ICANN61 Prep Assignment
Drafting Team 4, Thanks again to those of you who prepped to provide an intro to DN Purchase/Sale during the past few WG calls. As those who were on today's call heard, we have decided to take a week to prep for ICANN61 by working on a specific assignment in drafting team mode. Our team's assignment is to reexamine our past output on DN Purchase/Sale: https://community.icann.org/download/attachments/74580010/DraftingTeam4-DNPu rchaseSale-Purpose-v9-clean.pdf to answer the following questions more explicitly and conceptually: 1. Who associated with the domain name registration needs to be identified and/or contacted for each purpose? 2. What is the objective achieved by identifying and/or contacting each of those entities? 3. What might be expected of that entity with regard to the domain name? To prep for ICANN61, it is imperative that we discuss these questions and produce output over the next week - ideally by 5 March but no later than 7 March. We know this is a tall order, give a short timeframe. However, the leadership believes that this will help us use our F2F time at ICANN61 more effectively, which I hope we all agree would be a terrific idea. To give us a head start, attached please find a first draft at answers, prepared by me from our past output, and raising a few potential gaps for discussion. To learn more about this assignment, please read these instructions: https://community.icann.org/download/attachments/79432608/Drafting%20Team%20 Assignment%2026%20Feb.pdf If you were unable to attend today's WG call, please catch up by reading or listening to the call recording/notes/transcript: https://community.icann.org/x/oAu8B To get started, please ask any questions you may have about this assignment within the next 24 hours. If you have any suggested edits or additions or deletions to the attached first draft, even better! I encourage you to share them in reply to this message, copying the DT mailing list gnso-rds-pdp-4@icann.org Thanks for doing what you can to help this drafting team come through on this new assignment. Best, Lisa
Hi Lisa, Thank you for writing the first draft! I read through and only have one minor suggestion. On the following line, I would suggest adding that both the buyer and the seller expect communication to be reliably relayed.
In the case of relayed communication, the buyer **and seller** expect communication to be reliably relayed by the Privacy/Proxy to the authentic entity who has legal rights to sell the domain name.
Regarding the final question, I believe the answer is yes. One the seller initiates the transfer, the registrar should complete the translate process post-acquisition. Curious to hear others' thoughts too! Best, Erica Erica Varlese | .blog Shepherd @ KKWT Email: erica@my.blog Skype: evarlese On Tue, Feb 27, 2018 at 4:44 PM, Lisa Phifer <lisa@corecom.com> wrote:
Drafting Team 4,
Thanks again to those of you who prepped to provide an intro to DN Purchase/Sale during the past few WG calls.
As those who were on today’s call heard, we have decided to take a week to prep for ICANN61 by working on a specific assignment in drafting team mode.
Our team’s assignment is to reexamine our past output on DN Purchase/Sale:
https://community.icann.org/download/attachments/74580010/ DraftingTeam4-DNPurchaseSale-Purpose-v9-clean.pdf
to answer the following questions more explicitly and conceptually:
1. Who associated with the domain name registration needs to be identified and/or contacted for each purpose? 2. What is the objective achieved by identifying and/or contacting each of those entities? 3. What might be expected of that entity with regard to the domain name?
*To prep for ICANN61, it is imperative that we discuss these questions and produce output over the next week – ideally by 5 March but no later than 7 March.*
We know this is a tall order, give a short timeframe. However, the leadership believes that this will help us use our F2F time at ICANN61 more effectively, which I hope we all agree would be a terrific idea.
To give us a head start, attached please find a first draft at answers, prepared by me from our past output, and raising a few potential gaps for discussion.
To learn more about this assignment, please read these instructions:
https://community.icann.org/download/attachments/79432608/ Drafting%20Team%20Assignment%2026%20Feb.pdf
If you were unable to attend today’s WG call, please catch up by reading or listening to the call recording/notes/transcript:
https://community.icann.org/x/oAu8B
*To get started, please ask any questions you may have about this assignment within the next 24 hours.*
If you have any suggested edits or additions or deletions to the attached first draft, even better! I encourage you to share them in reply to this message, copying the DT mailing list gnso-rds-pdp-4@icann.org
Thanks for doing what you can to help this drafting team come through on this new assignment.
