FW: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working Group for Directory Services ( new Whois)

Benedetta Rossi bc-secretariat at icann.org
Thu Aug 8 11:55:34 UTC 2013


Dear BC Members,

 

Please see below an email sent by David Fares which did not come through to
the list due to an issue with the mailing list.

 

Thank you,

 

Kind Regards,

 

Benedetta Rossi

BC Secretariat

bc-secretariat at icann.org

https://community.icann.org/display/gnsobc/Home

www.bizconst.org

 

 

From: Fares, David 
Sent: Wednesday, August 07, 2013 10:04 AM
To: 'Smith, Bill'; bc-gnso at icann.org list
Subject: RE: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)

 

Colleagues,

 

We have been reviewing the BC comments and the very robust exchange among
members.  We would like to raise two issues which are fundamental to the
BC’s views.  We look forward to working with everyone to find a compromise
and a way forward.

 

1.       We have concerns regarding the focus on commercial versus
non-commercial sites.  Some sites may not have any commercial intent or
raise any revenues but they could still have a commercial impact on other
businesses.  Addressing this latter issue is essential to maintaining both
business and consumer trust in the Internet.  We are very sympathetic to the
need to protect political speech and are happy to work with members to
define an appropriate approach for the BC to advocate.  Perhaps it is better
to focus on the “reveal” rules for proxy services if the domain name is
commercial or has a commercial impact?

 

2.       We share concerns regarding access by authoritarian regimes but
wonder if, as drafted, the comments will create significant political
challenges for the BC going forward.  It could also put ICANN in a very
difficult political situation that could jeopardize its position as a
technical body.  We are not sure how we handle this but wanted to flag it
for consideration.

 

Thank you for your consideration and as mentioned we look forward to
discussing these comments.

 

David

 

 

From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of
Smith, Bill
Sent: Tuesday, August 06, 2013 4:58 PM
To: bc-gnso at icann.org list
Subject: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)

 

Thanks to all for the proposed language and willingness to come to an
agreement. i will defer to others on language and/or whether or not include
a statement on this issue or not. I think it unfortunate that we were driven
to such a rapid conclusion on this topic but that is where we are. 

On Aug 6, 2013, at 5:06 AM, Gabriela Szlak <gabrielaszlak at gmail.com> wrote:

 

Dear all, 

 

We would like to thank all BC members that are involved in these efforts,
particularly Susan who is a member of the EWG and the drafters of the
comment and proposed changes.

 

We support Marie´s compromise language for the ccTLDs issue and the approach
suggested by Marilyn. 

 

Regarding the security concerns we are not a technical organization but we
do recognize the security issues at stake are important and would like to
point out those issues with the best approach possible, counting on the
guidance of the expertise of other members of the group. In that light
Marie´s moderated version, if accepted by the group are fine with us. 

 

Thanks again for these efforts, 

Gabi

 

 

 

2013/8/6 Marilyn Cade <marilynscade at hotmail.com>


Thanks, Marie. I think this is a good approach.

Sent via BlackBerry by AT&T

-----Original Message-----

From: Marie Pattullo <marie.pattullo at aim.be>
Date: Tue, 6 Aug 2013 10:42:08
To: <stephvg at gmail.com>; <john at crediblecontext.com>
Cc: <susank at fb.com>; <jscottevans at yahoo.com>; <bill.smith at paypal-inc.com>;
<sdelbianco at netchoice.org>; <bc-gnso at icann.org>
Subject: RE: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
 Group for Directory Services ( new Whois)




Dear all,
 
I don't know the politics and history, but wonder if we can find a middle
ground: eventually we'd like the system to be the same everywhere, for
everyone. So for that long game, and to give us something to refer back to
without putting anyone on the spot right now, could we replace Stéphane's
suggestion with something more generic, e.g.:
 
"The BC looks forward to active involvement in this debate as it goes
forward and hopes that the entire community will work towards one unified
model for all registration data in the future, to the benefit of all
Internet users and the entire DNS industry."
 
