[CCWG-ACCT] CCWG-Accountability-WS2 - 27-28 September Plenary Agenda and Materials - 1 of 2 - FoI text proposal to bridge divergences
Paul Twomey
paul.twomey at argopacific.com
Fri Sep 29 18:38:18 UTC 2017
Dear Jorge
Thank you for your detail and clarity as well.
I understand the intent of the separation of the SOs etc from other
functions of ICANN. I just am not sure that "business" is the right
way to describe the other functions - so many of those functions are
closer to global public good functions rather than "business" -
certainly business as understood in the Ruggie Principles.
As I think further about the risks I am concerned about, I would agree
with Greg Shatan's observation:
"Finally, none of this is to say that Ruggie should not be considered in
the implementation of the Human Rights Core Value -- which is already
supported in the Considerations portion of the document.
It is to say that Ruggie should not be used to interpret the meaning of
the Bylaw itself."
I will leave it to other to consider whether my comments helps us
resolve your language as it stands. I am not trying to be disrespectul
of your efforts or the comments by the three government. I am just
very skeptical about how uninformed judges interpret such language.
Best
Paul
On 9/29/17 5:41 AM, Jorge.Cancio at bakom.admin.ch wrote:
>
> Dear Paul, and dear all,
>
> Paul, thank you for your clarity.
>
> However, I feel that these concerns you mention and which you brought
> forward, if my recollection is right, during work stream 1 (now it
> seems ages ago…) have IMO been taken care by the adopted Bylaws
> themselves – a compromise proposal that we sturdily helped to pass at
> the end of work stream 1, accepting that such precautions were needed
> to address such general concerns.
>
> But now we are at the beginning of the end of work stream 2.
>
> The Bylaw that was passed as a result of the Marrakech agreements took
> care of such general caveats by, inter alia, the following measures:
>
> (1) it configures the HR clause as a “core value”;
>
> (2) the core value is just guiding;
>
> (3) it is subject to the core value balancing test;
>
> (4) core values yield to what is established in the commitments;
>
> (5) the core value has to be applied strictly within the Mission of
> ICANN;
>
> (6) the core value itself establishes that in applying the HR ICANN is
> bound only to what is required by “applicable law”, that it is bound
> by the Mission, that it cannot enforce HR obligations – for itself or
> for third parties; etc.
>
> Btw, I’m not sure how the potential actions you describe would fit
> into ICANNs narrow Mission.
>
> Here is the Core Value text again for the convenience of all:
>
> /“//Subject to the limitations set forth in _Section 27.2_, within the
> scope of its Mission and other Core Values, respecting internationally
> recognized human rights as required by applicable law. This Core Value
> does not create, and shall not be interpreted to create, any
> obligation on ICANN outside its Mission, or beyond obligations found
> in applicable law. This Core Value does not obligate ICANN to enforce
> its human rights obligations, or the human rights obligations of other
> parties, against other parties.”/
>
> The FoI and the Considerations document flesh out and further specify
> many of these belts and suspenders that "protect" against any
> overexpansion of the HR core value.
>
> It goes without saying that the text I proposed does not change any of
> the Bylaw provisions. And it fits well into the FoI (and
> considerations) document, which is only complemented with two
> sentences. As said before, there is no contradiction with the
> “considerations”, as those refer to the application of the UNGP to
> _all of_ ICANN in general. In contrast, and taking into consideration
> the concerns expressed by some in the Subgroup, the text we propose
> only refers to ICANN “Organization” and not to SO/ACs.
>
> As to these two sentences that I have proposed, they make two things:
>
> ·First, there is a mention, amongst the international instruments, of
> the UNGP: “*/The UN Guiding Principles on Businesses and Human Rights
> are relevant for business organizations.” /* As I explained below this
> is a statement of fact that should not be problematic. The UNGP are an
> international instrument endorsed by the United Nations. As other
> declarations mentioned in the FoI, it is not as such a legally binding
> document, but it was unanimously endorsed in 2011 by the United
> Nations Human Rights Council through a formal resolution. ICANN has,
> as many have said here, business organization aspects – I may well
> accept to nuance it as Avri proposed (“not-profit business
> organization”, I think) – so it is a relevant instrument.