Best, Lisa
_______________________________________________ Gnso-rds-pdp-4 mailing list Gnso-rds-pdp-4@icann.org https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-4
Thanks very much Erica – Does anyone have any suggested text for why the registrars need to be identified or contacted (and by whom), the expectations of the registrars, etc? We may also want to add something about the benefit to both buyer and seller – a point raised on yesterday’s WG call but after I took my first cut at that draft. Best, Lisa From: Erica Varlese [mailto:erica@my.blog] Sent: Wednesday, February 28, 2018 5:53 AM To: Lisa Phifer Cc: gnso-rds-pdp-4@icann.org Subject: Re: [Gnso-rds-pdp-4] ICANN61 Prep Assignment Hi Lisa, Thank you for writing the first draft! I read through and only have one minor suggestion. On the following line, I would suggest adding that both the buyer and the seller expect communication to be reliably relayed.
In the case of relayed communication, the buyer **and seller** expect communication to be reliably relayed by the Privacy/Proxy to the authentic entity who has legal rights to sell the domain name.
Regarding the final question, I believe the answer is yes. One the seller initiates the transfer, the registrar should complete the translate process post-acquisition. Curious to hear others' thoughts too! Best, Erica Erica Varlese | .blog Shepherd @ KKWT Email: erica@my.blog Skype: evarlese On Tue, Feb 27, 2018 at 4:44 PM, Lisa Phifer <lisa@corecom.com> wrote: Drafting Team 4, Thanks again to those of you who prepped to provide an intro to DN Purchase/Sale during the past few WG calls. As those who were on today’s call heard, we have decided to take a week to prep for ICANN61 by working on a specific assignment in drafting team mode. Our team’s assignment is to reexamine our past output on DN Purchase/Sale: https://community.icann.org/download/attachments/74580010/DraftingTeam4-DNPu... to answer the following questions more explicitly and conceptually: 1. Who associated with the domain name registration needs to be identified and/or contacted for each purpose? 2. What is the objective achieved by identifying and/or contacting each of those entities? 3. What might be expected of that entity with regard to the domain name? To prep for ICANN61, it is imperative that we discuss these questions and produce output over the next week – ideally by 5 March but no later than 7 March. We know this is a tall order, give a short timeframe. However, the leadership believes that this will help us use our F2F time at ICANN61 more effectively, which I hope we all agree would be a terrific idea. To give us a head start, attached please find a first draft at answers, prepared by me from our past output, and raising a few potential gaps for discussion. To learn more about this assignment, please read these instructions: https://community.icann.org/download/attachments/79432608/Drafting%20Team%20... If you were unable to attend today’s WG call, please catch up by reading or listening to the call recording/notes/transcript: https://community.icann.org/x/oAu8B To get started, please ask any questions you may have about this assignment within the next 24 hours. If you have any suggested edits or additions or deletions to the attached first draft, even better! I encourage you to share them in reply to this message, copying the DT mailing list gnso-rds-pdp-4@icann.org Thanks for doing what you can to help this drafting team come through on this new assignment. Best, Lisa _______________________________________________ Gnso-rds-pdp-4 mailing list Gnso-rds-pdp-4@icann.org https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-4
Thanks, Lisa. My additional thoughts in redline in the attached. From: Gnso-rds-pdp-4 [mailto:gnso-rds-pdp-4-bounces@icann.org] On Behalf Of Lisa Phifer Sent: Sunday, March 04, 2018 7:21 PM To: gnso-rds-pdp-4@icann.org Subject: [Gnso-rds-pdp-4] Please review attached v2 answers Importance: High DT4, Attached is an updated draft of answers to questions we have been asked to answer no later than 7 March for discussion at ICANN61. In this draft, I have applied the changes suggested by Erica below. Does anyone have any further edits to the attached draft - especially to address the questions raised below? Please supply any edits by COB Monday 5 March. Also, will any of you be on the 6 March WG call to provide a status update on behalf of this drafting team? Best, Lisa At 07:15 AM 2/28/2018, Lisa Phifer wrote: Thanks very much Erica – Does anyone have any suggested text for why the registrars need to be identified or contacted (and by whom), the expectations of the registrars, etc? We may also want to add something about the benefit to both buyer and seller – a point raised on yesterday’s WG call but after I took my first cut at that draft. Best, Lisa From: Erica Varlese [mailto:erica@my.blog ] Sent: Wednesday, February 28, 2018 5:53 AM To: Lisa Phifer Cc: gnso-rds-pdp-4@icann.org<mailto:gnso-rds-pdp-4@icann.org> Subject: Re: [Gnso-rds-pdp-4] ICANN61 Prep Assignment Hi Lisa, Thank you for writing the first draft! I read through and only have one minor suggestion. On the following line, I would suggest adding that both the buyer and the seller expect communication to be reliably relayed.
