[CWG-RFP3] Is there is a more suitable legal jurisdiction for anIANA subsidiary?

Fri Nov 7 03:39:31 UTC 2014

INdeed, I think this is a pretty important caveat.  But it seems to me, 
without wishing to drag the argument around in circles, it is important 
when designing a legal entity, to understand the legal requirements that 
apply....and how do you do that if you don't decide on a jurisdiction?  
There is certainly a wide choice of jurisdictions with different 
norms....and how do we know California is the best?  Would it not be 
helpful to have a look at some of the jurisdictional variations rather 
than just assume all is ok? Without understand the variations, we can 
hardly establish the business requirements.
Stephanie Perrin
On 2014-11-06, 12:12, Burr, Becky wrote:
> I agree with one caveat -- to the extent people think that creating a 
> separate legal entity actually fixes jurisdictional concerns, 
> understanding whether or not that is true is directly relevant to our 
> ultimate recommendation, no?
>
> J. Beckwith Burr
>
> *Neustar, Inc. /* Deputy General Counsel and Chief Privacy Officer
>
> 1775 Pennsylvania Avenue NW, Washington, DC 20006
>
> Office: + 1.202.533.2932  Mobile: +1.202.352.6367 / 
> becky.burr at neustar.biz <mailto:becky.burr at neustar.biz> / www.neustar.biz
>
>
> From: <Lindeberg>, Elise <elise.lindeberg at npt.no 
> <mailto:elise.lindeberg at npt.no>>
> Date: Wednesday, November 5, 2014 at 11:18 PM
> To: Greg Shatan <gregshatanipc at gmail.com 
> <mailto:gregshatanipc at gmail.com>>, Becky Burr <becky.burr at neustar.biz 
> <mailto:becky.burr at neustar.biz>>
> Cc: "cwg-rfp3 at icann.org <mailto:cwg-rfp3 at icann.org>" 
> <cwg-rfp3 at icann.org <mailto:cwg-rfp3 at icann.org>>
> Subject: SV: [CWG-RFP3] Is there is a more suitable legal jurisdiction 
> for anIANA subsidiary?
>
> All,
>
> Greg - following this discussion on jurisdiction is really intense. As 
> it stands now I agree with most of your perspective, and your conclusion
>
> ///9. I started with scope, and I'll end with it.  If we recommend a 
> corporate IANA, Inc., it would be helpful but not entirely necessary 
> to recommend a jurisdiction.  We could be silent on it.  If (from the 
> point of view of stewardship/accountability) California is a bad 
> choice, it would be helpful to know it.  But this is only one facet 
> (or "variable") of our work (and a sub-variable at that).  We should 
> manage our time accordingly./
>
> If I understand you correctly -  I  agree that CWG can have 
> discussions and recommendations in regards of IANA as a separate legal 
> entity and establishment of an Oversight Body/Mechanism as a separate 
> legal entity  - WITHOUT going into details on the complicated issue of 
> jurisdiction of ICANN/IANA
>
> Kind regards
>
> Elise
>
> *Fra:*cwg-rfp3-bounces at icann.org <mailto:cwg-rfp3-bounces at icann.org> 
> [mailto:cwg-rfp3-bounces at icann.org] *På vegne av* Greg Shatan
> *Sendt:* 5. november 2014 22:00
> *Til:* Burr, Becky
> *Kopi:* cwg-rfp3 at icann.org <mailto:cwg-rfp3 at icann.org>
> *Emne:* Re: [CWG-RFP3] Is there is a more suitable legal jurisdiction 
> for anIANA subsidiary?
>
> A few comments on this very active thread:
>
> 1.  We have to be careful about scope.  I would like to be liberal in 
> what we discuss, but balance that against getting bogged down in 
> tangential discussions.  I don't think that changing the jurisdiction 
> of *ICANN* is within the scope of our work.  (Though it is an 
> endlessly fascinating topic.)
>
> 2.  On the other hand, it is possible that we could recommend the 
> establishment of *IANA* as a separate legal entity.  I say that 
> without judgment on the likelihood or advisability of that move, but 
> it is clearly "on the table" for discussion.  If IANA is a separate 
> legal entity it may be created as a wholly-owned subsidiary of ICANN 
> (at least until some triggering accountability event causes that to 
> change).  It is also possible that IANA could be a wholly independent 
> entity and not a subsidiary of ICANN (FYI, it is my understanding that 
> California non-profits can have subsidiaries. By contrast, New York 
> non-profits apparently cannot.)
>
> 3.  It is also possible that we could recommend the establishment of 
> an Oversight Body as a separate legal entity.
>
> 4.  Given the above, I would support some exploration of the pro's and 
> con's of using a California non-profit as an entity, in contrast to a 
> US non-profit corporation formed in another U.S. state, an entity 
> formed in another country, or an unincorporated association.  I agree 
> with Becky and others that getting information from an independent, 
> neutral and knowledgeable source would be extremely helpful.  (I am a 
> practicing lawyer, but I am not licensed to practice in California.  I 
> sometimes work with non-profits, but I am by no means a non-profit law 
> specialist.)
