April 2018 - GNSO-RPM-WG - lists.icann.org

Recordings, Attendance, & Webex Chat for Review of all Rights Protection Mechanisms (RPMs) PDP Working Group call on Wednesday, 18 April 2018
by Andrea Glandon April 18, 2018

April 18, 2018

Dear all, Please find the attendance and Webex Chat transcript attached to this email, and the MP3 recording below for the Review of all Rights Protection Mechanisms (RPMs) PDP Working Group call held Wednesday, 18 April 2018 at 17:00 UTC. Attendance and recordings of the call is posted on agenda wiki page: https://community.icann.org/x/5AMFBQ MP3: https://audio.icann.org/gnso/gnso-rpm-review-18apr18-en.mp3<https://urldefense.proofpoint.com/v2/url?u=http-3A__emails.samanage.com_wf_…> The recordings and transcriptions of the calls are posted on the GNSO Master Calendar page: https://gnso.icann.org/en/group-activities/calendar ** Please let me know if your name has been left off the list ** Mailing list archives: http://mm.icann.org/pipermail/gnso-rpm-wg/ Main wiki page for the working group: https://community.icann.org/x/wCWAAw Kind Regards, Andrea Glandon

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Re: [gnso-rpm-wg] Proposed agenda for RPM Working Group call on 18 April 2018 at 1700 UTC
by Ariel Liang April 18, 2018

April 18, 2018

[Message sent on behalf of the RPM PDP WG Co-Chairs] Dear WG members: Please find attached documents generated by the Sub Teams on Practitioners, and on Providers. There is a short description of each document below. These documents will be the presented by the Sub Team Chairs and serve as the main focus of our discussion on tomorrow’s WG call (Wed, 18 April at 17:00-18:30 UTC), with an aim to approving final versions expeditiously so that they can be sent out and responded to as soon as possible. Providers Sub Team: 1. Consolidated Questions to URS Providers 2. Responses to Propose Questions to URS Providers: -- The document includes responses already received from Providers during ICANN61 presentation and follow-up emails, as well as responses provided by staff research per Sub Team requests; -- Questions partially responded by Providers are also included in the document to show why these questions are directed to specific Provider(s) Practitioners Sub Team: URS Practitioner Background Experience and Perspective Considerable work has gone into these documents and we thank the Sub Teams for their time, effort and care. As Co-Chairs, we urge that edits be proposed with great care, as balances were carefully considered by the Sub Teams. A separate URS Documents Sub Team Summary Report being edited by Brian Beckham will be provided shortly. Time-allowing, we will consider this Summary Report tomorrow, otherwise, on 4/25. Best to all, Philip & Kathy From: gnso-rpm-wg <gnso-rpm-wg-bounces(a)icann.org> on behalf of Julie Hedlund <julie.hedlund(a)icann.org> Date: Friday, April 13, 2018 at 2:20 PM To: "gnso-rpm-wg(a)icann.org" <gnso-rpm-wg(a)icann.org> Subject: [gnso-rpm-wg] Proposed agenda for RPM Working Group call on 18 April 2018 at 1700 UTC Dear RPM PDP WG members, Here is the proposed agenda for the Working Group call Wednesday, 18 April 2018, scheduled for 1700 UTC: Proposed Agenda: 1. Roll call (via WebEx and phone bridge only); updates to Statements of Interest 2. Status reports - with specific recommendations for next steps and timeline - from the three URS Sub Teams (Documents, Practitioners, Providers) 3. Discussion/agreement on next steps for the three URS Sub Teams in view of the current Phase One timeline 4. Notice of agenda for 25 April meeting Best regards, Mary, Julie, Ariel and Berry

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Proposed agenda for RPM Working Group call on 18 April 2018 at 1700 UTC
by Julie Hedlund April 13, 2018

April 13, 2018

Dear RPM PDP WG members, Here is the proposed agenda for the Working Group call Wednesday, 18 April 2018, scheduled for 1700 UTC: Proposed Agenda: Roll call (via WebEx and phone bridge only); updates to Statements of Interest Status reports - with specific recommendations for next steps and timeline - from the three URS Sub Teams (Documents, Practitioners, Providers) Discussion/agreement on next steps for the three URS Sub Teams in view of the current Phase One timeline Notice of agenda for 25 April meeting Best regards, Mary, Julie, Ariel and Berry

