines that the Team has been discussing for months. Which paradigm were you meaning to invoke?
Best,
Paul
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *Stephanie Perrin *Sent:* Monday, July 20, 2015 12:18 PM *To:* gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Lets be clear here: if we accredit proxy providers, they are obliged to act if they have credible evidence (in the form of a warrant, notice of investigation, or other perfectly normal instrument of due process presented to them. Is that not correct? So can we walk through the case studies of the human traffickers, cyberbullies, and other nefarious types who have got away with hiding behind proxy services that will remain unreachable under our new accreditation process? I am having trouble imagining these situations, case studies would be very useful to assist our discussions. It was my understanding that ISPS are a fruitful avenue for these kinds of investigations....gives one much more data that the WHOIS. kind regards, Stephanie Perrin
On 2015-07-20 8:25, McGrady, Paul D. wrote:
Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of “The name and postal address of the Registered Name Holder.” What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others.
Even if abolishing 3.3.1.6 were a possibility and the DNS wasn’t built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected – even if they have not contributed financially to the system by purchasing a domain name.
I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance.
Regards,
Paul
*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 *James Gannon *Sent:* Monday, July 20, 2015 5:51 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
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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@key-systems.net <mailto:vgreimann@key-systems.net>
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Follow us on Twitter or join our fan community on Facebook and stay updated:
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And by RA, I mean RAA. Thanks and sorry for the typo. From: McGrady, Paul D. Sent: Monday, July 20, 2015 7:24 AM To: 'James Gannon'; Volker Greimann; gnso-ppsai-pdp-wg@icann.org Subject: RE: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Thanks James. The ship has already sailed on option a). See 3.3.1.6 of the RA noting the mandatory requirement of the disclosure of "The name and postal address of the Registered Name Holder." What this team is discussing is how to develop an framework for exceptions to 3.3.1.6 that does not create a safe haven for human traffickers, cyber-bullies, and other nefarious types that would harm non-commercial users of the Internet. It is not within our remit to undo 3.3.1.6, no matter how many form comments are posted asking that we do so. Our remit is finding what circumstances warrant the exception through allowing WHOIS modification and which do not, the means to communicate to someone who is legitimately using such WHOIS modification services, and the terms upon which such allowable WHOIS modification will be terminated if it is being used to abuse others. Even if abolishing 3.3.1.6 were a possibility and the DNS wasn't built on a series of contracts (which it is), I see no particular upside to telling parents of children being bullied online, geriatric victims of banking scams, and targets of pay-in-advance credit offers that they have to wait months while their local court order requiring disclosure makes its way through the Hague Convention service process in order to be effectuated by a far-away privacy service. Although we have heard much about protecting the rights of non-commercial users of the Internet who happen to be domain name registrants as well and who are using P/P services (and we should be concerned about them), we also need to keep in mind the other non-commercial users of the Internet who will also be affected - even if they have not contributed financially to the system by purchasing a domain name. I for one hope we can get back on track and discuss the substantive, relevant comments and reach final consensus on the handful of outstanding issues and get a report in to the GNSO that reflects a sensible balance. Regards, Paul 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 James Gannon Sent: Monday, July 20, 2015 5:51 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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. 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.
Thanks James and Volker. I'm curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is "No one's personal information should be revealed without a court order." How is that not almost verbatim to (b)? From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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.
Interpretation of the comments by looking at the context. The comments should be viewed in the context of this PDP which deals with proposed changes to the way these services operate, as well as the report which proposes a more loose reveal requirements not requiring a court order. In fact, one of the proposals specifically calls for a reveal requirement that does not necessitate a court order. So clearly, the comments should be read as references to that. Volker Am 20.07.2015 um 14:55 schrieb Williams, Todd:
Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *James Gannon *Sent:* Monday, July 20, 2015 6:50 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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-- 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@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>
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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@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>
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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@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@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.
