[bc-gnso] FOR FINAL APPROVAL: draft BC comment on proposed final 2013 RAA (Registrar Accreditation Agreement)

Chris Chaplow chris at andalucia.com
Wed May 29 16:26:41 UTC 2013



Chris Chaplow
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E-mail:  <mailto:chris at andalucia.com> chris at andalucia.com
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Information about Andalucia, Spain.


De: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] En nombre de
Angie Graves
Enviado el: miércoles, 29 de mayo de 2013 18:16
Para: Ron Andruff
CC: Steve DelBianco; Bc GNSO list; Hansen, Anjali
Asunto: Re: [bc-gnso] FOR FINAL APPROVAL: draft BC comment on proposed final
2013 RAA (Registrar Accreditation Agreement)


Thank you, Steve et al, for the draft, which I support.



Angie Graves


On Wed, May 29, 2013 at 11:40 AM, Ron Andruff <randruff at rnapartners.com>

Thanks to the drafters for their hard work!


RNA Partners supports this final document.


Kind regards,




Ronald N. Andruff

RNA Partners, Inc. <http://www.rnapartners.com> 


From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of
Steve DelBianco
Sent: Tuesday, May 28, 2013 10:27 PM
To: bc-gnso at icann.org
Cc: Hansen, Anjali
Subject: [bc-gnso] FOR FINAL APPROVAL: draft BC comment on proposed final
2013 RAA (Registrar Accreditation Agreement)


On the 22-May BC member call we discussed final changes to the BC comment
draft, to address whether registrars would be obligated to sign an updated


Anjali Hansen and Elisa Cooper updated the draft with this paragraph (on
page 2):


Section 5.3 -- “Right to Substitute Updated Agreement”  -- provides for the
possibility that ICANN will enter into a revised “form Registrar
accreditation agreement” into which a registrar could “elect” to enter.  The
procedure for updating the RAA appears to be on a different track from the
amendment process and the BC requests more information on this process and
wishes to understand the repercussions of having some registrars elect to
enter into a new agreement while others might elect to stay with the current
accreditation agreement.   


Please do your final review by 30-May-2013 so that we can submit to ICANN.
Any objections or edits should be sent as Reply to All. 


Thanks again to Anjali Hansen, Elisa Cooper, Susan Kawaguchi, and others for
work on this draft.




From: Steve DelBianco <sdelbianco at netchoice.org>
Date: Tuesday, May 14, 2013 7:45 AM
To: "bc-gnso at icann.org" <bc-gnso at icann.org>
Cc: "Hansen, Anjali" <AHansen at council.bbb.org>
Subject: FOR REVIEW: draft BC comment on proposed final 2013 RAA (Registrar
Accreditation Agreement)


ICANN has posted the proposed final 2013 RAA (Registrar Accreditation
Agreement) for public comment. (link
<http://www.icann.org/en/news/public-comment/proposed-raa-22apr13-en.htm> ) 


Anjali Hansen admirably volunteered to draft BC comments.  Several BC
members provided input, including Ron Andruff, Bill Smith, Susan Kawaguchi,
Zahid Jamil, and Elisa Cooper.  


We held a conference call on this topic on 2-May where many others provided
ideas. (call minutes
s+call+MAY+02+2013.pdf?version=1&modificationDate=1368100389000%20>  and
f?version=1&modificationDate=1368100411000>  )


Still, Anjali shows several pending questions in the attached draft.   We
need further help from BC members with direct experience dealing with
registrars and privacy/proxy providers.


Comment period closes 4-Jun.   That allows our regular 14-day review and
approval period.  So, please REPLY ALL with your suggested edits and
comments regarding this draft, before 28-May-2013.


Steve DelBianco

Vice chair for policy coordination

Business Constituency



From: owner-bc-gnso at icann.org [mailto:owner-bc-gnso at icann.org] On Behalf Of
Steve DelBianco
Sent: Monday, April 08, 2013 2:54 AM
To: 'bc - GNSO list'
Subject: [bc-gnso] Notes from Monday 8-April Beijing session on new RAA


ICANN staff just spent an hour answering BC questions about the new RAA
(registrar Accreditation Agreement).


The main element of controversy is the process for ICANN to amend the RAA.
On 2-April, ICANN proposed a new amendment process (link
nt-process-02apr13-en.pdf> )


The notes below may be helpful for volunteers Anjali Hansen and Zahid Jamil,
who volunteered last week to draft BC  comments on the new RAA.


Law enforcement items were first priority for negotiation.  ICANN says the
LEA items are agreed by registrars, so ICANN added a dozen “new asks”, incl:

- EBERO, Registrant Rights, data escrow, abuse contact, 

- obligations for registrars using Resellers, 

- greater compliance tools, incl provision that “pattern or practice of
cybersquatting” is grounds for termination )


Made progress on privacy /proxy services (P/P) since Toronto.   Temporary
P/P specification while ICANN develops accreditation program.   In response
to a compliance question, Samantha said the P/P Spec sets high level
principles that are actually easy to enforce.   At my request, Susan
Kawaguchi is drafting BC comment on just this specification since she has
significant experience with P/P issues.


I asked about delay to the P/P accreditation in light of the Expert Group on
Directory Services.   Samantha said that Registrars truly want ICANN to do a
P/P accreditation program so it would apply to all P/P providers – not just
those affiliated with Registrars who have to sign the RAA.


RAA will be a model document, so its not subject to negotiation with each
registrar (except for bilateral amendments).  So negotiations won’t be a
bottleneck for getting registrars on-board.


I asked whether the RAA needed exceptions for registrars created just to
service a dot-brand gTLD.  (single registrant, single-user) Such as
transition on termination; Rights to data; transfers, etc.    Staff and BC
members could not come up with concerns that would call for exceptions.


Public comment would be 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.  See Cyrus blog on 2-Apr


Ron Andruff asked if the next iteration of the RAA will be posted for public
comment.  Answer was not definitive, so I asked Ron to draft a couple
paragraphs of rationale for BC comments. 



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