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Proposed new time for 4th rotational Working Group call
by Mary Wong April 7, 2018

April 7, 2018

Dear Working Group members, Following the poll that was conducted and feedback from several members, including Europe-based members, the Working Group co-chairs requested that staff reach out to our active APAC-based members to solicit their input on the poll options of Wednesday 2200 UTC and Wednesday 2300 UTC, as well as a possible additional option of Wednesday or Thursday at 1200 UTC. Based on all the feedback received, and taking into account what we know in terms of the geographical locations of Working Group members, the co-chairs and staff would like to propose that, with effect from Wednesday 25 April, the 4th rotational (generally, end of month) call for our Working Group take place at 1200 UTC. We realize that this may inconvenience members who are based on the west coast of North America, but there does not seem to be a time that will work for all members in all regions. As with all call times, this can be reviewed periodically based on attendance and further feedback. For your information, 1200 UTC is 5 a.m. US Pacific / 8 a.m. US Eastern / 1 p.m. London / 2 p.m. Frankfurt / 8 p.m. Singapore, Perth, Hong Kong / 9 p.m. Tokyo. Please refer to this resource for additional times and to convert time zones: https://www.timeanddate.com/. Finally, and on a related point, staff anticipates that (subject to the co-chairs’ discretion and the progress of the three URS Sub Teams) the next Working Group call will take place on Wednesday 18 April at the usual non-rotational time of 1700 UTC. Please look out for the applicable calendar invitations next week. Thanks and cheers Mary, Julie, Ariel & Berry

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Response from the Co-Chairs RE: Proposal to Shift URS review to Phase II
by Corwin, Philip April 6, 2018