But the Initial Report also provides that: "Nothing in this document prevents a Service Provider from adopting and implementing policies to publish the contact details of Customers in Whois, or to terminate privacy and proxy service to a Customer, for breach of Service Provider's published Terms of Service, or on other grounds stated in the published Terms of Service, even if the criteria outlined in this document for a Request have not been met." (Initial Report at 85). Why would the comments not be read as references to that as well? From: Volker Greimann [mailto:vgreimann@key-systems.net] Sent: Monday, July 20, 2015 10:09 AM To: Williams, Todd; James Gannon; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Interpretation of the comments by looking at the context. The comments should be viewed in the context of this PDP which deals with proposed changes to the way these services operate, as well as the report which proposes a more loose reveal requirements not requiring a court order. In fact, one of the proposals specifically calls for a reveal requirement that does not necessitate a court order. So clearly, the comments should be read as references to that. Volker Am 20.07.2015 um 14:55 schrieb Williams, Todd: Thanks James and Volker. I'm curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is "No one's personal information should be revealed without a court order." How is that not almost verbatim to (b)? 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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. 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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.
They could probably read as such, but considering the legal risks that a provider faces as the public face of the RNH, such a proposal would have a severe impact on the exonomic and legal realities of existing services to an extent that I do not believe we would come to consensus on that interpretation. We can of course devote (part of) a session to discussing the comments in that context, of course. Volker Am 20.07.2015 um 16:16 schrieb Williams, Todd:
But the Initial Report also provides that:
“Nothing in this document prevents a Service Provider from adopting and implementing policies to publish the contact details of Customers in Whois, or to terminate privacy and proxy service to a Customer, for breach of Service Provider’s published Terms of Service, or on other grounds stated in the published Terms of Service, even if the criteria outlined in this document for a Request have not been met.”
(Initial Report at 85).
Why would the comments not be read as references to that as well?
*From:*Volker Greimann [mailto:vgreimann@key-systems.net] *Sent:* Monday, July 20, 2015 10:09 AM *To:* Williams, Todd; James Gannon; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Interpretation of the comments by looking at the context. The comments should be viewed in the context of this PDP which deals with proposed changes to the way these services operate, as well as the report which proposes a more loose reveal requirements not requiring a court order. In fact, one of the proposals specifically calls for a reveal requirement that does not necessitate a court order.
So clearly, the comments should be read as references to that.
Volker
Am 20.07.2015 um 14:55 schrieb Williams, Todd:
Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
*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 *James Gannon *Sent:* Monday, July 20, 2015 6:50 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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--
Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
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Key-Systems GmbH
Im Oberen Werk 1
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Geschäftsführer: Alexander Siffrin
Handelsregister Nr.: HR B 18835 - Saarbruecken
Umsatzsteuer ID.: DE211006534
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--------------------------------------------
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@key-systems.net <mailto:vgreimann@key-systems.net>
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Follow us on Twitter or join our fan community on Facebook and stay updated:
www.facebook.com/KeySystems <http://www.facebook.com/KeySystems>
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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@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@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@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@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.
Thanks Volker. I tend to agree with you on that. But I also think that's essentially what Steve said on Friday. Also, given that many providers' current Terms of Service allow for disclosure in response to trademark or copyright complaints, even absent a court order (see, e.g., www.1and1.com/TcPdr?__lf=Static<http://www.1and1.com/TcPdr?__lf=Static>, www.domain.com/legal/legal_domain.bml#domain-privacy-service<http://www.domain.com/legal/legal_domain.bml#domain-privacy-service>, www.domainit.com/terms.html<http://www.domainit.com/terms.html>, www.moniker.com/legal/registration-agreement<http://www.moniker.com/legal/registration-agreement>, www.name.com/policies/idp<http://www.name.com/policies/idp>, www.namecheap.com/legal/whoisguard/whoisguard-agreement.aspx<http://www.namecheap.com/legal/whoisguard/whoisguard-agreement.aspx>, www.web.com/legal/terms-of-service/domains.aspx<http://www.web.com/legal/terms-of-service/domains.aspx>), I think it's also true that removing III(D) from Annex E would likewise have a severe impact on the economic and legal realities of existing services to an extent that I do not believe we would come to consensus on that interpretation. From: Volker Greimann [mailto:vgreimann@key-systems.net] Sent: Monday, July 20, 2015 10:21 AM To: Williams, Todd; James Gannon; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments They could probably read as such, but considering the legal risks that a provider faces as the public face of the RNH, such a proposal would have a severe impact on the exonomic and legal realities of existing services to an extent that I do not believe we would come to consensus on that interpretation. We can of course devote (part of) a session to discussing the comments in that context, of course. Volker Am 20.07.2015 um 16:16 schrieb Williams, Todd: But the Initial Report also provides that: "Nothing in this document prevents a Service Provider from adopting and implementing policies to publish the contact details of Customers in Whois, or to terminate privacy and proxy service to a Customer, for breach of Service Provider's published Terms of Service, or on other grounds stated in the published Terms of Service, even if the criteria outlined in this document for a Request have not been met." (Initial Report at 85). Why would the comments not be read as references to that as well? From: Volker Greimann [mailto:vgreimann@key-systems.net] Sent: Monday, July 20, 2015 10:09 AM To: Williams, Todd; James Gannon; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Interpretation of the comments by looking at the context. The comments should be viewed in the context of this PDP which deals with proposed changes to the way these services operate, as well as the report which proposes a more loose reveal requirements not requiring a court order. In fact, one of the proposals specifically calls for a reveal requirement that does not necessitate a court order. So clearly, the comments should be read as references to that. Volker Am 20.07.2015 um 14:55 schrieb Williams, Todd: Thanks James and Volker. I'm curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is "No one's personal information should be revealed without a court order." How is that not almost verbatim to (b)? 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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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@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@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@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@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.
Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue. b) no disclosure should be allowed without a court order. Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin On 2015-07-20 8:55, Williams, Todd wrote:
Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *James Gannon *Sent:* Monday, July 20, 2015 6:50 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
Mit freundlichen Grüßen,
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Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email:vgreimann@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>
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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@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>
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Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that "no one's personal information should be revealed without a court order": 1) Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and 2) Because such a standard would not "fly" legally in some jurisdictions, as you've pointed out. Is that correct? From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Stephanie Perrin Sent: Monday, July 20, 2015 1:25 PM To: gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue. b) no disclosure should be allowed without a court order. Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin On 2015-07-20 8:55, Williams, Todd wrote: Thanks James and Volker. I'm curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is "No one's personal information should be revealed without a court order." How is that not almost verbatim to (b)? 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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP On 2015-07-20 16:01, Williams, Todd wrote:
Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that “no one’s personal information should be revealed without a court order”:
1)Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and
2)Because such a standard would not “fly” legally in some jurisdictions, as you’ve pointed out.
Is that correct?
*From:*gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] *On Behalf Of *Stephanie Perrin *Sent:* Monday, July 20, 2015 1:25 PM *To:* gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue.
b) no disclosure should be allowed without a court order.
Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin
On 2015-07-20 8:55, Williams, Todd wrote:
Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
*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 *James Gannon *Sent:* Monday, July 20, 2015 6:50 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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Stephanie, I think with the proper information presented to them, the public would have been more than capable of understanding options for exigency. Unfortunately I didn't see that explained to them on any of the websites which generated these comments. I don't think we can reasonably infer or read anything into the comments. How do we know what their preference is if we are questioning whether they understand or appreciate the very important section with allows registrars to use (adequate, sufficient, compelling) reasons to push back against disclosure, especially since so many of the situations cited in comments would absolutely warrant a refusal to disclose? I have thus far stayed out of this discussion, but frankly I'm not okay with discounting these people's opinion by stating they couldn't have possibly understood a part of the report so we'll just read in our desired conclusion. K Kiran Malancharuvil Policy Counselor MarkMonitor 415-419-9138 (m) Sent from my mobile, please excuse any typos. On Jul 20, 2015, at 9:04 PM, Stephanie Perrin <stephanie.perrin@mail.utoronto.ca<mailto:stephanie.perrin@mail.utoronto.ca>> wrote: I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP On 2015-07-20 16:01, Williams, Todd wrote: Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that “no one’s personal information should be revealed without a court order”: 1) Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and 2) Because such a standard would not “fly” legally in some jurisdictions, as you’ve pointed out. Is that correct? 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 Stephanie Perrin Sent: Monday, July 20, 2015 1:25 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue. b) no disclosure should be allowed without a court order. Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin On 2015-07-20 8:55, Williams, Todd wrote: Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)? 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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
Thanks Stephanie. I don't think we can re-interpret the comments to mean whatever we want them to mean. If they argued for a proposal for which we cannot reach consensus (either because the proposal won't fly legally, for the reasons that you pointed out, or because it won't fly economically, for the reasons that Volker pointed out), then I don't think it's our place to re-cast what they argued into something else, or try to divine their intent in order to "take their comments as an expression" of something else. I'm not even sure how we would do that. From: Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] Sent: Tuesday, July 21, 2015 12:03 AM To: Williams, Todd; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP On 2015-07-20 16:01, Williams, Todd wrote: Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that "no one's personal information should be revealed without a court order": 1) Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and 2) Because such a standard would not "fly" legally in some jurisdictions, as you've pointed out. Is that correct? 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 Stephanie Perrin Sent: Monday, July 20, 2015 1:25 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue. b) no disclosure should be allowed without a court order. Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin On 2015-07-20 8:55, Williams, Todd wrote: Thanks James and Volker. I'm curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is "No one's personal information should be revealed without a court order." How is that not almost verbatim to (b)? 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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
