Um, seems we have a problem with the metaphor, Michele. Here's a hint (*my emphasis*): "During this period of uncertainty, and under the conditions noted below, ICANN Contractual Compliance will defer taking action against any registry or registrar for noncompliance with contractual obligations related to the handling of registration data. To be eligible, a contracted party that intends to deviate from its existing obligations must share its model with ICANN Contractual Compliance and the Global Domains Division. *To the extent that the party requests confidential treatment,** ICANN will remove any identifying information and share only the elements of the model with the Hamilton law firm for the purpose of legal analysis against the requirements of the GDPR. The model should reflect a reasonable accommodation of existing contractual obligations and the GDPR and should be accompanied by an analysis explaining how the model reconciles the two. For clarity, Contractual Compliance would not defer enforcement if, for example, a contracted party submitted a model under which it abandoned its WHOIS obligations. In addition, a model that satisfies the conditions noted here might also require compliance with other contractual obligations or consensus policies, e.g., the Registry Services Evaluation Policy (RSEP). A model may also require further modifications if it is later determined not to comply either with the GDPR or any future community-developed policy.* Detailed guidance regarding the process and eligibility requirements will be provided shortly. ​" -Carlton​ ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Sun, Nov 5, 2017 at 12:29 PM, Michele Neylon - Blacknight < michele@blacknight.com> wrote:

Carlton

Which part of it do you find unclear?

Regards

Michele

--

Mr Michele Neylon

Blacknight Solutions

Hosting, Colocation & Domains

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*From: *<registration-issues-wg-bounces@atlarge-lists.icann.org> on behalf of Carlton Samuels <carlton.samuels@gmail.com> *Date: *Sunday 5 November 2017 at 16:19 *To: *"registration-issues-wg@icann.org" <registration-issues-wg@icann.org>, "lac-discuss-en@atlarge-lists.icann.org" <lac-discuss-en@atlarge-lists. icann.org> *Subject: *[registration-issues-wg] ICANN Compliance Statement on impact of GDPR on WHOIS Obligations

There is its, clear as mud!

https://www.icann.org/resources/pages/contractual- compliance-statement-2017-11-02-en

-Carlton

============================== *Carlton A Samuels*

*Mobile: 876-818-1799 <(876)%20818-1799> Strategy, Planning, Governance, Assessment & Turnaround* =============================