April 6, 2018

Dear John: Thank you for your submission regarding a variety of proposed changes to this Working Group's Charter. Our understanding from discussions with staff is that, while there is no set requirement for the level of support within a WG required to request that GNSO Council consider a Charter revision, such revisions are relatively rare and have in the past been supported by a substantial majority of WG members in the absence of significant opposition prior to transmission to Council for its consideration. We therefore strongly encourage all WG members to carefully review your proposal and, regardless of whether one supports or opposes it, to provide some feedback to the full WG email list so that we can begin to gauge overall support. Such email discussion can be preliminary to a full WG oral discussion on a call sometime in late April or early May, if there are indications of substantial support within the WG and a desire to engage in further discussion. The full WG will resume its regular Wednesday calls by mid-April (we anticipate April 18), after the URS Documents, Practitioners and Providers sub-teams have completed their current work. We also note that your proposal raises multiple issues, including: * Amendment of the WG Charter to move the URS review and recommendations to Phase II * Amendment of the WG Charter to define issues that must, may, and may not be addressed * Adjustment of the WG Charter to provide additional guidance on the scope of URS and UDRP Review * Adjustment of the WG leadership structure for Phase II * Potential pause in the start of Phase II keyed to GDPR impact understanding These are all major issues and we encourage WG members to comment on all of them. Finally, regardless of whether there is substantial support within the WG for any of the elements of your proposal, we agree that the impending enforcement of GDPR raises substantial WHOIS data access issues for trademark owners and for URS and UDRP dispute resolution providers. The issues for trademark owners are currently being discussed within the full ICANN community regarding interim and final compliance models, the latter involving accreditation and tiered data access. In regard to the ability of URS and UDRP providers to continue to have access to the data elements necessary to fulfill their dispute resolution provider (DRP) roles, it is our intent to prepare a draft letter to ICANN's CEO noting that such continued access for DRPs is essential to maintaining these non-judicial alternatives for addressing trademark infringement in the DNS, and requesting that ICANN raise this important matter in its continuing discussions with EU Data Protection Authorities. We will work with staff to prepare this draft letter and then share it with WG members for review and comment, after which we will coordinate with Council Leadership and the WG Liaison regarding transmission of a final text to ICANN management. Best regards, Philip & Kathy Philip S. Corwin Policy Counsel VeriSign, Inc. 12061 Bluemont Way Reston, VA 20190 703-948-4648/Direct 571-342-7489/Cell "Luck is the residue of design" -- Branch Rickey From: gnso-rpm-wg [mailto:gnso-rpm-wg-bounces@icann.org] On Behalf Of John McElwaine Sent: Thursday, April 05, 2018 9:55 PM To: gnso-rpm-wg <gnso-rpm-wg(a)icann.org> Subject: [EXTERNAL] [gnso-rpm-wg] Proposal to Shift URS review to Phase II Dear RPM Working Group: In our meeting in San Juan, Puerto Rico, I raised the issue of moving the work set forth in this Working Group's charter relating to the URS to Phase II. The Chairs asked that I put something in writing detailing the specific recommendation and reasoning, which I present below and have also attached hereto in a Word document for your review and consideration. Kind regards, John Proposal to Shift URS from Phase I to Phase II: 1. On 15 December 2011, the GNSO Council requested that eighteen (18) months after the launch of the New gTLD Program ICANN staff prepare and publish an Issue Report on the state of all rights protection mechanisms implemented for both existing and new gTLDs, including but not limited to the UDRP and URS. The Council subsequently agreed to extend the timeline for a report by a further six (6) months. 2. On 9 October 2015, a Preliminary Issues Report was published discussing the scope of this potential PDP and outlining three possible options for moving forward. The third option ultimately was elected at that time: The "third option would be to conduct a policy review of all the RPMs in two phases, with the initial phase being a review only of the RPMs developed for the New gTLD Program. . . . The second, subsequent phase of work would be a review of the UDRP, based on the concerns specific to its scope that were raised in the 2011 GNSO Issue Report and any additional relevant topics derived from the first phase of work concerning the RPMs developed for the New gTLD Program." 3. On 15 March 2016, the two phase approach was approved in the Charter for the Review of all Rights Protection Mechanisms (RPMs) in all gTLDs PDP Working Group ("RPM Working Group"). Phase One was to focus on a review of all the RPMs that were developed for the New gTLD Program, and Phase Two will focus on a review of the UDRP. 4. The Objective & Goals in the PDP's Charter were to examine (i) the RPMs effectiveness, (ii) whether the RPMs collectively fulfil their purposes, and (iii) whether additional policy specific recommendations are needed, including to clarify and unify the policy goals. RPM Working Group Charter, at p. 3. The Objectives & Goals in the PDP's Charter were broadly defined: "In addition to an assessment of the effectiveness of each RPM, the PDP Working Group is expected to consider, at the appropriate stage of its work, the overarching issue as to whether or not all the RPMs collectively fulfill the purposes for which they were created, or whether additional policy recommendations are needed, including to clarify and unify the policy goals. If such additional policy recommendations are needed, the Working Group is expected to develop recommendations to address the specific issues identified. The Working Group is also directed to bear in mind that a fundamental underlying intention of conducting a review of all RPMs in all gTLDs is to create a framework for consistent and uniform reviews of these mechanisms in the future." 5. However, the RPM Working Group Charter also contains a lengthy attachment entitled "LIST OF POTENTIAL ISSUES FOR CONSIDERATION IN THIS PDP" This "list was derived from various community suggestions in different forums, they are not listed in any particular order of importance nor has staff attempted to analyze the merits, relevance or significance of each issue". This list contains topics that are out of scope when compared with the Objectives and Goals, including: 1. Are generic dictionary words being adequately protected so that they are available for all to use as allowed under their national laws and international treaties? E.g. sun, window 2. Should monetary damages be awarded? 3. Are last names and geographic places adequately protected so that they are available for all to use as allowed under their national laws, e.g, Smith, McDonald, Capitol Hill Cafe, Old Town Deli? 4. Should injunctive relief be available? 