So are you suggesting throwing them out? Because they dont understand the complexity of what we are dealing with, and make a simple recommendation that appears to be based on US law? If this is the case, I respectfully suggest that this is dismissive of public comment, which is the central point of my remarks below. If on the other hand, we include the recommendation in our report, we could of course discuss the pros and cons. I believe that would be the fair thing to do. By the way, most of us are not law enforcement experts here, nor are we jurisdictional experts. So while I raised of couple of examples of why (2) was different and more problematic than (1), my goal was to explicate the ways they were different, not to disqualify the comments because they were not framed as a legal argument. SP, always with the caveat that I am not a lawyer. On 2015-07-21 8:15, Williams, Todd wrote:
Thanks Stephanie. I don’t think we can re-interpret the comments to mean whatever we want them to mean. If they argued for a proposal for which we cannot reach consensus (either because the proposal won’t fly legally, for the reasons that you pointed out, or because it won’t fly economically, for the reasons that Volker pointed out), then I don’t think it’s our place to re-cast what they argued into something else, or try to divine their intent in order to “take their comments as an expression” of something else. I’m not even sure how we would do that.
*From:*Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] *Sent:* Tuesday, July 21, 2015 12:03 AM *To:* Williams, Todd; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP
On 2015-07-20 16:01, Williams, Todd wrote:
Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that “no one’s personal information should be revealed without a court order”:
1)Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and
2)Because such a standard would not “fly” legally in some jurisdictions, as you’ve pointed out.
Is that correct?
*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 *Stephanie Perrin *Sent:* Monday, July 20, 2015 1:25 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue.
b) no disclosure should be allowed without a court order.
Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin
On 2015-07-20 8:55, Williams, Todd wrote:
Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
*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 *James Gannon *Sent:* Monday, July 20, 2015 6:50 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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No, that's not what I said. We should review and consider every comment. But as we do so, we can't change them to mean whatever we want them to mean. We have to take what they say at face value. In fact, I would argue that it's more "dismissive" to read a comment and say: Well, the comment says A, but the commenter probably doesn't "understand the complexity of what we are dealing with," so instead I'm going to assume the commenter meant B. From: Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] Sent: Tuesday, July 21, 2015 8:27 AM To: Williams, Todd; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments So are you suggesting throwing them out? Because they dont understand the complexity of what we are dealing with, and make a simple recommendation that appears to be based on US law? If this is the case, I respectfully suggest that this is dismissive of public comment, which is the central point of my remarks below. If on the other hand, we include the recommendation in our report, we could of course discuss the pros and cons. I believe that would be the fair thing to do. By the way, most of us are not law enforcement experts here, nor are we jurisdictional experts. So while I raised of couple of examples of why (2) was different and more problematic than (1), my goal was to explicate the ways they were different, not to disqualify the comments because they were not framed as a legal argument. SP, always with the caveat that I am not a lawyer. On 2015-07-21 8:15, Williams, Todd wrote: Thanks Stephanie. I don't think we can re-interpret the comments to mean whatever we want them to mean. If they argued for a proposal for which we cannot reach consensus (either because the proposal won't fly legally, for the reasons that you pointed out, or because it won't fly economically, for the reasons that Volker pointed out), then I don't think it's our place to re-cast what they argued into something else, or try to divine their intent in order to "take their comments as an expression" of something else. I'm not even sure how we would do that. From: Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] Sent: Tuesday, July 21, 2015 12:03 AM To: Williams, Todd; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP On 2015-07-20 16:01, Williams, Todd wrote: Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that "no one's personal information should be revealed without a court order": 1) Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and 2) Because such a standard would not "fly" legally in some jurisdictions, as you've pointed out. Is that correct? 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 Stephanie Perrin Sent: Monday, July 20, 2015 1:25 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue. b) no disclosure should be allowed without a court order. Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin On 2015-07-20 8:55, Williams, Todd wrote: Thanks James and Volker. I'm curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is "No one's personal information should be revealed without a court order." How is that not almost verbatim to (b)? 