>
> ·Then, the proposed text says that ICANN “the Organization” should
> consider the UNGP as a “useful guide”: “*/Insofar ICANN the
> Organization is concerned, it should consider, as a business, the UN
> Guiding Principles on Businesses and Human Rights as a useful guide
> when applying the Human Rights Core Value./**“ *This text builds in
> additional safeguards to avoid any danger whatsoever of extension of
> the UNGP to the non-business elements of ICANN (SO/ACs) as there is
> specific mention that the UNGP would be relevant only for ICANN the
> Organization. In addition, the mention is constrained to having to
> “_consider_” the UNGP “_as a useful guide_” when applying the core value.
>
> Therefore, I would be thankful if we discussed the specific text
> proposals and, in a spirit of compromise, we made concrete proposals
> that would address specific and factual concerns arising from the
> proposed two sentences. After all this is a proposal. At the same
> time, as said, this is an intended common ground proposal that
> differs, by being significantly less ambitious, from the public
> comment proposals filed by the Governments of Switzerland, UK and
> Brazil – which have at various time been supported by a number of
> other countries and participants.
>
> Thanks all for your consideration and kind regards
>
> Jorge
>
> *Von:*Paul Twomey [mailto:paul.twomey at argopacific.com]
> *Gesendet:* Donnerstag, 28. September 2017 23:41
> *An:* Cancio Jorge BAKOM <Jorge.Cancio at bakom.admin.ch>;
> turcotte.bernard at gmail.com; accountability-cross-community at icann.org
> *Betreff:* Re: AW: [CCWG-ACCT] CCWG-Accountability-WS2 - 27-28
> September Plenary Agenda and Materials - 1 of 2 - FoI text proposal to
> bridge divergences
>
> Thanks Jorge
>
> At this late stage let me be somewhat blunt to be clear.
>
> The sort of language in the Ruggie Principles which worry me is:
>
> 13. The responsibility to respect human rights requires that business
> enterprises: …
>
> (b) Seek to prevent or mitigate adverse human rights impacts that are
> directly linked to their operations, products or services by their
> business relationships, even if they have not contributed to those
> impacts.
>
> 15. In order to meet their responsibility to respect human rights,
> business enterprises should have in place policies and processes
> appropriate to their size and circumstances, including: (c) Processes
> to enable the remediation of any adverse human rights impacts they
> cause or to which they contribute.
>
> My concern is not to ensure that ICANN can continue to coordinate with
> all the relevant technical organizations around the world (many of
> which are government run) which enable the operate of the Domain Name
> System, the IP address allocation and the Protocol Parameter
> responsibilities of the IANA functions.
>
> Just to give one example, let us look at ccTLD operators. ICANN does
> have a range of agreements within around 86 ccTLD operators, (See:
> https://www.icann.org/resources/pages/cctlds/cctlds-en) I do not think
> we intend to establish wording which would result in dissident groups
> from various countries going to a US court arguing that ICANN is in
> breach of its bylaws by having an explicit or implied agreement with a
> ccTLD operator recognized as part of the IANA process, especially
> where the dissident group alleges that the ccTLD operator is breaching
> human rights by following its government’s instructions on
> registrations. You can think of several examples where this may
> happen. Having the sections above applying to ICANN (even where it
> operates as a business) would put at risk ICANN’s ability to be a
> global coordinator as per its mission. By definition, it has to be
> able to serve every ccTLD.
>
> Furthermore, any court or other group thinking that ICANN should under
> principle 15 take action to remediate the adverse human rights impact
> would have to consider ICANN breaking off links with that ccTLD.
> Which brings me back to my global coordinator challenge.
>
> I hope this helps
>
> Paul
>
> On 9/28/17 5:07 PM, Jorge.Cancio at bakom.admin.ch
> <mailto:Jorge.Cancio at bakom.admin.ch>wrote:
>
> Dear Paul,
>
> I would appreciate your being more specific, and elaborating what
> wording in my proposal gives rise to such fears, and what is
> exactly which is so distinct from the prior FoI text.
>
> For your convenience, here is again the proposed change in red:
>
> “/By committing to one or more of these international instruments,
> nation states are expected to embed human rights in their national
> legislation*. */
>
> */The UN Guiding Principles on Businesses and Human Rights are
> relevant for business organizations. Insofar ICANN the
> Organization is concerned, it should consider, as a business, the
> UN Guiding Principles on Businesses and Human Rights as a useful
> guide when applying the Human Rights Core Value./**“*
>
> Thanks for your help in understanding your position.