Obviously deferring to John, Marilyn and the other experts here!
 
Marie
 


From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of
stephvg at gmail.com
Sent: mardi 6 août 2013 11:33
To: john at crediblecontext.com
Cc: Susan Kawaguchi; J. Scott Evans; Smith, Bill; Steve DelBianco;
bc-gnso at icann.org list
Subject: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)
 
Thanks John.

 

I really am not looking to light a fuse.

 

I am looking to address a problem that repeatedly vexes Internet users. They
just do not understand why they have to face such varying levels of WHOIS
format, complexity and operation in their daily domain-owning lives. And
they tend to own both cc and g domains regardless, according to their needs.

 

However as said before, I understand your concerns. Your suggestion to
approach Byron discreetly may be a good "diplomatic" move. I would support.

 

I would also support Marilyn's suggestion to check where the rest of the CSG
is on this issue.

 

Thanks,

 



Stéphane Van Gelder
Chairman and Managing Director/Fondateur
STEPHANE VAN GELDER CONSULTING

T (FR): +33 (0)6 20 40 55 89 <tel:%2B33%20%280%296%2020%2040%2055%2089> 

T (UK): +44 (0)7583 457053 <tel:%2B44%20%280%297583%20457053> 

Skype: SVANGELDER

www.StephaneVanGelder.com <http://www.stephanevangelder.com/>
<http://www.stephanevangelder.com/>
----------------

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Le 6 août 2013 à 03:02, john at crediblecontext.com
<mailto:john at crediblecontext.com>  a écrit :





Stephane,

 

As you know, I am not afraid to light a fuse, but make no mistake in my
judgement that this will be lighting a fuse.  Perhaps we can let Byron (new
chair of the ccNSO council know what we are up to.  I would be more than
happy to make the contact as he is Canadian and will likely take it politely
if not well.

 

Cheers,

 

Berard

 
--------- Original Message ---------

Subject: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)

From: stephvg at gmail.com <mailto:stephvg at gmail.com>

Date: 8/5/13 4:58 pm

To: "Susan Kawaguchi" <susank at fb.com <mailto:susank at fb.com> >
Cc: "J. Scott Evans" <jscottevans at yahoo.com <mailto:jscottevans at yahoo.com>
>, "john at crediblecontext.com <mailto:john at crediblecontext.com> "
<john at crediblecontext.com <mailto:john at crediblecontext.com> >, "Smith, Bill"
<bill.smith at paypal-inc.com <mailto:bill.smith at paypal-inc.com> >, "Steve
DelBianco" <sdelbianco at netchoice.org <mailto:sdelbianco at netchoice.org> >,
"bc-gnso at icann.org <mailto:bc-gnso at icann.org>  list" <bc-gnso at icann.org
<mailto:bc-gnso at icann.org> >


I understand the sentiments expressed by John and Susan.

 

However, I would think it a pity that the ICANN community as a whole once
again decides to shy away completely from any attempt at bringing some
common sense into the g and cc coexistence.

 

For me, at a time when so many ccs are either already behaving as gs or
about to manage some new gTLDs themselves, I think it is not unreasonable to
suggest that both namespaces look towards some way of finding a common
approach on registration data.

 

I also think that the BC, as the home of business in the ICANN ecosystem,
would be behaving in a responsible manner to its constituents by
highlighting this fact in this instance.

 

I believe the language I have suggested is soft enough not to appear
aggressive for cc managers.

 

So I would suggest we have a good opportunity here to get a common sense
message across.

