Updated ICANN org Urgent Request Proposal for IRT review and Feedback by 9 September
Dear IRT, Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> for an Urgent Request timeline. The proposal in blue, which is a combination of the different proposals and feedback received includes: * A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. * A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. * A new implementation note K. For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day Monday, September 9. If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself. As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session on September 10. I will also schedule a tentative 90-minute session on September 24, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion. As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks. August 20205 Proposed Urgent Request Language<https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> I look forward to discussing with you all soon. Kind Regards, Isabelle -- Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<http://www.icann.org> Mobile: +1 310 266 7469
Isabelle and IRT colleagues, I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is *important. *It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities." Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent? Steve On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Dear IRT,
Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>for an Urgent Request timeline.
The proposal in blue, which is a combination of the different proposals and feedback received includes:
- A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. - A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. - A new implementation note K.
For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day *Monday, September 9.*
If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself.
As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session *on September 10*.
I will also schedule a tentative 90-minute session *on September 24*, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion.
As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks.
August 20205 Proposed Urgent Request Language <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>
I look forward to discussing with you all soon.
Kind Regards,
Isabelle
--
Isabelle Colas-Adeshina
Sr. Manager, Policy Research & Stakeholder Programs
Internet Corporation for Assigned Names and Numbers (ICANN)
Los Angeles, CA
www.icann.org
Mobile: +1 310 266 7469
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Hi Isabelle, Could I please request an extension for input to the document so I’m able to update our Stakeholder Group on the proposals? Thank you very much, Beth From: Steve Crocker via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Thursday, August 28, 2025 at 8:44 PM To: Isabelle Colas-Adeshina <isabelle.colasadeshina@icann.org> Cc: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Updated ICANN org Urgent Request Proposal for IRT review and Feedback by 9 September Isabelle and IRT colleagues, I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is important. It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities." Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent? Steve On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Dear IRT, Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> for an Urgent Request timeline. The proposal in blue, which is a combination of the different proposals and feedback received includes: * A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. * A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. * A new implementation note K. For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day Monday, September 9. If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself. As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session on September 10. I will also schedule a tentative 90-minute session on September 24, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion. As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks. August 20205 Proposed Urgent Request Language<https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> I look forward to discussing with you all soon. Kind Regards, Isabelle -- Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<http://www.icann.org> Mobile: +1 310 266 7469 _______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> To unsubscribe send an email to irt.regdatapolicy-leave@icann.org<mailto:irt.regdatapolicy-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://www.icann.org/privacy/tos>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. --
Same for me and the ISPCP, please! Best, Thomas Von: Elizabeth Bacon via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Datum: Dienstag, 9. September 2025 um 19:39 An: Steve Crocker <steve@shinkuro.com>, Isabelle Colas-Adeshina <isabelle.colasadeshina@icann.org> Cc: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Betreff: [IRT.RegDataPolicy] Re: Updated ICANN org Urgent Request Proposal for IRT review and Feedback by 9 September Hi Isabelle, Could I please request an extension for input to the document so I’m able to update our Stakeholder Group on the proposals? Thank you very much, Beth From: Steve Crocker via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Thursday, August 28, 2025 at 8:44 PM To: Isabelle Colas-Adeshina <isabelle.colasadeshina@icann.org> Cc: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Updated ICANN org Urgent Request Proposal for IRT review and Feedback by 9 September Isabelle and IRT colleagues, I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is important. It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities." Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent? Steve On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Dear IRT, Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> for an Urgent Request timeline. The proposal in blue, which is a combination of the different proposals and feedback received includes: * A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. * A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. * A new implementation note K. For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day Monday, September 9. If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself. As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session on September 10. I will also schedule a tentative 90-minute session on September 24, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion. As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks. August 20205 Proposed Urgent Request Language<https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> I look forward to discussing with you all soon. Kind Regards, Isabelle -- Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<http://www.icann.org> Mobile: +1 310 266 7469 _______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> To unsubscribe send an email to irt.regdatapolicy-leave@icann.org<mailto:irt.regdatapolicy-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. --
