Hi Lili: See my comments in line. ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* ============================= On Sat, Jun 2, 2018 at 10:21 PM, SUN Lili <L.SUN@interpol.int> wrote:

Dear Privacy & Proxy subgroup members,

I went through the draft report of this subgroup on wiki page ( https://community.icann.org/pages/viewpage.action?pageId=71604717) and step in with my concerns:

1. To the Data Accuracy subgroup, the Whois accuracy of domain names that utilize Privacy and Proxy Services is invisible. And Volker also mentioned that this will be dealt with in the Privacy & Proxy subgroup.

​Under current rules, the accredited P/P provider is obliged to ensure contactability of customer of his service​. That this is the case cannot be verified independently and some of us have argued from inception this is a major hole in the agreement. We have alternately argued that there should be graded penalties for this violation after the fact.

As such, I strongly support Susan’s comments on “6 Conducting periodic due diligence checks on customer contact information” and “8 Providing clear and unambiguous guidance on the rights and responsibilities of registered name holders, and how those should be managed in the privacy/proxy environment.” There is no reason for a customer who chose P/P service thus been protected from responsibilities.

​See above. We expect that the risk triage will allow the cost of violation to pass to the customer.​

2. There is no indication about the legacy domain names that utilize P/P Services before the provider been accredited. Will it be a similar situation as Grandfathered domains?

​Some of us have argued that there should be a Privacy/Proxy Data Accuracy Reminder policy along the line of the WHOIS Data reminder. It was not accepted. But there is no reason the P/P provider cannot be obliged and bound to it in terms of the accreditation for renewals. ​

3. Like the example I gave during the 2nd F2F meeting, if there is not enough regulation and overseeing in place, P/P service is very likely to be abused. To be clear, I elaborated the example in a word document (see attached). Do we really need this kind of fake prosperity of domain industry?

A response from this subgroup is much appreciated.

​Best, -Carlton​

Thanks,

Lili

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