5. Now that Reverse Domain Name Hijacking is a regular finding of UDRP panels, indicating that domain name registrants are being abused by complaints brought against them in the UDRP process, what penalties and sanctions should be imposed on Complainants found to be reverse domain name hijackers? How can those penalties and sanctions be aligned so as to be fair, as compared to the loss of a domain name taken from a registrant found to be a "cybersquatter"? 6. Issues from this list and other new out of scope issues, complaints and modifications are causing the work of the RPM Working Group to slow and are polarizing the members; thus, harming the ability to achieve consensus in the Working Group. As recommend by the PDP breakout group and discussed by the Community in attendance at the Sunday gNSO Working Session in San Juan, it would be particularly useful if working group charters would: 1. Define clearly what success for the proposed working group "should look like". (K. Kleiman reporting on breakout session, Transcript ICANN61 San Juan GNSO Working Session Part 2 Sunday, 11 March 2018 at 10:30 AS ("Transcript") at p. 5). 2. Define topics or issues that must be addressed, may be addressed and may not be addressed. (Transcript at p. 4). 3. Have "more defined issues, [be] more bounded, more limited." (Transcript at p. 5). 4. Have a narrower scope and be broken up into separate projects. (Transcript at p. 5). 5. Having a charter drafting team that "that are experts, and that might mean a legal expert, but we should also have people that have experience, practical experience." (S. DelBianco reporting on breakout session, Transcript at p. 5). 7. The Trademark Clearinghouse, Sunrise and Trademark Claims Notices are RPMs relating to the registration process of domain names in the new gTLDs. The URS is more akin to the UDRP, and like the UDRP is a mandatory dispute resolution proceeding to recover a domain name that has been clearly registered in bad faith. Since the URS is intended to be complementary of the UDRP and will have similar issues it would be more efficient to address these RPMs in a more cohesive manner. 8. With respect to the URS and UDRP, The European Parliament, the Council of the European Union, and the European Commission have enacted a new data privacy regulation in 2016 entitled the General Data Protection Regulation (GDPR) that will likely adversely impact the ability of the URS and UDRP to function as these policies are currently implemented. The new regulation is scheduled to take effect on May 25, 2018. Among other ways, GDRP may adversely impact the URS and the UDRP by: 1. Procedure for UDRP/URS: 1. Possibility that Providers cannot serve the UDRP/URS Complaint if an email address cannot be obtained. 2. Possibility that the Language of the URS proceeding cannot be determined. 2. Procedure for URS: 1. Possibility that the URS provider cannot translate the notice of URS complaint into the predominant language used in the Registrant's country or territory. 2. Possibility that URS complainants cannot know the language of a possible response. 3. Possibility that URS complainants do not know whether the URS complaint was translated into the correct language(s) and that proceedings were administered correctly. 3. UDRP Element 2 / URS: 1. Cannot argue that the registrant is not commonly known by the Domain Name at issue. 2. Cannot determine if the registrant has been authorized by the Trademark holder. 3. Cannot determine if the registrant is an authorized reseller of the Trademark holder's product. 4. Cannot determine on what date the domain name was "registered" by the current domain name holder if it was transferred to this current domain name holder. (requires being able to see the WhoIs history). This could prevent baseless claims from being filed. 4. UDRP Element 3: 1. Cannot determine if registrant has engaged in a pattern of bad faith registrations. Rule 4(b)(ii). 2. Cannot determine if registrant has been found to engage other unlawful actions, such as malware, phishing or scams. 3. Cannot determine if the registrant is in a particular geographic region to be better assess the possibility of legitimate co-existence (thus possibly even foregoing the filing of a case, and response, in the first place). 4. Cannot determine if the registrant is technically a "competitor" that has registered the Domain Name for the purpose of disrupting the business of the Complainant. Rule 4(b)(iii). 9. Due to GDPR compliance issues, ICANN org is considering substantial changes to WhoIs, and has published an Interim Model for GDPR Compliance, e.g. "The CookBook" which proposes to significantly limit the public display of WhoIs data after May 25, 2018." see: https://www.icann.org/en/system/files/files/gdpr-compliance-interim-model-0…. Aggressive current timelines for tiered access to WhoIs data that might provide some fix for the above issues is December 2018. There is no question that GDPR will require policy consideration relating to the URS and UDRP that cannot be predicted and analyzed at this time. Recommendation: 1. The RPM Working Group finishes its already well-advanced work and issues an Initial Report on the PDDRP, Trademark Clearinghouse, Sunrise, and Trademark Claims Notices for public comment. 2. After comments have been analyzed for those elements, that the RPM Working Group finishes its work and issues its Final Report on the PDDRP, Trademark Clearinghouse, Sunrise, and Trademark Claims Notices. 3. The RPM Working Group issues a request through its Appointed Working Group Liaison to the GNSO Council to amend the RPM Working Group Charter as follows: 1. shift the work related to the URS to Phase II and, if necessary, pause starting Phase II until after the permanent impacts of GDPR on the URS and UDRP are known; 2. provide clear guidance to the WG on the issues that (i) must be addressed, (ii) may be addressed, and (iii) may not be addressed; 3. provide clear guidance on the scope of the review of the URS and UDRP. Although a separate issue from this proposal, it is also recommended that Phase II Working Group has one chairperson with appropriate neutrality and experience in PDP consensus building and parliamentary procedures. Assistance to the chair can be provided by utilizing vice-chairs and well-structured sub-teams. <http://www.nelsonmullins.com/img/ecard-logo.png> JOHN C. MCELWAINE PARTNER john.mcelwaine(a)nelsonmullins.com<mailto:john.mcelwaine@nelsonmullins.com> LIBERTY CENTER | SUITE 600 151 MEETING STREET | CHARLESTON, SC 29401 T 843.534.4302 F 843.722.8700 101 CONSTITUTION AVENUE, NW | SUITE 900 WASHINGTON, D.C., 20001 T 202.689.2939 F 202.689.2862 NELSONMULLINS.COM<http://www.nelsonmullins.com> VCARD<http://www.nelsonmullins.com/people/john-mcelwaine/vcard> VIEW BIO<http://www.nelsonmullins.com/people/john-mcelwaine> Confidentiality Notice This message is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged, 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 either by phone (800-237-2000) or reply to this e-mail and delete all copies of this message.