 

Thanks,

 



Stéphane Van Gelder
Chairman and Managing Director/Fondateur
STEPHANE VAN GELDER CONSULTING

T (FR): +33 (0)6 20 40 55 89 <tel:%2B33%20%280%296%2020%2040%2055%2089> 

T (UK): +44 (0)7583 457053 <tel:%2B44%20%280%297583%20457053> 

Skype: SVANGELDER

www.StephaneVanGelder.com <http://www.stephanevangelder.com/>
<http://www.stephanevangelder.com/>
----------------

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Le 6 août 2013 à 00:58, Susan Kawaguchi <susank at fb.com
<mailto:susank at fb.com> > a écrit :

 




I agree with John, we have been very careful on the EWG to look at the
ccTlds and how they manage the domain name record data but our mandate did
not include looking at  ccTld registration data for this database.  I think
we already have a steep uphill climb for gTlds and we may want to leave the
ccTlds out of it for now.  




 

 

 

Susan Kawaguchi

Domain Name Manager

Facebook Legal Dept.

 

Phone - 650 485-6064 <tel:650%20485-6064> 

 

 

 

 

From: "J. Scott Evans" <jscottevans at yahoo.com <mailto:jscottevans at yahoo.com>
>
Reply-To: "J. Scott Evans" <jscottevans at yahoo.com
<mailto:jscottevans at yahoo.com> >

Date: Monday, August 5, 2013 3:52 PM

To: "john at crediblecontext.com <mailto:john at crediblecontext.com> "
<john at crediblecontext.com <mailto:john at crediblecontext.com> >, "Smith, Bill"
<bill.smith at paypal-inc.com <mailto:bill.smith at paypal-inc.com> >,
"stephvg at gmail.com <mailto:stephvg at gmail.com> " <stephvg at gmail.com
<mailto:stephvg at gmail.com> >
Cc: Steve DelBianco <sdelbianco at netchoice.org
<mailto:sdelbianco at netchoice.org> >, "bc-gnso at icann.org
<mailto:bc-gnso at icann.org>  list" <bc-gnso at icann.org
<mailto:bc-gnso at icann.org> >

Subject: Re: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert
Working Group for Directory Services ( new Whois)

 




John:

 

Thanks for the comment.  That's just the kind of dialogue I am looking for
here.  Others?

 

J. Scott

 

 

 

j. scott evans -  head of global brand, domains & copyright - Yahoo! Inc. -
408.349.1385 - jscottevans at yahoo.com <mailto:jscottevans at yahoo.com>

 

 

 




----------------

From: "john at crediblecontext.com <mailto:john at crediblecontext.com> "
<john at crediblecontext.com <mailto:john at crediblecontext.com> >
To: J. Scott Evans <jscottevans at yahoo.com <mailto:jscottevans at yahoo.com> >;
"Smith, Bill" <bill.smith at paypal-inc.com <mailto:bill.smith at paypal-inc.com>
>; stephvg at gmail.com <mailto:stephvg at gmail.com>
Cc: Steve DelBianco <sdelbianco at netchoice.org
<mailto:sdelbianco at netchoice.org> >; "bc-gnso at icann.org
<mailto:bc-gnso at icann.org>  list" <bc-gnso at icann.org
<mailto:bc-gnso at icann.org> >

Sent: Monday, August 5, 2013 3:37 PM
Subject: RE: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert
Working Group for Directory Services ( new Whois)

 


J. Scott, et. al.,

 

With regard to whether it will be a political bombshell or not, I cannot
say, but as the GNSO Council liaison to the ccNSO Council I have come to
appreciate the bright line they draw between the "g" and the "cc" name
space.  I suspect that even if Stephane's suggestion would not be the
incendiary device you foretell, it would be a distraction from the more
urgent matter of solving the directory services problem for the the gTLDs.
I would vote not to include the language.

 

My two cents.