>
> Regards
>
> Jorge
>
> *Von:*Paul Twomey [mailto:paul.twomey at argopacific.com]
> *Gesendet:* Donnerstag, 28. September 2017 23:00
> *An:* Cancio Jorge BAKOM <Jorge.Cancio at bakom.admin.ch>
> <mailto:Jorge.Cancio at bakom.admin.ch>; turcotte.bernard at gmail.com
> <mailto:turcotte.bernard at gmail.com>;
> accountability-cross-community at icann.org
> <mailto:accountability-cross-community at icann.org>
> *Betreff:* Re: [CCWG-ACCT] CCWG-Accountability-WS2 - 27-28
> September Plenary Agenda and Materials - 1 of 2 - FoI text
> proposal to bridge divergences
>
> Dear Jorge
>
> I have to say that I agree with Greg on this. My interventions
> on the HR working group have consistently focused on the ability
> of ICANN to operate its IANA and other technical functions under
> policy and/or numerous agreements with numerous technical bodies
> (such as ccTLD operators, Root Zone operators etc) in support of a
> global, interoperable Internet. The wording you propose would in
> my view put this at risk - as I have point several times over the
> last years the Rugge Principles, especially as those principles
> which apply to supply chains and contractors, are well suited to a
> mining company which can decide whether or not to do business in
> certain circumstance in certain countries. ICANN does not have
> that luxury. It is charged with supporting a Global Internet and
> hence has to be able to deal with every relevant ccTLD operator,
> Root Zone Operator, RIR etc, many of which it has agreements.
> In that sense ICANN is not like a private company at all.
>
> Paul
>
> On 9/28/17 4:38 PM, Jorge.Cancio at bakom.admin.ch
> <mailto:Jorge.Cancio at bakom.admin.ch>wrote:
>
> Dear Greg, dear all,
>
> The UNGP are an international instrument endorsed by the
> United Nations. As other declarations mentioned in the FoI, it
> is not as such a legally binding document, but it was
> unanimously endorsed in 2011 by the United Nations Human
> Rights Council through a formal resolution. Therefore,
> locating it under instruments makes sense.
>
> There is no contradiction with the “considerations”, as those
> refer to the application of the UNGP to _all of ICANN in
> general_. In contrast, and taking into consideration the
> concerns expressed by some in the Subgroup, the text we
> propose _only refers to ICANN “Organization”_ and not to SO/ACs.
>
> This is a common ground proposal that differs, by being
> significantly less ambitious, from the public comment
> proposals filed by the Governments of Switzerland, UK and
> Brazil – which have at various time been supported by a number
> of other countries and participants.
>
> Therefore, I hope that the CCWG Plenary will work on a CCWG
> broader consensus text on this basis, giving consideration and
> being inclusive of at least a minimal part of the named public
> comment inputs.
>
> Kind regards
>
> Jorge
>
> *Von:*Greg Shatan [mailto:gregshatanipc at gmail.com]
> *Gesendet:* Donnerstag, 28. September 2017 22:12
> *An:* Cancio Jorge BAKOM <Jorge.Cancio at bakom.admin.ch>
> <mailto:Jorge.Cancio at bakom.admin.ch>
> *Cc:* Bernard Turcotte <turcotte.bernard at gmail.com>
> <mailto:turcotte.bernard at gmail.com>;
> accountability-cross-community at icann.org
> <mailto:accountability-cross-community at icann.org>
> *Betreff:* Re: [CCWG-ACCT] CCWG-Accountability-WS2 - 27-28
> September Plenary Agenda and Materials - 1 of 2 - FoI text
> proposal to bridge divergences
>
> Unfortunately, I cannot support this suggestion.
>
> First, this statement is partially redundant of and partially
> contradicts another section of the Report, under "Consider
> which specific Human Rights conventions or other instruments,
> if any, should be used by ICANN in interpreting and
> implementing the Human Rights Bylaw":
>
> With regards to the UN Guiding Principles for Business and
> Human Rights, no consensus was reached as to their
> suitability for interpreting the Core Value. However with
> regard to the implementation of the Core Value certain
> aspects of the UN Guiding Principles for Business and
> Human Rights could be considered as a useful guide in the
> process of applying the Human Rights Core Value. There are
> certain Guiding Principles that may not be suitable for
> ICANN and others that might be applicable, depending on
> the circumstances. However, it is beyond the scope of this
> document to provide a detailed analysis of the Guiding
> Principles and their application, or not, in particular
> situations.