In the case of relayed communication, the buyer **and seller** expect communication to be reliably relayed by the Privacy/Proxy to the authentic entity who has legal rights to sell the domain name.
Regarding the final question, I believe the answer is yes. One the seller initiates the transfer, the registrar should complete the translate process post-acquisition. Curious to hear others' thoughts too! Best, Erica Erica Varlese | .blog Shepherd @ KKWT Email: erica@my.blog<mailto:erica@my.blog> Skype: evarlese On Tue, Feb 27, 2018 at 4:44 PM, Lisa Phifer <lisa@corecom.com<mailto:lisa@corecom.com>> wrote: Drafting Team 4, Thanks again to those of you who prepped to provide an intro to DN Purchase/Sale during the past few WG calls. As those who were on today’s call heard, we have decided to take a week to prep for ICANN61 by working on a specific assignment in drafting team mode. Our team’s assignment is to reexamine our past output on DN Purchase/Sale: https://community.icann.org/download/attachments/74580010/DraftingTeam4-DNPurchaseSale-Purpose-v9-clean.pdf<https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_74580010_DraftingTeam4-2DDNPurchaseSale-2DPurpose-2Dv9-2Dclean.pdf&d=DwMFAw&c=XRWvQHnpdBDRh-yzrHjqLpXuHNC_9nanQc6pPG_SpT0&r=6lUxzkhJPN5qts-Nve5TYqxoGjP81z1kCvXgsmw-MiQ&m=wC3naFaZFya8Pmujv_86Kx2YB4IoWzC5SaS7nP6NtEY&s=dzc1PE9ZmQOfYCG9eXu1RWlQo_sCoKAflY6w-gH55q0&e=> to answer the following questions more explicitly and conceptually: 1. Who associated with the domain name registration needs to be identified and/or contacted for each purpose? 2. What is the objective achieved by identifying and/or contacting each of those entities? 3. What might be expected of that entity with regard to the domain name? To prep for ICANN61, it is imperative that we discuss these questions and produce output over the next week – ideally by 5 March but no later than 7 March. We know this is a tall order, give a short timeframe. However, the leadership believes that this will help us use our F2F time at ICANN61 more effectively, which I hope we all agree would be a terrific idea. To give us a head start, attached please find a first draft at answers, prepared by me from our past output, and raising a few potential gaps for discussion. To learn more about this assignment, please read these instructions: https://community.icann.org/download/attachments/79432608/Drafting%20Team%20Assignment%2026%20Feb.pdf<https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_79432608_Drafting-2520Team-2520Assignment-252026-2520Feb.pdf&d=DwMFAw&c=XRWvQHnpdBDRh-yzrHjqLpXuHNC_9nanQc6pPG_SpT0&r=6lUxzkhJPN5qts-Nve5TYqxoGjP81z1kCvXgsmw-MiQ&m=wC3naFaZFya8Pmujv_86Kx2YB4IoWzC5SaS7nP6NtEY&s=mJSgmhJ_q8RZYs7XRteeFD3xEOfXbvufDda_0D71iMs&e=> If you were unable to attend today’s WG call, please catch up by reading or listening to the call recording/notes/transcript: https://community.icann.org/x/oAu8B<https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_x_oAu8B&d=DwMFAw&c=XRWvQHnpdBDRh-yzrHjqLpXuHNC_9nanQc6pPG_SpT0&r=6lUxzkhJPN5qts-Nve5TYqxoGjP81z1kCvXgsmw-MiQ&m=wC3naFaZFya8Pmujv_86Kx2YB4IoWzC5SaS7nP6NtEY&s=Z9L6XcZdpoO0miLuX90Zfy8fpZzBfkCUcPnU67y7RIs&e=> To get started, please ask any questions you may have about this assignment within the next 24 