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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Agreed Volker I would put my analysis in set A aswell. -James 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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Steve, these comments can be read in different ways: a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order. I tend to interpret the comments as being in the a) column. Best, Volker Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report. The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we? Steve From: James M. Bladel [mailto:jbladel@godaddy.com] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Steve: With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments. Thank you, J. ____________ James Bladel GoDaddy On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don't think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made. Let's get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don't wish to join subteams, again, I agree it would be useful to identify (as you put it) the "major issues and concerns" that you find in the comments, with citations to those comments that you believe raise those major issues and concerns. 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 Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue. While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters? I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday. Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments. If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer. Best and tx, Kathy 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 Mary Wong Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org<mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments Dear WG members, Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration: 1. Use of Sub Teams for Specific Topics: * Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a "test case" for the exercise. * As outlined on the call, a sub team will do a "first pass" through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday. 2. Full WG Review of Other Comments to Continue in Parallel: * Staff will "collapse" (per James' suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added - these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call. 3. Collated Information: * In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves. We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report. 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<mailto:mary.wong@icann.org> ________________________________ Confidentiality Notice This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message. _______________________________________________ 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 _______________________________________________ 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 _______________________________________________ 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 -- 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@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@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@icann.org<mailto:Gnso-ppsai-pdp-wg@icann.org> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
I dont know how you interpret what I said to be, commenter says A, but clearly does not understand the issue, so he really means B. What I am trying to say (obviously ineffectively, and apologies to all english-as-second-language speakers who are having trouble following this thread) is: 1. Many people said they think release of their data should be only upon presentation of a court order, apparently 2. In fact, Court order procedures vary from state to state, and we do not explain that anywhere in the report. Nor do the website generators. 3. When we consider the comment, which appears to be a widely held view, we need to consider the reality of what a policy that reflected that would have to accommodate (i.e. jurisdictional and procedural variance. I do not believe that either twists the meaning of a public comment, introduces my own preferred option, or anything else. the goal is to further explicate what such a proposal would mean. A plus X, not A=B. I am going to quit this now, but feel free to comment. cheers Stephanie On 2015-07-21 8:37, Williams, Todd wrote:
No, that’s not what I said. We should review and consider every comment. But as we do so, we can’t change them to mean whatever we want them to mean. We have to take what they say at face value.
In fact, I would argue that it’s more “dismissive” to read a comment and say:
Well, the comment says A, but the commenter probably doesn’t “understand the complexity of what we are dealing with,” so instead I’m going to assume the commenter meant B.
*From:*Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] *Sent:* Tuesday, July 21, 2015 8:27 AM *To:* Williams, Todd; gnso-ppsai-pdp-wg@icann.org *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
So are you suggesting throwing them out? Because they dont understand the complexity of what we are dealing with, and make a simple recommendation that appears to be based on US law? If this is the case, I respectfully suggest that this is dismissive of public comment, which is the central point of my remarks below. If on the other hand, we include the recommendation in our report, we could of course discuss the pros and cons. I believe that would be the fair thing to do. By the way, most of us are not law enforcement experts here, nor are we jurisdictional experts. So while I raised of couple of examples of why (2) was different and more problematic than (1), my goal was to explicate the ways they were different, not to disqualify the comments because they were not framed as a legal argument. SP, always with the caveat that I am not a lawyer.
On 2015-07-21 8:15, Williams, Todd wrote:
Thanks Stephanie. I don’t think we can re-interpret the comments to mean whatever we want them to mean. If they argued for a proposal for which we cannot reach consensus (either because the proposal won’t fly legally, for the reasons that you pointed out, or because it won’t fly economically, for the reasons that Volker pointed out), then I don’t think it’s our place to re-cast what they argued into something else, or try to divine their intent in order to “take their comments as an expression” of something else. I’m not even sure how we would do that.
