I support the proposition of June 7
For Urgent Requests for Lawful Disclosure, Registrar and Registry Operator MUST acknowledge and respond without undue delay, but no more than 24 hours two (2) business days from receipt.
This for me is useful for crises like DNS Abuse and can be comprehensive for large time zone matters.

regards

Betty FAUSTA -
Mobile : +590 (0) 690 4973 09 (Guadeloupe) Fax : +33 (0) 972 2278 55
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Le mar. 18 juill. 2023, à 12 h 00, Kapin, Laureen via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> a écrit :

I knew you were wedded to the last word 😉.

 

Kind regards,

Laureen Kapin

Assistant Director for International Consumer Protection

Office of International Affairs

Federal Trade Commission

lkapin@ftc.gov

 

From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> On Behalf Of Rubens Kuhl via IRT.RegDataPolicy
Sent: Tuesday, July 18, 2023 11:58 AM
To: Dennis Chang via IRT.RegDataPolicy <irt.regdatapolicy@icann.org>
Subject: Re: [IRT.RegDataPolicy] [EXTERNAL] Proposal for reconciling competing issues related to Urgent requests

 

 



Em 18 de jul. de 2023, à(s) 12:39, Kapin, Laureen <LKAPIN@ftc.gov> escreveu:

 

We’ll have to agree to disagree Rubens.  We will continue the discussion later this week but please note –

 

1) several SG's disagree with the current view (not just "someone");

 

Including a number of SGs with members in this IRT, the same IRT that approved this exact text in the first place… 



2) the public comments expressing concerns with the proposed approach were sufficiently persuasive to convince ICANN Org’s review team to reconsider given the importance of the topic and magnitude of concerns conveyed;

 

Whether ICANN Org is looking at the subject or at “optics” is something to be determined. But Org will have to choose between throwing away the PDP manual and please some actors. And I will be sure to uphold the PDP manual and the bylaws. 



3) the stakeholder's who are most likely to make urgent requests continue to have grave concerns with the current approach; and

4) the optics of recommending a response to urgent requests that is not fit for purpose are not good, especially given the current focus on the topic of DNS Abuse 

 

The main feature of the proposed language is the phrase “without undue delay”. That’s where it clearly states the treatment urgent requests require. All the other attempts of clarifying that only created hazardous situations that only fitted the convenience of some jurisdictions (like no longer than 3 calendar days). 

 

Since you mentioned, DNS Abuse amendments are a good example of what can be accomplished without unrealistic expectations (like on-call lawyers), which is why they will be in force long before this policy. 

 

 

Rubens

 

 

 

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