hours. If you have any suggested edits or additions or deletions to the attached first draft, even better! I encourage you to share them in reply to this message, copying the DT mailing list gnso-rds-pdp-4@icann.org<mailto:gnso-rds-pdp-4@icann.org> Thanks for doing what you can to help this drafting team come through on this new assignment. Best, Lisa _______________________________________________ Gnso-rds-pdp-4 mailing list Gnso-rds-pdp-4@icann.org<mailto:Gnso-rds-pdp-4@icann.org> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-4<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gnso-2Drds-2Dpdp-2D4&d=DwMFAw&c=XRWvQHnpdBDRh-yzrHjqLpXuHNC_9nanQc6pPG_SpT0&r=6lUxzkhJPN5qts-Nve5TYqxoGjP81z1kCvXgsmw-MiQ&m=wC3naFaZFya8Pmujv_86Kx2YB4IoWzC5SaS7nP6NtEY&s=g_ZjcloOLdjYRW9zkRQc2wacwy90yr0v13wq9iWh7C0&e=> _______________________________________________ Gnso-rds-pdp-4 mailing list Gnso-rds-pdp-4@icann.org<mailto:Gnso-rds-pdp-4@icann.org> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-4<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gnso-2Drds-2Dpdp-2D4&d=DwMFAw&c=XRWvQHnpdBDRh-yzrHjqLpXuHNC_9nanQc6pPG_SpT0&r=6lUxzkhJPN5qts-Nve5TYqxoGjP81z1kCvXgsmw-MiQ&m=wC3naFaZFya8Pmujv_86Kx2YB4IoWzC5SaS7nP6NtEY&s=g_ZjcloOLdjYRW9zkRQc2wacwy90yr0v13wq9iWh7C0&e=> ________________________________ NOTICE: This communication may contain privileged or other confidential information. If you have received it in error, please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents. Thank you.
I must be a little dense here.I don’t understand why these two points don’t simple go without saying. If I buy Privacy/Proxy service, it should do what it is supposed to. It hides me but reliably relays communications when it is contacted. I also expect a registrar to do with it is contracted to do in terms of transfer services for domain name holders. /(I expect some blockchain supported techniques to pop up here/.). Sam L. On 3/4/2018 7:21 PM, Lisa Phifer wrote:
DT4,
Attached is an updated draft of answers to questions we have been asked to answer no later than 7 March for discussion at ICANN61. In this draft, I have applied the changes suggested by Erica below. Does anyone have any further edits to the attached draft - especially to address the questions raised below? *Please supply any edits by COB Monday 5 March. **Also, will any of you be on the 6 March WG call to provide a status update on behalf of this drafting team? *Best, Lisa
At 07:15 AM 2/28/2018, Lisa Phifer wrote:
Thanks very much Erica – Does anyone have any suggested text for why the registrars need to be identified or contacted (and by whom), the expectations of the registrars, etc? We may also want to add something about the benefit to both buyer and seller – a point raised on yesterday’s WG call but after I took my first cut at that draft. Best, Lisa
*From:* Erica Varlese [mailto:erica@my.blog ] *Sent:* Wednesday, February 28, 2018 5:53 AM *To:* Lisa Phifer *Cc:* gnso-rds-pdp-4@icann.org *Subject:* Re: [Gnso-rds-pdp-4] ICANN61 Prep Assignment
Hi Lisa, Thank you for writing the first draft! I read through and only have one minor suggestion. On the following line, I would suggest adding that both the buyer and the seller expect communication to be reliably relayed.