 

Berard

 
--------- Original Message ---------

Subject: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)

From: "J. Scott Evans" <jscottevans at yahoo.com <mailto:jscottevans at yahoo.com>
>

Date: 8/5/13 3:25 pm

To: "Smith, Bill" <bill.smith at paypal-inc.com
<mailto:bill.smith at paypal-inc.com> >, stephvg at gmail.com
<mailto:stephvg at gmail.com>
Cc: "Steve DelBianco" <sdelbianco at netchoice.org
<mailto:sdelbianco at netchoice.org> >, "bc-gnso at icann.org
<mailto:bc-gnso at icann.org>  list" <bc-gnso at icann.org
<mailto:bc-gnso at icann.org> >



Dear All:

 

I have reviewed Bill's emails, his comments and those added by Stephane.  I
am fine with Stephane's comments so long as we all feel this wouldn't be a
political bombshell (however realistic and practical it may be).

 

As for Bill's suggestion about "entities".  I have attempted to suggest
language that I think assuage my concerns.  Bill?

 

J. Scott

 

 

j. scott evans -  head of global brand, domains & copyright - Yahoo! Inc. -
408.349.1385 - jscottevans at yahoo.com <mailto:jscottevans at yahoo.com>

 

 

 




----------------

From: "Smith, Bill" <bill.smith at paypal-inc.com
<mailto:bill.smith at paypal-inc.com> >
To: "<stephvg at gmail.com <mailto:stephvg at gmail.com> >" <stephvg at gmail.com
<mailto:stephvg at gmail.com> >

Cc: J. Scott Evans <jscottevans at yahoo.com <mailto:jscottevans at yahoo.com> >;
"Smith, Bill" <bill.smith at paypal-inc.com <mailto:bill.smith at paypal-inc.com>
>; Steve DelBianco <sdelbianco at netchoice.org
<mailto:sdelbianco at netchoice.org> >; "bc-gnso at icann.org
<mailto:bc-gnso at icann.org>  list" <bc-gnso at icann.org
<mailto:bc-gnso at icann.org> >

Sent: Monday, August 5, 2013 12:37 PM
Subject: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)

 



I have attached an updated version. I'm quite happy with Stephane's addition
but would ask J. Scott to offer alternative language for "entities" and to
look with Yahoo to get a better understanding of the complexity and
difficulty of operating a large-scale directory infrastructure, especially
one that is by its nature sensitive.

 

(see my comments within J Scott's comments)


 

Any move from a freely available public WHOIS system to one that is mediated
and subject to access controls requires careful consideration. Implementing
a secure, internet-scale, global directory for "accredited" security
professionals will be no small task.




 

 






 

 

On Aug 5, 2013, at 11:50 AM, <stephvg at gmail.com <mailto:stephvg at gmail.com> >


 wrote:
 


I have added to J Scott's latest redraft a bit at the end about the
possibility of extending this work to the cc space.

 

The wording is not perfect IMO, but hopefully the intent is clear.

 

Thanks,

 

 


 

 



Stéphane Van Gelder
Chairman and Managing Director/Fondateur
STEPHANE VAN GELDER CONSULTING

T (FR): +33 (0)6 20 40 55 89 <tel:%2B33%20%280%296%2020%2040%2055%2089> 

T (UK): +44 (0)7583 457053 <tel:%2B44%20%280%297583%20457053> 

Skype: SVANGELDER

www.StephaneVanGelder.com <http://www.stephanevangelder.com/>
<https://urldefense.proofpoint.com/v1/url?u=http://www.stephanevangelder.com
/
<https://urldefense.proofpoint.com/v1/url?u=http://www.stephanevangelder.com
/&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5x
qQTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=39
6c77079583c49e46abef00845888658b07005e75d215b90ece8f0b321629b3>
&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xq
QTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=396
c77079583c49e46abef00845888658b07005e75d215b90ece8f0b321629b3>
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Le 5 août 2013 à 18:58, "J. Scott Evans" <jscottevans at yahoo.com
<mailto:jscottevans at yahoo.com> > a écrit :

 



Bill and team:

 

I have re-reviewed the draft with Bill's suggested revisions.  I have
attached a redline showing my thoughts on top of Bill's suggested edits.