I have a similar but mildly modified comment to Steve's which is that I cannot stress well enough that the word "Urgent" should be avoided in lieu of some other specific term for these imminent situations requiring this expedient handling, preferably used only for these types of requests so that they can be filtered for prompt handling. something like "Crisis RDPIRT Handling Request" "Critical RDPIRT Exigent Matter" My rationale for this recommendation is that >98% of matters sent to registrars are labelled with "Urgent" and its over-use would create a layer of noise that I fear a valid requestor's legitimate contact requiring the level urgency of handling currently being litigated here in the IRT could get lost in that noise if it were simply labelled 'urgent'. It would be bad for those 2 or 3 annual situations across the industry where use cases related to this matter actually might arise to not have them receive due care over being labelled in a manner that camouflages them. -Jothan Jothan Frakes Tel: +1.206-355-0230 This email and any attachments may contain confidential and/or privileged information intended solely for the use of the individual or entity to whom it is addressed. If you are not the intended recipient, please notify the sender immediately and delete this message. Any unauthorized use, disclosure, or distribution is prohibited. On Thu, Aug 28, 2025 at 5:44 PM Steve Crocker via IRT.RegDataPolicy < irt.regdatapolicy@icann.org> wrote:
Isabelle and IRT colleagues,
I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is *important. *It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities."
Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent?
Steve
On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Dear IRT,
Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>for an Urgent Request timeline.
The proposal in blue, which is a combination of the different proposals and feedback received includes:
- A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. - A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. - A new implementation note K.
For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day *Monday, September 9.*
If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself.
As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session *on September 10*.
I will also schedule a tentative 90-minute session *on September 24*, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion.
As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks.
August 20205 Proposed Urgent Request Language <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>
I look forward to discussing with you all soon.
Kind Regards,
Isabelle
--
Isabelle Colas-Adeshina
Sr. Manager, Policy Research & Stakeholder Programs
Internet Corporation for Assigned Names and Numbers (ICANN)
Los Angeles, CA
www.icann.org
Mobile: +1 310 266 7469
_______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org To unsubscribe send an email to irt.regdatapolicy-leave@icann.org
_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
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_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
hi Everyone I'm can join Jothan proposal and share 2 tags options : - Extrem critical request - Critical request - Critical dispude (if there is a label with a law issue can impact registrars) About the due diligence time, 2 hours is too short for small organisations and countries concern by local languages or have some technical partners in another country maybe in another timezone. 4 hours is more reasonable. regards *Betty FAUSTA -* Mobile : +590 (0) 690 4973 09 (Guadeloupe) Fax : +33 (0) 972 2278 55 Contacts : Skype BETFAU | Pin BBM : 76521821 | Whats'app &Viber Le mar. 9 sept. 2025, à 16 h 37, Jothan Frakes via IRT.RegDataPolicy < irt.regdatapolicy@icann.org> a écrit :
I have a similar but mildly modified comment to Steve's which is that I cannot stress well enough that the word "Urgent" should be avoided in lieu of some other specific term for these imminent situations requiring this expedient handling, preferably used only for these types of requests so that they can be filtered for prompt handling.
something like "Crisis RDPIRT Handling Request" "Critical RDPIRT Exigent Matter"
My rationale for this recommendation is that >98% of matters sent to registrars are labelled with "Urgent" and its over-use would create a layer of noise that I fear a valid requestor's legitimate contact requiring the level urgency of handling currently being litigated here in the IRT could get lost in that noise if it were simply labelled 'urgent'.
It would be bad for those 2 or 3 annual situations across the industry where use cases related to this matter actually might arise to not have them receive due care over being labelled in a manner that camouflages them.
-Jothan
Jothan Frakes Tel: +1.206-355-0230
This email and any attachments may contain confidential and/or privileged information intended solely for the use of the individual or entity to whom it is addressed. If you are not the intended recipient, please notify the sender immediately and delete this message. Any unauthorized use, disclosure, or distribution is prohibited.
On Thu, Aug 28, 2025 at 5:44 PM Steve Crocker via IRT.RegDataPolicy < irt.regdatapolicy@icann.org> wrote:
Isabelle and IRT colleagues,
I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is *important. *It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities."
Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent?
Steve
On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Dear IRT,
Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>for an Urgent Request timeline.
The proposal in blue, which is a combination of the different proposals and feedback received includes:
- A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. - A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. - A new implementation note K.
For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day *Monday, September 9.*
If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself.
As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session *on September 10*.
I will also schedule a tentative 90-minute session *on September 24*, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion.
As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks.
August 20205 Proposed Urgent Request Language <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>
I look forward to discussing with you all soon.
Kind Regards,
Isabelle
--
Isabelle Colas-Adeshina
Sr. Manager, Policy Research & Stakeholder Programs
Internet Corporation for Assigned Names and Numbers (ICANN)
Los Angeles, CA
www.icann.org
Mobile: +1 310 266 7469
_______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org To unsubscribe send an email to irt.regdatapolicy-leave@icann.org
_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
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_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
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Hi Team, I’m realizing I wasn’t clear in my previous email that I will be able to offer preliminary views on our call today, but need a little more time for final comments into the doc. I appreciate everyone’s patience and flexibility! Thanks, Beth From: BF via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Tuesday, September 9, 2025 at 6:44 PM To: Jothan Frakes <jothan@jothan.com> Cc: Isabelle Colas-Adeshina <isabelle.colasadeshina@icann.org>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Updated ICANN org Urgent Request Proposal for IRT review and Feedback by 9 September hi Everyone I'm can join Jothan proposal and share 2 tags options : * Extrem critical request * Critical request * Critical dispude (if there is a label with a law issue can impact registrars) About the due diligence time, 2 hours is too short for small organisations and countries concern by local languages or have some technical partners in another country maybe in another timezone. 4 hours is more reasonable. regards Betty FAUSTA - Mobile : +590 (0) 690 4973 09 (Guadeloupe) Fax : +33 (0) 972 2278 55 Contacts : Skype BETFAU | Pin BBM : 76521821 | Whats'app &Viber Le mar. 9 sept. 2025, à 16 h 37, Jothan Frakes via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> a écrit : I have a similar but mildly modified comment to Steve's which is that I cannot stress well enough that the word "Urgent" should be avoided in lieu of some other specific term for these imminent situations requiring this expedient handling, preferably used only for these types of requests so that they can be filtered for prompt handling. something like "Crisis RDPIRT Handling Request" "Critical RDPIRT Exigent Matter" My rationale for this recommendation is that >98% of matters sent to registrars are labelled with "Urgent" and its over-use would create a layer of noise that I fear a valid requestor's legitimate contact requiring the level urgency of handling currently being litigated here in the IRT could get lost in that noise if it were simply labelled 'urgent'. It would be bad for those 2 or 3 annual situations across the industry where use cases related to this matter actually might arise to not have them receive due care over being labelled in a manner that camouflages them. -Jothan Jothan Frakes Tel: +1.206-355-0230 This email and any attachments may contain confidential and/or privileged information intended solely for the use of the individual or entity to whom it is addressed. If you are not the intended recipient, please notify the sender immediately and delete this message. Any unauthorized use, disclosure, or distribution is prohibited. On Thu, Aug 28, 2025 at 5:44 PM Steve Crocker via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Isabelle and IRT colleagues, I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is important. It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities." Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent? Steve On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Dear IRT, Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> for an Urgent Request timeline. The proposal in blue, which is a combination of the different proposals and feedback received includes: * A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. * A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. * A new implementation note K. For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day Monday, September 9. If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself. As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session on September 10. I will also schedule a tentative 90-minute session on September 24, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion. As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks. August 20205 Proposed Urgent Request Language<https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit> I look forward to discussing with you all soon. Kind Regards, Isabelle -- Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<http://www.icann.org> Mobile: +1 310 266 7469 _______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> To unsubscribe send an email to irt.regdatapolicy-leave@icann.org<mailto:irt.regdatapolicy-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://www.icann.org/privacy/tos>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. -- _______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> To unsubscribe send an email to irt.regdatapolicy-leave@icann.org<mailto:irt.regdatapolicy-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://www.icann.org/privacy/tos>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. _______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> To unsubscribe send an email to irt.regdatapolicy-leave@icann.org<mailto:irt.regdatapolicy-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://www.icann.org/privacy/tos>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
There absolutely must be flexibility to deal with real world lives here. Registrars are not robots, they are staffed with people. I suspect there may be some misinformation about the resourcing of registrars, but the 10.7.2.3 appears to be offensively inflexible wording about impact to the lives of smaller registrars and perhaps naive about the size of registrar companies and how the weaponization of policy occurs when they get an answer that is the best they can get but are unsatisfied about the outcome and want a pound of flesh via being punitive through ICANN compliance. We must shift back to business days not calendar days, unless ICANN is willing to discount my accreditation fees by the amount of costs to double my staffing. Also, this is incredibly problematic: "For the avoidance of doubt, circumstances which do not justify extending the 24-hour timeline include foreseeable circumstances such as calendar holidays, planned leave, or planned travel." This needs to be stricken, it is offensive. When applied with the change from business days to calendar days, the policy wording may be straying into introducing human rights issues or adverse working conditions. The 24 hour timeline and coverage is understood as to the aspirations of response times, but registrars are not all large 5000+ person companies where the staffing and resources are present to absorb this, nor do margins from domain or associated sales leave room for the costs and burden these create. For all practical purposes, many of us will have no alternative but to use voicemail for this coverage, and check frequently, as we simply lack the personnel or resourcing to meet this aggressive requirement. There are registrars with 40+ staff where these requirements are difficult and expensive to meet without having to resort to having it go to voicemail and messages responded to. This might be the best reasonable manner to handle things occurring outside of business hours. The wording that introduced flexibility was not seeking to make room for violation of the fastest possible responses, it was present to create guard rails against those who weaponize compliance inappropriately. Jothan Frakes Tel: +1.206-355-#### This email and any attachments may contain confidential and/or privileged information intended solely for the use of the individual or entity to whom it is addressed. If you are not the intended recipient, please notify the sender immediately and delete this message. Any unauthorized use, disclosure, or distribution is prohibited. On Wed, Sep 10, 2025 at 7:46 AM Elizabeth Bacon <bbacon@pir.org> wrote:
Hi Team, I’m realizing I wasn’t clear in my previous email that I will be able to offer preliminary views on our call today, but need a little more time for final comments into the doc. I appreciate everyone’s patience and flexibility! Thanks, Beth
*From: *BF via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> *Date: *Tuesday, September 9, 2025 at 6:44 PM *To: *Jothan Frakes <jothan@jothan.com> *Cc: *Isabelle Colas-Adeshina <isabelle.colasadeshina@icann.org>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> *Subject: *[IRT.RegDataPolicy] Re: Updated ICANN org Urgent Request Proposal for IRT review and Feedback by 9 September
hi Everyone
I'm can join Jothan proposal and share 2 tags options :
- Extrem critical request - Critical request - Critical dispude (if there is a label with a law issue can impact registrars)
About the due diligence time, 2 hours is too short for small organisations and countries concern by local languages or have some technical partners in another country maybe in another timezone. 4 hours is more reasonable.
regards
*Betty FAUSTA -* Mobile : +590 (0) 690 4973 09 (Guadeloupe) Fax : +33 (0) 972 2278 55 Contacts : Skype BETFAU | Pin BBM : 76521821 | Whats'app &Viber
Le mar. 9 sept. 2025, à 16 h 37, Jothan Frakes via IRT.RegDataPolicy < irt.regdatapolicy@icann.org> a écrit :
I have a similar but mildly modified comment to Steve's which is that I cannot stress well enough that the word "Urgent" should be avoided in lieu of some other specific term for these imminent situations requiring this expedient handling, preferably used only for these types of requests so that they can be filtered for prompt handling.
something like "Crisis RDPIRT Handling Request" "Critical RDPIRT Exigent Matter"
My rationale for this recommendation is that >98% of matters sent to registrars are labelled with "Urgent" and its over-use would create a layer of noise that I fear a valid requestor's legitimate contact requiring the level urgency of handling currently being litigated here in the IRT could get lost in that noise if it were simply labelled 'urgent'.