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Recall: RPM March 15 session - questions from George Kirikos
by Michael Graham (ELCA) April 4, 2018

April 4, 2018

Michael Graham (ELCA) would like to recall the message, "[gnso-rpm-wg] RPM March 15 session - questions from George Kirikos".

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RPM March 15 session - questions from George Kirikos
by George Kirikos April 4, 2018

April 4, 2018

[with the Adobe Connect down, it seems remote participants can only ask questions via email] For NAF: According to: [A] https://fedsoc.org/commentary/publications/national-arbitration-forum-settl… "On July 20, 2009, Minnesota Attorney General Lori Swanson announced that the country’s largest arbitrator of credit-card and consumer-collection disputes would no longer handle consumer arbitrations. The National Arbitration Forum’s decision to end its consumer-arbitration business resulted from a settlement it reached with the State of Minnesota less than a week after Attorney General Swanson sued the company in Ramsey County, Minnesota, accusing the company of violating Minnesota’s consumer-fraud, deceptive-trade-practices, and false-advertising statutes." [B] https://www.creditcards.com/credit-card-news/minnesota-attorney-general-law… "The lawsuit claims the NAF, the largest arbitration company in the United States, violates state consumer fraud and deceptive trade laws by hiding its financial ties to collection agencies and credit card companies. The lawsuit also claims the company violates false advertising laws by misrepresenting themselves as a neutral organization. " My questions are: (for NAF) (1) In light of [A], how do NAF's business practices in handling domain name disputes differ from those in the consumer-arbitration business which it left, and how can domain name registrants be confident that the same abuses which were alleged in consumer arbitrations are not present in its domain name dispute business? (2) In light of [B], who are the beneficial owners of NAF, and do they have any times to the trademark industry, law firms, or anyone else that might affect its neutrality? In other words, what is the "Statement of Interest" (SOI) for NAF itself as an organization? Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ P.S. Further background info at: https://library.nclc.org/sites/default/files/Arb10_Appx_O-1.pdf https://www.citizen.org/sites/default/files/arbitrationtrap.pdf https://en.wikipedia.org/wiki/Forum_(alternative_dispute_resolution)

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FW: [Gnso-next-gen-rds-lead] FW: URGENT REQUEST - Community Input re Accreditation Model Draft
by Terri Agnew April 2, 2018