*From:*Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] *Sent:* Tuesday, July 21, 2015 12:03 AM *To:* Williams, Todd; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP
On 2015-07-20 16:01, Williams, Todd wrote:
Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that “no one’s personal information should be revealed without a court order”:
1)Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and
2)Because such a standard would not “fly” legally in some jurisdictions, as you’ve pointed out.
Is that correct?
*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 *Stephanie Perrin *Sent:* Monday, July 20, 2015 1:25 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue.
b) no disclosure should be allowed without a court order.
Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin
On 2015-07-20 8:55, Williams, Todd wrote:
Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
*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 *James Gannon *Sent:* Monday, July 20, 2015 6:50 AM *To:* Volker Greimann; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
*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 *Volker Greimann *Sent:* Monday, July 20, 2015 11:37 AM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven:
No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
*From:*James M. Bladel [mailto:jbladel@godaddy.com] *Sent:* Friday, July 17, 2015 3:35 PM *To:* Metalitz, Steven *Cc:* Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J.
____________
James Bladel
GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 *Kathy Kleiman *Sent:* Thursday, July 16, 2015 6:34 PM *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
*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 *Mary Wong
*Sent:*14 July 2015 23:50 *To:* gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> *Subject:* [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
_1. Use of Sub Teams for Specific Topics_:
* Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). * To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. * As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. * Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.)
*PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. *Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
_2. Full WG Review of Other Comments to Continue in Parallel_:
* Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
_3. Collated Information_:
* In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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Hi Todd, even so, we should take the comment into account in our deliberation and, if possible, make sure our proposals and recommendations use the overall comments as a basis, i.e. when deviating from what has been said, we should clarify why we deviated and how. In general, even if a 1:1 implementation is not possible, we can try to come as close as possible. Best, Volker
On 21 Jul 2015, at 14:15, Williams, Todd <Todd.Williams@turner.com> wrote:
Thanks Stephanie. I don’t think we can re-interpret the comments to mean whatever we want them to mean. If they argued for a proposal for which we cannot reach consensus (either because the proposal won’t fly legally, for the reasons that you pointed out, or because it won’t fly economically, for the reasons that Volker pointed out), then I don’t think it’s our place to re-cast what they argued into something else, or try to divine their intent in order to “take their comments as an expression” of something else. I’m not even sure how we would do that.
From: Stephanie Perrin [mailto:stephanie.perrin@mail.utoronto.ca] Sent: Tuesday, July 21, 2015 12:03 AM To: Williams, Todd; gnso-ppsai-pdp-wg@icann.org Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
I dont hold the public to the same standards as, for instance, legal counsel who are there to assist me in legislative drafting. So I don't expect all the people who wrote in to understand that while in principle we should demand court orders, there are options for exigency. Neither should we expect them to understand the powers of, for instance, the French intelligence agencies. So what I am saying is, we should take their comments as an expression of strong preference for only releasing with proper legal authority, Does that sound fair? I don't think we have a right to question the substantive value of a comment....we have a responsibility to ensure we recommend what is legal and practical and affordable and fair. Long and convoluted answer to what was a simple question....my apologies. cheers SP On 2015-07-20 16:01, Williams, Todd wrote: Thanks Stephanie. Assuming that what you outlined below is accurate, I think that means that you and Volker have now identified two good reasons for us to question the substantive value of any comment arguing that “no one’s personal information should be revealed without a court order”:
1) Because such a standard is not economically feasible for P/P Providers, as Volker has pointed out; and 2) Because such a standard would not “fly” legally in some jurisdictions, as you’ve pointed out.
Is that correct?
From: gnso-ppsai-pdp-wg-bounces@icann.org <mailto: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 Stephanie Perrin Sent: Monday, July 20, 2015 1:25 PM To: gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Forgive me please is someone has already dissected this text. Lot of ICANN traffic these days.... 1. a) ICANN should not implement policy that requires disclosure without a court order, or This means that ICANN should not develop a policy which requires a service provider to release information without a Court order....on a routine basis, the policy requires it. Seems clear enough. Violates national constitutional protections in some jurisdictions, I would argue.
b) no disclosure should be allowed without a court order.