It would be bad for those 2 or 3 annual situations across the industry where use cases related to this matter actually might arise to not have them receive due care over being labelled in a manner that camouflages them.
-Jothan
Jothan Frakes Tel: +1.206-355-0230
This email and any attachments may contain confidential and/or privileged information intended solely for the use of the individual or entity to whom it is addressed. If you are not the intended recipient, please notify the sender immediately and delete this message. Any unauthorized use, disclosure, or distribution is prohibited.
On Thu, Aug 28, 2025 at 5:44 PM Steve Crocker via IRT.RegDataPolicy < irt.regdatapolicy@icann.org> wrote:
Isabelle and IRT colleagues,
I continue to object to the use of the term "urgent" and the reference in the definition to "imminent." The timeline is not consistent with these words. The use of the word "urgent" in the title creates a misunderstanding and incorrect expectations. The definition "Urgent Request" makes it clear the request is *important. *It's widely understood that importance and urgency are distinct, and should not be conflated. Accordingly, a more accurate title would be "Important Requests from Authorized Law Enforcement Authorities."
Perhaps at some future time there will be policy and implementation changes that provide responses in seconds or minutes. At that point, the use of the word "urgent" will be fitting. If "urgent" is used for the requests as defined in this draft, what word will be available to use when responses are available a thousand times faster? Perhaps truly urgent?
Steve
On Thu, Aug 28, 2025 at 6:21 PM Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Dear IRT,
Thank you for the productive discussion during our IRT session on August 6. As discussed, ICANN org has taken into consideration the proposals received, as well as the feedback and concerns raised. Based on this consideration, please find an updated ICANN org proposal <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>for an Urgent Request timeline.
The proposal in blue, which is a combination of the different proposals and feedback received includes:
- A new definition for Authenticated Requestors, along with a proposed edit to the Urgent Requests definition. - A new section in the Registration Data Policy - Section 10.7, which includes the proposed Urgent Request timeline. - A new implementation note K.
For each proposed change, I have provided a brief rationale for its inclusion. Please take the time to review and discuss the language with your stakeholder groups and provide feedback directly on the document by the end of the day *Monday, September 9.*
If you would like further context on the rationale and thought process behind the proposed language, I have attached a rationale paper, which outlines ongoing IRT discussions regarding Urgent Requests and provides additional context behind the proposed language from ICANN org. Please note that the rationale paper is provided for informational purposes only, and I suggest that the IRT focus their feedback on the proposed language itself.
As we approach our fifth Urgent Request IRT session, please keep in mind that the Urgent Request discussions were intended to be limited in nature. Therefore, our goal is to finalize and reach an agreement on a proposed timeline during the upcoming session. In light of this, I will schedule a 90-minute Urgent Request session *on September 10*.
I will also schedule a tentative 90-minute session *on September 24*, which will serve as a placeholder for this group only if we determine that additional time is needed to reach a conclusion.
As the aim is to reach alignment during the first 90-minute session, it is important that you provide feedback on the proposal, including potential solutions, so we, as a group, can be well-prepared to discuss it further in the coming weeks.
August 20205 Proposed Urgent Request Language <https://docs.google.com/document/d/1T2CMza4whggkveWiu5Ri2dOR1a27PYXN/edit>
I look forward to discussing with you all soon.
Kind Regards,
Isabelle
--
Isabelle Colas-Adeshina
Sr. Manager, Policy Research & Stakeholder Programs
Internet Corporation for Assigned Names and Numbers (ICANN)
Los Angeles, CA
www.icann.org
Mobile: +1 310 266 7469
_______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org To unsubscribe send an email to irt.regdatapolicy-leave@icann.org
_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
--
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_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
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_______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
participants (6)
-
BF -
Elizabeth Bacon -
Isabelle Colas-Adeshina -
Jothan Frakes -
Steve Crocker -
Thomas Rickert | rickert.law