April 2, 2018

FYI From: Brian Winterfeldt <Brian(a)Winterfeldt.law <mailto:Brian@Winterfeldt.law> > Date: Monday, April 2, 2018 at 15:07 To: "so-ac-sg-cleaders(a)icann.org <mailto:so-ac-sg-cleaders@icann.org> " <so-ac-sg-cleaders(a)icann.org <mailto:so-ac-sg-cleaders@icann.org> > Cc: "internet(a)winterfeldt.law <mailto:internet@winterfeldt.law> " <internet(a)winterfeldt.law <mailto:internet@winterfeldt.law> > Subject: RE: URGENT REQUEST - Community Input re Accreditation Model Draft Dear ICANN Community Leadership Colleagues: I write to follow up on my prior communication below to provide you with a formal invitation from the IPC and the BC to participate in a community-wide discussion regarding the proposed accreditation and access model for non-public WHOIS data, which was first circulated to the community during ICANN 61. The discussion will take place via ICANN-supported remote participation and/or audio bridge this Friday April 6, 2018 from 1400-1600 UTC. Please find the formal invitation attached with the pertinent participation details. Please distribute the invitation to your respective stakeholders and encourage broad distribution to encourage as much participation as possible in the discussion. Of course, please continue to channel written comments on the accreditation model proposal to <mailto:3amcomments@gmail.com> 3amcomments(a)gmail.com, with a copy to <mailto:internet@winterfeldt.law> internet(a)winterfeldt.law. Thank you very much for your assistance and engagement with respect to this ongoing effort. Best regards, Brian _____ <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> [winterfeldt.law] Brian J. Winterfeldt Principal Winterfeldt IP Group <x-apple-data-detectors://12/1> 1200 17 <x-apple-data-detectors://12/1> th <x-apple-data-detectors://12/1> St NW, <x-apple-data-detectors://12/1> Ste 501 <x-apple-data-detectors://12/1> Washington, DC 20036 <mailto:brian@winterfeldt.law> brian(a)winterfeldt.law +1 202 903 4422 From: Brian Winterfeldt Sent: Thursday, March 29, 2018 7:24 PM To: <mailto:so-ac-sg-cleaders@icann.org> so-ac-sg-cleaders(a)icann.org Cc: <mailto:internet@winterfeldt.law> internet(a)winterfeldt.law Subject: URGENT REQUEST - Community Input re Accreditation Model Draft Importance: High Dear ICANN Community Leadership Colleagues: As a follow-up to my statement on behalf of the IPC during Public Forum II at ICANN 61 in Puerto Rico with Steve DelBianco (from the BC), I am writing to again request your stakeholders' input and collaboration on the proposed Accreditation Model for access to non-public WHOIS data (Version 1.3). Our sincere hope is that this model will be implemented alongside the ICANN-developed Proposed Interim Model for GDPR Compliance. The Accreditation Model can be found here: <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ipconstituency.org_ assets_docs_WHOIS-2520Access-2520Accreditation-2520Process-25201.3-255b1-255 d.pdf&d=DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhp AMF1nu2x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ &s=ZVAEQxooXzT86rLVPfHTxmzU0WSDnjHfiAcifwTNcmk&e=> http://www.ipconstituency.org/assets/docs/WHOIS%20Access%20Accreditation%20P rocess%201.3[1].pdf[ipconstituency.org]. We welcome any questions or feedback on the proposed Accreditation Model, put forward as a strawman to facilitate broader community-wide efforts to develop an accreditation system proposal. We had hoped to convene a community-wide call swiftly after ICANN 61, but the absence of Adobe Connect has made facilitating community discussion and input difficult. However, with the stop-gap solutions being put into place, we hope to convene a call to discuss Accreditation Model development within the next week or so. Developing an Accreditation Model for access to non-public WHOIS data is a critical yet-to-be-developed element of the interim GDPR compliance model, and as Goran noted in his letter to DPAs, the community has achieved consensus that something must be finalized and implemented to assure the appropriate functioning of a gated/tiered/layered access WHOIS system. Again, we hope that the Accreditation Model proposal we are sharing can act as a starting point for the community to make quick progress in this respect. Please send any input on this matter to <mailto:3amcomments@gmail.com> 3amcomments(a)gmail.com as soon as possible, with a copy to <mailto:internet@winterfeldt.law> internet(a)winterfeldt.law. This will help us make sure all the input provided is received and appropriately captured. Again, we hope to convene a community call to facilitate continued discussion on this issue next week, so we would love to receive your feedback ideally before the community session! Thank you for your input and timely engagement in this vital aspect of our ongoing work around GDPR and WHOIS! Best regards, Brian _____ <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d =DwMFAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=DJ69mAe-idEhpAMF1nu2 x6c2w3xl7xb5cjS_7sB4h6Y&m=2B8W8Arbme-D4u-B_TRTbN1ysc44yNrgdHI9xYiXehQ&s=XWpe sj5trpbb65DYwAD6KtjhoswZ8rGSMTTB7LZrTRc&e=> [winterfeldt.law] Brian J. Winterfeldt Principal Winterfeldt IP Group <x-apple-data-detectors://12/1> 1200 17 <x-apple-data-detectors://12/1> th <x-apple-data-detectors://12/1> St NW, <x-apple-data-detectors://12/1> Ste 501 <x-apple-data-detectors://12/1> Washington, DC 20036 <mailto:brian@winterfeldt.law> brian(a)winterfeldt.law +1 202 903 4422

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