 

J. Scott

 

 

j. scott evans -  head of global brand, domains & copyright - Yahoo! Inc. -
408.349.1385 - jscottevans at yahoo.com <mailto:jscottevans at yahoo.com>

 

 

 




----------------

From: "Smith, Bill" <bill.smith at paypal-inc.com
<mailto:bill.smith at paypal-inc.com> >

To: "stephvg at gmail.com <mailto:stephvg at gmail.com> " <stephvg at gmail.com
<mailto:stephvg at gmail.com> >
Cc: Steve DelBianco <sdelbianco at netchoice.org
<mailto:sdelbianco at netchoice.org> >; "bc-gnso at icann.org
<mailto:bc-gnso at icann.org>  list" <bc-gnso at icann.org
<mailto:bc-gnso at icann.org> >

Sent: Monday, August 5, 2013 9:12 AM
Subject: Re: [bc-gnso] FOR REVIEW BY 11-AUG: BC comments on Expert Working
Group for Directory Services ( new Whois)

 



+1

 

Attached is a marked up version of the document. I have attempted to replace
web and website with Internet and service (generally) and hope that my
changes read properly. I believe it important to make the distinction
between the web and Internet since the ARDS is used for much more than the
web.

 

I also included some comments and additions that I believe are necessary to
include. In particular, I disagree with the assertion that there is no
foundation for the belief that the scale of the ARDS make it vulnerable.
Internet entities are vulnerable regardless of size but as they grow, they
become increasingly attractive targets. ARDS will be attractive - or the
Registrar community has been disingenuous about the scale of SPAM, customer
loss, etc. that results from harvesting information via WHOIS.

 

I have also added text related to Gated Access and concerns related to data
aggregation and operation of such a critical resource necessarily dependent
on PII of security professionals. These individuals face very real risks
given the work they do, those they "oppose", and the penalties imposed for
crimes they uncover.

 

I hope we will consider the changes I have proposed.


 

 



 


 

On Aug 3, 2013, at 3:51 PM, stephvg at gmail.com <mailto:stephvg at gmail.com>
wrote:
 

Thank you Steve, Laura, Susan, J Scott and Elisa for a well drafted document
that I believe is perfectly inline with business users interests as defined
by our charter.

 

If I might make a suggestion, even though it's out of scope of the EWG's
work, I would love to see something in our opening comments about the fact
that if the RDS model is adopted (or another unified model for managing gTLD
registration data), it would be extremely beneficial for Internet users
worldwide if ccTLD registries were also willing to work towards the adoption
of the same, single-format, model.

 

I think it's useful for commentors to the EWG's draft report to make this
point, even though ccTLD managers abide by their own national laws and ways
of doing things, because we all have a lot to gain from a more effective and
more uniform registration data database.

 

Apart from that suggestion, I have no other comments. The draft seems spot
on to me and is supported by SVG Consulting Ltd.

 

Thanks,

 



Stéphane Van Gelder
Chairman and Managing Director/Fondateur
STEPHANE VAN GELDER CONSULTING

T (FR): +33 (0)6 20 40 55 89 <tel:%2B33%20%280%296%2020%2040%2055%2089> 

T (UK): +44 (0)7583 457053 <tel:%2B44%20%280%297583%20457053> 

Skype: SVANGELDER

www.StephaneVanGelder.com <http://www.stephanevangelder.com/>
<https://urldefense.proofpoint.com/v1/url?u=http://www.stephanevangelder.com
/
<https://urldefense.proofpoint.com/v1/url?u=http://www.stephanevangelder.com
/&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5x
qQTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=39
6c77079583c49e46abef00845888658b07005e75d215b90ece8f0b321629b3>
&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xq
QTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=396
c77079583c49e46abef00845888658b07005e75d215b90ece8f0b321629b3>
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Le 3 août 2013 à 17:53, Steve DelBianco <sdelbianco at netchoice.org
<mailto:sdelbianco at netchoice.org> > a écrit :

 




It's time for the BC to comment on the draft model for Next Generation gTLD
Directory Services. 