>
> In any case, a conflict between any Guiding Principle and
> an ICANN Bylaw provision or Article of Incorporation must
> be resolved in favor of the Bylaw or Article. The use of
> the Guiding Principles as potential guidance has to be
> carefully considered by each SO and AC as well as ICANN
> the organization.
>
> The suggested language absolutely contradicts the conclusion
> that "
>
> With regards to the UN Guiding Principles for Business and
> Human Rights, no consensus was reached as to their suitability
> for interpreting the Core Value.
>
> " This was carefully balanced language, in itself a
> compromise. Further the language goes on to indicate how the
> UNGP could be considered during _implementation_ of the Bylaw.
>
> With the conclusion that no conThis section, for which no
> revision is suggested, states quite appropriately why the UNGP
> should be treated as it is in the report.
>
> Second, this is being inserted into the interpretation of
> the term
>
> "internationally recognized human rights
>
>
>
> "
>
> as stated in the Core Value.
>
> This is troublesome. The UNGP is not a human rights
> declaration, so it should not be mentioned here. Aside from
> covenants and declarations, this section of the FoI discusses
> only international law. So the UNGP does not belong here.
> Also, the proposal would drop this statement into the middle
> of a discussion of international human rights instruments
> (which apply to states, not to ICANN), completely disrupting
> the analysis.
>
> Unfortunately, we were not supplied with the entire text,
> which would have made this more clear. Here it is, without
> the suggested addition:
>
> There are a range of international human-rights
> declarations and covenants that could be relevant to
> ICANN’s Human Rights Core Value. However, none of these
> instruments has a direct application to ICANN, because
> they only create obligations for States. By committing to
> one or more of these international instruments, nation
> states are expected to embed human rights in their
> national legislation.
>
> The reference to “internationally recognized human rights”
> in the bylaw should not be read in isolation; rather it
> must be considered together with, and limited by, the
> reference “as required by applicable law.” As a
> consequence, under the Human Rights Core Value,
> international human rights instruments are not directly
> applicable to ICANN beyond what is provided for in
> applicable law. Rather, only those human rights that are
> “required by applicable law” will be relevant to ICANN.
>
> Furthermore, depending on the jurisdiction in which ICANN
> operates, the law applicable to its operations may vary
> and thus the human rights applicable to ICANN’s operations
> will vary as well.
>
> Nevertheless, ICANN understands that internationally
> recognised human rights, including those expressed in the
> Universal Declaration of Human Rights, can guide its
> decisions and actions.
>
> Finally, I will note my view that the Subgroup fully, fairly,
> comprehensively and inclusively considered all of the Public
> Comments and held numerous discussions on this very topic. As
> such, I think that without persuasive arguments on substance,
> sufficient to convince the Plenary to take a different view,
> there is no reason to change the Report.
>
> On Thu, Sep 28, 2017 at 8:21 AM, <Jorge.Cancio at bakom.admin.ch
> <mailto:Jorge.Cancio at bakom.admin.ch>> wrote:
>
> Dear all,
>
> Further to my Email below, I would like to share with you
> the following proposal that would constitute in my view an
> acceptable outcome of the public consultation on the
> Framework of Interpretation, and build on the wording
> proposals made by Switzerland in its public comment input
> (see attached) and the exchanges had thereafter in the
> Subgroup.
>
> Specifically, I would like to propose that the following
> paragraph on page 6 (under “internationally recognized
> human rights”) be reworded as follows (changes in red):
>
> “/By committing to one or more of these international
> instruments, nation states are expected to embed human
> rights in their national legislation*. */
>
> */The UN Guiding Principles on Businesses and Human Rights
> are relevant for business organizations. Insofar ICANN the
> Organization is concerned, it should consider, as a
> business, the UN Guiding Principles on Businesses and
> Human Rights as a useful guide when applying the Human
> Rights Core Value./**“*
>
> The UN Guiding Principles on Businesses and Human Rights
> (UNGP) are the universally accepted voluntary standard for
> business organizations. Therefore, we feel that it should
> be mentioned under the instruments regarding
> “internationally recognized human rights”. In order to
> avoid any extension of the UNGP to the non-business
> elements of ICANN (SO/ACs) there is specific mention that
> the UNGP would be relevant only for ICANN the
> Organization. In addition, the mention is constrained to
> having to “consider” the UNGP “as a useful guide” – which,
> in our view, eliminates any perceived danger of creating
> any obligation whatsoever through this mention.
