[bc-gnso] Outline for discussion of RAA comments today

Hansen, Anjali AHansen at council.bbb.org
Thu May 2 15:21:56 UTC 2013

That's okay Gabi, we'll circulate comments after this call and you can still provide feedback.

Anjali Karina Hansen  Deputy General Counsel

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From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of gabrielaszlak at gmail.com
Sent: Thursday, May 02, 2013 10:46 AM
To: Steve Delbianco; owner-bc-gnso at icann.org; bc - GNSO list
Subject: Re: [bc-gnso] Outline for discussion of RAA comments today

Dear all,

Steve: thanks so much as always for the excellent work and the useful and organized information you send to facilitate our analysis and interchange of ideas.

My apologies to all: I will have to follow this issue through the transcripts as something urgent has just came up and I cannot participate today.


Gabriela Szlak
Enviado desde mi BlackBerry de Movistar (http://www.movistar.com.ar)
From: Steve DelBianco <sdelbianco at netchoice.org<mailto:sdelbianco at netchoice.org>>
Sender: owner-bc-gnso at icann.org<mailto:owner-bc-gnso at icann.org>
Date: Thu, 2 May 2013 14:26:16 +0000
To: 'bc - GNSO list'<bc-gnso at icann.org<mailto:bc-gnso at icann.org>>
Subject: [bc-gnso] Outline for discussion of RAA comments today

Here's an outline for today's member discussion of BC comments on the RAA.  (11am eastern US time)

Public Comment page is here<http://www.icann.org/en/news/public-comment/proposed-raa-22apr13-en.htm>.   The proposed final RAA is here<http://www.icann.org/en/resources/registrars/raa/proposed-agreement-22apr13-en.pdf%20>. Initial comments due 13-May

1. Privacy/Proxy Specification (link<http://www.icann.org/en/resources/registrars/raa/proposed-registrant-rights-responsibilities-22apr13-en.pdf>)
There is no Service level specified for timing and methods to relay communications and reveal data to complainant.

2. Whois
Maintain bulk access to Whois (port 43)

"Willful provision of inaccurate or unreliable whois information" as basis to suspend a registration (

If Registrant data isn't validated in 15 days, should registrations be suspended during manual validation?

Should same accuracy requirement apply to Account Holder data as well?

3. Enforcement of Registrant Rights (link<http://www.icann.org/en/resources/registrars/raa/proposed-registrant-rights-responsibilities-22apr13-en.pdf>), in particular:
"You shall not be subject to false advertising or deceptive practices by your Registrar or though any proxy or privacy services made available by your Registrar. This includes deceptive notices, hidden fees, and any practices that are illegal under the consumer protection law of your residence."

Do we need additional clarity in order to enforce Registrar obligations?   Proposed RAA says:
RAA 3.7.10     Registrar shall publish on its website(s) and/or provide a link to the Registrants' Rights and Responsibilities Specification attached hereto and shall not take any action inconsistent with the corresponding provisions of this Agreement or applicable law.

Note: during the Beijing meeting, ICANN attorney Samantha Eisner told the BC that Public comment would be particularly valuable in these areas:
Registrant rights & responsibilities.  This was drafted by registrars.
Validation of registrant data (registrant and account holder?)
Penalties for inaccurate data
Registrars want to drop Port 43 access for thick registries
Unilateral amendment by ICANN.

Steve DelBianco
Executive Director
http://www.NetChoice.org and http://blog.netchoice.org

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