Thiis on the other hand would require a policy that says, no disclosure may be made without a court order. First problem is that not all jurisdictions have court orders, some authorities (notably intelligence authorities) do not need a Court order for certain kinds of releases. This applies to many western democracies. In some jurisdictions, there are also urgency provisions, in the case of life and death etc. So this is an absolute prohibition against release without a Court order, which would not fly, for instance, in Canada. Last time I checked there were provisions in our privacy law to permit service providers to disclose info to the police voluntarily when they believed a crime was taking place....put there to facilitate the investigation of child pornography and copyright abuse. Stephanie Perrin On 2015-07-20 8:55, Williams, Todd wrote: Thanks James and Volker. I’m curious how you interpret the comments to get to (a) rather than (b). The language from many of the comments is “No one’s personal information should be revealed without a court order.” How is that not almost verbatim to (b)?
From: gnso-ppsai-pdp-wg-bounces@icann.org <mailto: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 James Gannon Sent: Monday, July 20, 2015 6:50 AM To: Volker Greimann; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Agreed Volker I would put my analysis in set A aswell.
-James
From: gnso-ppsai-pdp-wg-bounces@icann.org <mailto: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 Volker Greimann Sent: Monday, July 20, 2015 11:37 AM To: gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Steve,
these comments can be read in different ways:
a) ICANN should not implement policy that requires disclosure without a court order, or b) no disclosure should be allowed without a court order.
I tend to interpret the comments as being in the a) column.
Best,
Volker
Am 17.07.2015 um 21:42 schrieb Metalitz, Steven: No, James, we should certainly consider those concerns but not necessarily change the report.
The single concern raised more often than any other, I am positive, is that proxy services should not be permitted to disclose any information on their customer without a court order. That is not a standard that your service or any other that I know of can meet. We can change our report to make that a requirement for privacy/proxy service providers. Should we?
Steve
From: James M. Bladel [mailto:jbladel@godaddy.com <mailto:jbladel@godaddy.com>] Sent: Friday, July 17, 2015 3:35 PM To: Metalitz, Steven Cc: Kathy Kleiman; gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> Subject: Re: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Steve:
With respect, if several thousand commenters raised issues that concern them, but are not addressed by our report, the our focus should be on changing the report, not discounting the comments.
Thank you,
J. ____________ James Bladel GoDaddy
On Jul 17, 2015, at 21:20, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
I am all in favor of people identifying topics they believe need to be addressed by the WG. However, Kathy, I have to disagree with your premise, which is that the ten thousand plus comments reflect responses to our questions or even statements of agreement or disagreement to our consensus positions or report proposals. A much smaller (though still significant) number of comments do that, and those should be our top priority for review and response. But the vast majority of comments clearly are not responses to our report. These mass comments raise a very limited number of issues, which I don’t think we will that much difficulty dealing with once we have addressed the responses to our questions and the reasoned statements of agreement or disagreement with specific proposals we have made.
Let’s get started on the more substantive comments, starting with the questions we did pose. We have subteams forming to start to tackle that, and the staff (and Graeme!) are providing some tools to try to help facilitate that. For those who don’t wish to join subteams, again, I agree it would be useful to identify (as you put it) the “major issues and concerns” that you find in the comments, with citations to those comments that you believe raise those major issues and concerns.
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 <mailto:gnso-ppsai-pdp-wg-bounces@icann.org>] On Behalf Of Kathy Kleiman Sent: Thursday, July 16, 2015 6:34 PM To: gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A slightly revised proposed approach for reviewing public comments
Hi Don, Steve, Graeme, Mary and all WG members, I would like recommend that we take a slightly different approach. We received over ten thousand comments, many coming from those who do not ordinarily participate in the ICANN process. They wrote to us us not only in response to our specific questions, but also to share agreement (and disagreement) to our consensus positions/report proposals, and to explain why proxy/privacy registrations are important to them. There has been a huge outpouring particularly on the last issue.
While a few topics for cataloging these comments were presented on the call, with great respect, I do not think we have dealt with or cataloged all of the major issues and concerns raised by the comments yet. Before we leap forward to subteams and analysis, shouldn't we ask further, in writing, and with the whole of the WG participating -- have we gotten the topics right? Have we created sufficient topics to allow us to catalog the broad range of information, concerns and comments shared with us by so many commenters?