>
> 5.  As Becky said, issues of jurisdiction are complex.  They are also 
> multi-faceted.  There are issues of domicile (physical location), 
> state of incorporation (legal location), choice of law (what law 
> applies to a particular contract), and jurisdiction (where an action 
> may be brought by or against an entity).  It would not be uncommon to 
> find a corporation located in New York, incorporated in Delaware, 
> entering into a contract subject to the laws of Texas (or France).  
> Based on facts and circumstances, it could be possible to sue that 
> corporation in any number of place (both those places named and other 
> places). Immunity from jurisdiction (in the sense of efforts to not be 
> "sue-able" in a particular place) is a separate issue, but one that 
> could influence decisions on each of the above issues. Some quality 
> information on California law would help.  Unless we find some real 
> problems with California law and domicile, spending a lot of time on 
> finding another place for an IANA, Inc. that may or may not exist on 
> Day 1 would be misguided.
>
> 6.  To clarify one point of California non-profit law that I am fairly 
> sure of -- a California non-profit (technically, called a "public 
> benefit corporation") may have members, but the law does not 
> presuppose that a California non-profit will have members.  This is a 
> choice that should be made at the time of incorporation (though it can 
> be changed later), and is based on the nature of the organization.  
> Some types of organizations are clearly membership organizations 
> (fraternal organizations, clubs, etc.), others are clearly not, others 
> can go either way.  That said, this is much more germane to the 
> CWG-Accountability mandate. Unless we are going to consider making 
> IANA a membership corporation... (!)
>
> 7.  With regard to Kieren's email, the interpretation of any law 
> (California law or otherwise) can be colored by who the client is and 
> who the audience is.  Advice that a lawyer gives to his/her client 
> about what the law says (or the range of interpretations of the law) 
> will differ from the position that the lawyer (or their client) takes 
> when discussing the law and its interpretation with third parties.  
> The first should be objective; the second is almost always going to be 
> subjective (either expressly or implicitly, it will be an "advocacy" 
> piece).  ICANN's lawyers are going to be advocates for positions that 
> benefit ICANN.  Asking them to give neutral advice or advice on how to 
> counter ICANN is fraught with peril (for the lawyers as well as those 
> taking the advice).  Of course, this is complicated by the question of 
> "Who is ICANN?" (the corporation, the community, the corporation plus 
> the SO's and AC's?)  But the bottom line is -- if you hire a lawyer, 
> you should expect straight-shooting advice on the law from that 
> lawyer; if you listen to somebody else's lawyer, there is no reason 
> whatsoever to expect straight-shooting advice.
>
> 8.  "International Organizations" are very rare (almost 
> non-existent).  Virtually all organizations have a legal "home" in a 
> particular country (and in U.S., in a particular state of the U.S.).  
> If you look at the first link Robert circulated, the Convention on 
> Legal Personality of INGOs presupposes that an INGO has a legal home 
> in one (and only one) member state.  The IOC is (I believe) a Swiss 
> entity. The International Committee of the Red Cross is a Swiss 
> entity, but one created by the Geneva Convention.  There may be a few 
> other treaty-based INGOs, but by and large INGOs have a legal "home" 
> jurisdiction.  It is their *activities* that are international, not 
> their domicile/state of incorporation.  Again, this is more of an 
> issue for CWG-Accountability (if it is an issue at all).
>
> 9.  I started with scope, and I'll end with it.  If we recommend a 
> corporate IANA, Inc., it would be helpful but not entirely necessary 
> to recommend a jurisdiction.  We could be silent on it.  If (from the 
> point of view of stewardship/accountability) California is a bad 
> choice, it would be helpful to know it.  But this is only one facet 
> (or "variable") of our work (and a sub-variable at that).  We should 
> manage our time accordingly.
>
> Greg
>
> On Wed, Nov 5, 2014 at 2:07 PM, Burr, Becky <Becky.Burr at neustar.biz 
> <mailto:Becky.Burr at neustar.biz>> wrote:
>
> The group of organizations working on the NGO Accountability Charter in
> the link Robert just sent around is very instructive:
>
> ActionAid International,
> Amnesty International
> Caritas Internationalis
> Care International
> CBM International
> CIVICUS World Alliance for Citizen Participation,
> CORDAID
> European Environmental Bureau
> Greenpeace International
> Educo
> IRC (International Water & Sanitation Centre)
> Oxfam International
> Plan International
> Sightsavers International
> SOS Kinderdorf International
> The Forest Trust
> World Vision International
> World YWCA
>
> These organizations may all be doing important work but - UNLIKE ICANN -
> they are NOT regulating commercial behavior. If I don¹t like what
> Greenpeace is doing, I won¹t make a contribution. But I can¹t operate a
> top level domain or sell registrations in .com without paying ICANN and
> complying with the policies it imposes.  It seems fairly obvious to me
> that ICANN should be held to a different accountability standard.