 

The Expert Working Group (EWG) published its draft report here
<https://urldefense.proofpoint.com/v1/url?u=https://www.icann.org/en/groups/
other/gtld-directory-services/initial-report-24jun13-en.pdf
<https://urldefense.proofpoint.com/v1/url?u=https://www.icann.org/en/groups/
other/gtld-directory-services/initial-report-24jun13-en.pdf&k=ZVNjlDMF0FElm4
dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xqQTlAKzPo%3D%0A&m=
RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=3ee5d59a43ea0734285f
08b830a85f0098008efd56d42a979e9c2ebd5f42949b>
&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xq
QTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=3ee
5d59a43ea0734285f08b830a85f0098008efd56d42a979e9c2ebd5f42949b> . 





 

Public comment page is here
<https://urldefense.proofpoint.com/v1/url?u=http://www.icann.org/en/groups/o
ther/gtld-directory-services/share-24jun13-en.htm
<https://urldefense.proofpoint.com/v1/url?u=http://www.icann.org/en/groups/o
ther/gtld-directory-services/share-24jun13-en.htm&k=ZVNjlDMF0FElm4dQtryO4A%3
D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xqQTlAKzPo%3D%0A&m=RaYn95eM%2
B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=52b62dd77d2bdf7019087cd723969e
c9858c98b1e503d06e3aa13aed7c5ff404>
&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xq
QTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=52b
62dd77d2bdf7019087cd723969ec9858c98b1e503d06e3aa13aed7c5ff404>  and the EWG
Wiki page is here
<https://urldefense.proofpoint.com/v1/url?u=https://community.icann.org/disp
lay/WG/Explore%2Bthe%2BDraft%2BNext%2BGeneration%2BgTLD%2BDirectory%2BServic
es%2BModel
<https://urldefense.proofpoint.com/v1/url?u=https://community.icann.org/disp
lay/WG/Explore%2Bthe%2BDraft%2BNext%2BGeneration%2BgTLD%2BDirectory%2BServic
es%2BModel&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc
%2FGWno5xqQTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3
D%0A&s=b8461cf7b2005648feb89c930fe68ae0efe7ec587ac269aeb035a526115cb64f>
&k=ZVNjlDMF0FElm4dQtryO4A%3D%3D%0A&r=RfTjtTQBKN%2BQcoX4JkHSqqoeuEc%2FGWno5xq
QTlAKzPo%3D%0A&m=RaYn95eM%2B3xlzmZ4%2FBnEsjNbeHw02IY86kkEIblkK58%3D%0A&s=b84
61cf7b2005648feb89c930fe68ae0efe7ec587ac269aeb035a526115cb64f> .


 


Laura Covington prepared the attached draft of BC comments, with help from
Susan Kawaguchi, J Scott Evans, and Elisa Cooper.

 









 

The comment period closes 12-Aug-2013, so please Reply All before 11-Aug
with edits or questions.  

 









--
Steve DelBianco





Vice chair for policy coordination
  Business Constituency

 


 
<BC Comments - EWG Draft Model [v1].doc>
<BC Comments - EWG Draft Model [v1] -JSE2.doc>
<BC Comments - EWG Draft Model [v1] -JSE2-SVG.doc>
 
 
 





 

-- 

Gabriela Szlak 

 <http://www.clared.co/> www.clared.co

 <http://www.estudiorosz.com.ar/> www.estudiorosz.com.ar  

 <http://www.einstituto.com.ar/> www.einstituto.org 

 <http://www.gabrielaszlak.com.ar/> www.gabrielaszlak.com.ar 

 

Skype: gabrielaszlak

Twitter: @GabiSzlak

 

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The information in this e-mail is confidential.

 

 


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