I would like to request that we be able to take big breath, and a slightly (only slightly!) different approach. In preparation for Tuesday's call, could we all skim the comments -- with our array of expertise, insight, knowledge of aspects of our commenter base -- to come up with topics that we think the WG should evaluate in tour review? Perhaps if we can circulate the topics online, and then discuss them on Tuesday.
Then we discuss how these topics/this substance might be overlaid on the subteam process laid out below and shared for the first time on last week's call. We will then have both substance and process! And we will know that we have considered all of the major issues arising from these important comments.
If we go forward now without this evaluation, I fear we may be missing much of what the comments have to offer.
Best and tx, Kathy
From: gnso-ppsai-pdp-wg-bounces@icann.org <mailto: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 Mary Wong
Sent: 14 July 2015 23:50 To: gnso-ppsai-pdp-wg@icann.org <mailto:gnso-ppsai-pdp-wg@icann.org> Subject: [Gnso-ppsai-pdp-wg] A proposed approach for reviewing public comments
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
1. Use of Sub Teams for Specific Topics: Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
2. Full WG Review of Other Comments to Continue in Parallel: Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
3. Collated Information: In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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 <mailto:mary.wong@icann.org>
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Happy to help on 1.3.2 initially, also would like to be on 1.3.3 David
On 15 Jul 2015, at 6:50 am, Mary Wong <mary.wong@icann.org> wrote:
Dear WG members,
Following from the WG call earlier today, the co-chairs and staff after some consultation would like to propose the following approach for your consideration:
1. Use of Sub Teams for Specific Topics: Sub-teams comprising a few WG volunteers each can be formed to do the initial review of public comments received on the three topics suggested by Steve on the call, i.e. (1) Section 1.3.2 of the Initial Report (on escalation of relay requests and the handling of disclosure/publication requests from third parties other than IP rights holders); (2) Section 1.3.3 (on the open question regarding online financial transactions); and (3) Annex E (the Illustrative Disclosure Framework). To assist the WG evaluate the usefulness of sub teams, a sub team for Section 1.3.2 can be formed first and serve as a “test case” for the exercise. As outlined on the call, a sub team will do a “first pass” through a template, based on the Public Comment Review Tool, that staff will populate with all the input received on that particular issue. The sub team will report back to the full WG in a timely fashion, including suggesting a WG response and/or proposed action in relation to the comments received. Sub teams may elect to do their work via email and online tools (e.g. Google Docs or a wiki page), with or without supplemental conference calls. Any calls will be recorded and transcribed for transparency purposes, and drafts and other documents prepared using online tools will also be made available to the full WG. (Do note, however, that depending on call scheduling and timing, staff support may not be available for all requested calls if several sub teams are used concurrently.) PLEASE VOLUNTEER FOR SUB TEAM 1.3.2 IF YOU ARE INTERESTED IN ASSISTING WITH THIS INITIAL REVIEW. Staff will endeavor to provide the template tool for 1.3.2 to the sub team as soon as possible, hopefully by Monday.
2. Full WG Review of Other Comments to Continue in Parallel: Staff will “collapse” (per James’ suggestion on the call) all those template responses received that were simply a Yes or No answer to a question, without any further comment added – these will be reflected in the Public Comment Review Tool accordingly, as a single collective entry. The current Tool (covering Preliminary Recommendations 1 through 9) will be updated in time for the WG to begin this review on the next call.
3. Collated Information: In addition to the updated spreadsheet just circulated by Graeme, we can also send you archived mail files of the contributions received to the public comment forum, should you or your group wish to conduct searches through each comment yourselves.
We hope the above will be helpful in facilitating good progress on the work to be done in preparation for the Final Report.
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
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participants (21)
-
Amr Elsadr -
Carlton Samuels -
Darcy Southwell -
David Cake -
Deacon, Alex -
h.raiche＠internode.on.net -
James Gannon -
James M. Bladel -
Kathy Kleiman -
Kiran Malancharuvil -
Lindsay Hamilton-Reid -
Mary Wong -
McGrady, Paul D. -
Metalitz, Steven -
Michele Neylon - Blacknight -
Phil Corwin -
Sherman, Valeriya -
Stephanie Perrin -
Terri Stumme -
Volker Greimann -
Williams, Todd