>
> I hope that this compromise proposal may be positively
> considered by all of you. Please note that it is made only
> by me with the aim of arriving at a common ground and that
> it has not been possible to coordinate due to time
> constraints with the other participants joining the dissent.
>
> Best regards
>
> Jorge
>
> *Von:*accountability-cross-community-bounces at icann.org
> <mailto:accountability-cross-community-bounces at icann.org>[mailto:accountability-cross-community-bounces at icann.org
> <mailto:accountability-cross-community-bounces at icann.org>]
> *Im Auftrag von *Jorge.Cancio at bakom.admin.ch
> <mailto:Jorge.Cancio at bakom.admin.ch>
> *Gesendet:* Montag, 25. September 2017 15:34
> *An:* turcotte.bernard at gmail.com
> <mailto:turcotte.bernard at gmail.com>;
> accountability-cross-community at icann.org
> <mailto:accountability-cross-community at icann.org>
> *Betreff:* Re: [CCWG-ACCT] CCWG-Accountability-WS2 - 27-28
> September Plenary Agenda and Materials - 1 of 2
>
> Dear all,
>
> Regarding *agenda point 8* and specifically the
> *dissenting opinion* attached to the Report from the
> Subgroup dealing with the Framework of Interpretation
> (FOI) of the Human Rights Core Value (see p. 2 of the
> attached document), which I have filed together with a
> number of colleagues, I would like to share some thoughts
> and a suggested path forward with the CCWG Plenary before
> the calls scheduled to discuss this.
>
> The main point of the dissent is, in my view, that we feel
> that the public comment period showed the existence of two
> schools of thought: some that favored maintaining the text
> sent to public comment “as is” (ALAC to a certain extent,
> and a number of different GNSO constituencies) and those
> (UK, BRZ, and CH) proposing some steps forward, especially
> in the recognition of the UN Guiding Principles (Ruggie
> Principles).
>
> However, again in our view, the discussions in the
> Subgroup did not yield a properly balanced result, which
> would have reflected at least some if not all of the
> positions and proposals made by the named Governments.
> This relates in particular, _that the FOI text should make
> stronger reference to the UN Guiding Principles as the
> most relevant voluntary international standard_. In our
> view, the Subgroup did not undertake an inclusive enough
> effort to determine if a compromise text could be
> formulated that would accommodate this position of the
> three governments.
>
> Therefore, I would like to _suggest that the CCWG Plenary
> could decide that some additional efforts to reaching a
> broader consensus on this important issue should be made_
> – a broader consensus that could be more inclusive of all
> views expressed during the public comment period.
>
> Hence, I would _suggest that the CCWG decides that the
> Report together with the dissent are sent back to the
> Subgroup with the request that a broader consensus
> solution is quickly sought within the coming e.g. 2 weeks
> after the Plenary call_.
>
> I hope this way to proceed may seem reasonable to you and
> obtain your support during the abovementioned call. I
> would be happy to answer any questions you may have and
> look forward to your feedback.
>
> For my part I’ll try hard to attend the Wednesday call,
> but I’m (physically) attending at the same time /the UN
> CSTD Working Group on Enhanced Cooperation/. Hence, I
> would be very thankful if this issue could be discussed on
> the Thursday call instead if possible.
>
> Kind regards
>
> Jorge
>
> *Von:*accountability-cross-community-bounces at icann.org
> <mailto:accountability-cross-community-bounces at icann.org>[mailto:accountability-cross-community-bounces at icann.org]
> *Im Auftrag von *Bernard Turcotte
> *Gesendet:* Donnerstag, 21. September 2017 18:05
> *An:* Accountability Cross Community
> <accountability-cross-community at icann.org
> <mailto:accountability-cross-community at icann.org>>
> *Betreff:* [CCWG-ACCT] CCWG-Accountability-WS2 - 27-28
> September Plenary Agenda and Materials - 1 of 2
>
> All,
>
> Please fins below and attached the agenda for the 27-28
> September plenary.