In the case of relayed communication, the buyer **and seller** expect communication to be reliably relayed by the Privacy/Proxy to the authentic entity who has legal rights to sell the domain name. Regarding the final question, I believe the answer is yes. One the seller initiates the transfer, the registrar should complete the translate process post-acquisition. Curious to hear others' thoughts too! Best, Erica
------------------------------------------------ "It is a disgrace to be rich and honoured in an unjust state" -Confucius 邦有道,贫且贱焉,耻也。邦无道,富且贵焉,耻也 ------------------------------------------------ Visiting Prof, Xi'an Jaiotong-Liverpool Univ, Suzhou, China Dr Sam Lanfranco (Prof Emeritus & Senior Scholar) Econ, York U., Toronto, Ontario, CANADA - M3J 1P3 email: sam@lanfranco.net Skype: slanfranco blog: https://samlanfranco.blogspot.com Phone: +1 613-476-0429 cell: +1 416-816-2852
Lisa, Here, since there are contracts, a bit more specific wording could say something about the rights and duties of the registrar and the domain name holder as detailed i the contract. (I like "domain name owner" but there are those who do not like "owner" so I guess something like "legal domain name holder" might be better wording. We should on occasion use some of the legal clauses, depending on the context, where they say things like "if not included, it is excluded" or "if not excluded, it is included". This is better than long lists of what is, or is not, included. Sam On 3/5/2018 3:42 PM, Lisa Phifer wrote:
Hi Sam, good point.
How about we add a footnote indicating that such expectations are detailed in the services agreement between the buyer/seller and the PP provider or registrar?
Best, Lisa
At 10:54 AM 3/5/2018, Sam Lanfranco wrote:
I must be a little dense here. I don’t understand why these two points don’t simple go without saying. If I buy Privacy/Proxy service, it should do what it is supposed to. It hides me but reliably relays communications when it is contacted. I also expect a registrar to do with it is contracted to do in terms of transfer services for domain name holders. /(I expect some blockchain supported techniques to pop up here/.).
Sam L. On 3/4/2018 7:21 PM, Lisa Phifer wrote:
DT4,
Attached is an updated draft of answers to questions we have been asked to answer no later than 7 March for discussion at ICANN61. In this draft, I have applied the changes suggested by Erica below. Does anyone have any further edits to the attached draft - especially to address the questions raised below? *Please supply any edits by COB Monday 5 March. **Also, will any of you be on the 6 March WG call to provide a status update on behalf of this drafting team? *Best, Lisa
At 07:15 AM 2/28/2018, Lisa Phifer wrote:
Thanks very much Erica – Does anyone have any suggested text for why the registrars need to be identified or contacted (and by whom), the expectations of the registrars, etc? We may also want to add something about the benefit to both buyer and seller – a point raised on yesterday’s WG call but after I r I took my first cut at that draft. Best, Lisa   *From:* Erica Varlese [mailto:erica@my.blog ] *Sent:* Wednesday, February 28, 2018 5:53 AM *To:* Lisa Phifer *Cc:* gnso-rds-pdp-4@icann.org <mailto:gnso-rds-pdp-4@icann.org> *Subject:* Re: [Gnso-rds-pdp-4] ICANN61 Prep Assignment  Hi Lisa, Thank you for writing the first draft! I read through and only have one minor suggestion. On the following line, I would suggest adding that both the buyer and the seller expect communication to be reliably relayed.
In the case of relayed communication, the buyer **and seller** expect communication to be reliably relayed by the Privacy/Proxy to the authentic entity who has legal rights to sell the domain name. Regarding the final question, I believe the answer is yes. One the seller initiates the transfer, the registrar should complete the translate process post-acquisition. Curious to hear others' thoughts too! Â Best, Erica
------------------------------------------------ "It is a disgrace to be rich and honoured in an unjust state" -Confucius 邦有é“ï¼Œè´«ä¸”è´±ç„‰ï¼Œè€»ä¹Ÿã€‚é‚¦æ— é“,富且贵焉,耻也 ------------------------------------------------ Visiting Prof, Xi'an Jaiotong-Liverpool Univ, Suzhou, China Dr Sam Lanfranco (Prof Emeritus & Senior Scholar) Econ, York U., Toronto, Ontario, CANADA - M3J 1P3 email: sam@lanfranco.net <mailto:sam@lanfranco.net> Skype: slanfranco blog: https://samlanfranco.blogspot.com Phone: +1 613-476-0429 cell: +1 416-816-2852
-- ------------------------------------------------ "It is a disgrace to be rich and honoured in an unjust state" -Confucius 邦有道,贫且贱焉,耻也。邦无道,富且贵焉,耻也 ------------------------------------------------ Visiting Prof, Xi'an Jaiotong-Liverpool Univ, Suzhou, China Dr Sam Lanfranco (Prof Emeritus & Senior Scholar) Econ, York U., Toronto, Ontario, CANADA - M3J 1P3 email: sam@lanfranco.net Skype: slanfranco blog: https://samlanfranco.blogspot.com Phone: +1 613-476-0429 cell: +1 416-816-2852
A couple of last minute comments:
"If an escrow agent is involved, they are expected to verify the transfer to buyer before releasing funds."