>
> As noted in an earlier email the Co-Chairs do not believe
> the plenary can get through all of these materials in a
> single two hour session and that it is imperative we do so
> this week given the timing constraints we are working
> under. As such an additional 2 hour plenary session has
> been added 28 September 1900 UTC (the original plenary
> meeting scheduled for 27 September 1300 UTC still stands).
>
> Also please note that given the large volume of documents
> we will be including these in two separate emails to avoid
> size limit issues for participants.
>
> Please do not hesitate to contact me if you have any
> questions or problems with the documents.
>
> Bernard Turcotte
>
> ICANN Staff Support to the CCWG-Accountability-WS2
>
> *Agenda for the CCWG-Accountability-WS2 Plenary of 27 and
> 28 September*
>
> **
>
> 1.Introduction, update to SOIs, reminder on standards of
> behavior
>
> 2.Review of Agenda
>
> 3.Administration
>
> 3.1.Review timeline.
>
> 3.2.Reminder of 27 October face to face in Abu Dhabi.
>
> 3.3.Reminder of High Interest sessions in Abu Dhabi
>
> 4.Legal Committee Update
>
> 4.1. Question sent to ICANN Legal on Ombudsman
> recommendation 8 regarding the independence of the
> proposed Ombuds Advisory Panel (questions sent directly to
> ICANN legal on approval of Co-chairs).
>
> 4.2.Transparency – at the 13 September meeting of the
> sub-group updated language for recommendations 2, 15 and
> 16 were considered. ICANN Legal advised that they would
> consider these and provide written feedback to the sub-group.
>
> 5.Point on Quorum (held over from last plenary)
>
> 6.Second Reading of the draft recommendations of the
> Diversity sub-group.
>
> o CCWG-Accountability-WS2-Diversity-DrafRecommendations-20170927
> (attached - same document as distributed to the 30
> August plenary)
>
> 7.First reading of the final recommendations of the SOAC
> Accountability sub-group.
>
> o CCWG-Accountability-WS2-SOACAcct-FinalReport-20170927
> (attached)
> o CCWG-Accountability-WS2-SOACAcct-FinalReport-RedLine-20170927
> (attached)
> o CCWG-Accountability-WS2-SOACAcct-AnalysisandResponsetoPublicComments-20170927
> (attached)
>
> 8.First reading of the final recommendations of the Human
> Rights sub-group.
>
> o CCWG-Accountability-WS2-HumanRight-FinalReportWithAdditions-20170927
> (attached)
> o CCWG-Accountability-WS2-HumanRights-PublicConsultation-May2017-Responses
> (attached)
>
> 9.First reading of the draft recommendation of the Ombuds
> sub-group (please note that the final report of the
> external review is provided as a separate file due to size
> issues)
>
> o CCWG-Accountability-WS2-Ombudsman-DrafRecommendations-20170927
> (attached in second email)
> o CCWG-Accountability-WS2-Ombudsman-ExternalReview-Final (attached
> in second email)
>
> 10.First reading of the draft recommendation of the Staff
> Accountability sub-group.
>
> o CCWG-Accountability-StaffAcct-DraftReport-20170927V1.6
> (attached in second email)
> o CCWG-Accountability-StaffAcct-DraftReport-TrnasmissionLetter-20170927
> (attached in second email)
>
> 11.AOB
>
> 12.Next Plenaries
>
> 12.1.Thursday 28 September 19:00UTC
>
> 12.2.Wednesday 4 October 0500 UTC (optional but please
> schedule)
>
> 12.3.Wednesday 11 October 1300 UTC (optional but please
> schedule)
>
> 12.4.Wednesday 18 October 1900UTC
>
> 13.Adjournment
>
>
> _______________________________________________
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>
>
>
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>
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>
>
>
>
> --
>
> Dr Paul Twomey
>
> Managing Director
>
> Argo P at cific
>
> US Cell: +1 310 279 2366
>
> Aust M: +61 416 238 501
>
> www.argopacific.com <http://www.argopacific.com>
>
>
>
> --
> Dr Paul Twomey
> Managing Director
> Argo P at cific
> US Cell: +1 310 279 2366
> Aust M: +61 416 238 501
> www.argopacific.com <http://www.argopacific.com>
--
Dr Paul Twomey
Managing Director
Argo P at cific
US Cell: +1 310 279 2366
Aust M: +61 416 238 501
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