There are often other steps, contractual requirements and so on not just when using escrow, what about changing that to * Additional steps, checks, processes and procedures may need to take place depending on the terms of the purchase/sale - this is commonly but not only when additional parties such as escrow are involved. After the purpose/definition should we include some notes like: * note that Registrant may choose not to be contacted/contactable and is under no obligation to be contactable or to reply to such solicitations * note that Unsolicited Commercial Email may be considered SPAM and may be illegal in some jurisdictions * note that repeated "offers to buy" can be construed as harrasment and are illegal in some jurisdictions
From 2 ...
"To complete a domain name acquisition, buyers need to identify the old and new Registrant to verify that the domain name change in ownership has been accurately recorded."
I'm not entirely sure, as the completion doesn't need or care about the old details, and the buyer can verify the new details with their registrar, but I understand what it's trying to say and cant currently write anything I prefer. IRTP-C has made this more difficult when not using a "platform" as the requirement for both old-and-new registrants to verify their details leaves problems where seller doesn't complete the process (which is part of why the WG proposals did not say what has become the policy) Personally I think the 3rdparty/registrant may be back-to-front (as the 3rd party is the initiator) ... I've reworded it and reversed it ... I realise this is "late" and apologise to the team, and fully understand if there's not time to discuss [ in which case I'm good with the current phraseology ] but my attempt is: Purpose Summary: Information to enable contact between a third-party (buyer) and a registrant, which may form part of a registrant proving/exercising property interest in a domain name and may assist third-party buyer in confirming the registrant's property interest and/or related merchantability. Definition: This purpose enables contact between third-party buyers and domain name registrants (e.g., small business owners, corporations, and domain name brokers) for unsolicited domain name purchase queries, and for both parties to complete and confirm agreed domain name transfers from seller to buyer. RE:
Does anyone have any suggested text for why the registrars need to be identified or contacted (and by whom), the expectations of the registrars, etc?
Having bought (and sold) a number of domains, the only instances I can recall where Registrar has been of particular interest are * to have domains "pushed" to an account I already have with them pending my choice as to whether to transfer out or not. * to reduce the offer price if certain registrars are involved due to "issues" with some of their T&Cs * as a due-dilligence check of current/recent exploits/hacks/etc which might indicate the domains ownership is in question RE:
In the case of relayed communication, the buyer **and seller** expect communication to be reliably relayed by the Privacy/Proxy to the authentic entity who has legal rights to sell the domain name.
Remembering that (a) email isn't always considered reliable and (b) the privacy/proxy service is generally one-way and not involved in the return communications Rob --- This email has been checked for viruses by Avast antivirus software. https://www.avast.com/antivirus
I will keep this short, one line, like a crow cawing in the distance. /I would not be surprised if somebody like the EU, or an aggressive Registrar, introduces the use of// // a distributed ledger (e.g. blockchain) to reduce the complications in domain name transfers./ Sam L. On 3/6/2018 10:29 PM, Rob Golding wrote:
A couple of last minute comments:
"If an escrow agent is involved, they are expected to verify the transfer to buyer before releasing funds."
There are often other steps, contractual requirements and so on not just when using escrow, what about changing that to
* Additional steps, checks, processes and procedures may need to take place depending on the terms of the purchase/sale - this is commonly but not only when additional parties such as escrow are involved.
<rest deleted>
participants (5)
-
Erica Varlese -
Lisa Phifer -
Rob Golding -
Sam Lanfranco -
Vayra, Fabricio (Perkins Coie)