>
> B
>
>
> J. Beckwith Burr
> Neustar, Inc. / Deputy General Counsel and Chief Privacy Officer
> 1775 Pennsylvania Avenue NW, Washington, DC 20006
> Office: + 1.202.533.2932 <tel:%2B%201.202.533.2932> Mobile: 
> +1.202.352.6367 <tel:%2B1.202.352.6367> /
> becky.burr at neustar.biz <mailto:becky.burr at neustar.biz> / 
> www.neustar.biz <http://www.neustar.biz>
>
>
>
>
>
> On 11/5/14, 12:43 PM, "Robert Guerra" <rguerra at privaterra.org 
> <mailto:rguerra at privaterra.org>> wrote:
>
> >-----BEGIN PGP SIGNED MESSAGE-----
> >Hash: SHA512
> >
> >Kieren,
> >
> >Let me share two quick links that I was able to to find that could be
> >of interest in regards providing more details about International
> >Non-Governmental Organizations and what seems to be best practices
> >that others are working on in regards to accountability.
> >
> >Links below..
> >
> >regards
> >
> >Robert
> >
> >European Convention on the Recognition of the Legal Personality of
> >International Non-Governmental Organizations
> >
> >
> >http://en.wikipedia.org/wiki/European_Convention_on_the_Recognition_of_the 
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__en.wikipedia.org_wiki_European-5FConvention-5Fon-5Fthe-5FRecognition-5Fof-5Fthe&d=AAMGaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=M4a9b8Uq2KA4oDOk0euAXMT1PLI3HMRhgFBQlTBhDc4&s=FiMndWp1vroW1qGxrv6ABZaFAf9BlWFLGnfMG3QN2Hs&e=>
> >_Legal_Personality_of_International_Non-Governmental_Organizations
> >
> >http://www.uia.org/archive/legal-status-4-11 
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.uia.org_archive_legal-2Dstatus-2D4-2D11&d=AAMGaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=M4a9b8Uq2KA4oDOk0euAXMT1PLI3HMRhgFBQlTBhDc4&s=drUw-IhVkEgp-KdwSvttFUSwyyGHSir9Bys9so65gfk&e=>
> >
> >International Non-Governmental Organisations Accountability Charter
> >http://en.wikipedia.org/wiki/International_Non-Governmental_Organisations_ 
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__en.wikipedia.org_wiki_International-5FNon-2DGovernmental-5FOrganisations-5F&d=AAMGaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=M4a9b8Uq2KA4oDOk0euAXMT1PLI3HMRhgFBQlTBhDc4&s=N_aExfsThjw9FUJh41QgfEQDUj8sUmpvxXXjkmYrLn0&e=>
> >Accountability_Charter
> >
> >The International Non-Governmental Organisations Accountability
> >Charter (INGO Accountability Charter) is a charter, founded in 2006 by
> >a group of independent non-profit organisations, which is intended to
> >foster accountability and transparency of non-governmental
> >organisations, as well as stakeholder communication and performance.
> >
> >
> >
> >
> >
> >On 2014-11-05 12:30 PM, Kieren McCarthy wrote:
> >> I'm finding this conversation thread very frustrating.
> >>
> >> If this is a topic being seriously considered - and it looks like
> >> it is. And if none of us are in any way qualified to provide a
> >> cogent analysis - which it looks like we aren't. Then surely the
> >> obvious solution is to find someone, or some group, that can
> >> provide some answers to questions.
> >>
> >> Based purely on human nature, I strongly suspect that the argument
> >> that California is some how a special place for ICANN/IANA is more
> >> to do with it being the status quo than any verifiable reality.
> >>
> >> It is possible that IANA would be better placed in another
> >> jurisdiction - although since we have failed to draw up any grounds
> >> by which that judgment would be made, the whole conversation seems
> >> a little pointless.
> >>
> >> It is equally possible that moving jurisdiction would have no real
> >> impact at all.
> >>
> >> One thing that I do see as a fact is that "California law" has been
> >> used repeatedly to stymie recommended changes that the staff hasn't
> >> agreed with or wanted to introduce. That is a problem.
> >>
> >> If that is the problem we are seeking a solution to, it strikes me
> >> that the conversation should focus on how to get independent
> >> analysis of decisions that reference "California law" as a reason
> >> for a given direction rather than embark on a discussion about
> >> jurisdictions overall.
> >>
> >> Either way, let's take our jobs seriously and find some experts
> >> rather than mistake familiarity with expertise.
> >>
> >>
> >> Kieren
> >>
> >>
> >>
> >>
> >>
> >> On Wed, Nov 5, 2014 at 8:16 AM, Allan MacGillivray
> >> <allan.macgillivray at cira.ca <mailto:allan.macgillivray at cira.ca> 
> <mailto:allan.macgillivray at cira.ca <mailto:allan.macgillivray at cira.ca>>>
> >> wrote:
> >>
> >> Becky  I think that would be of considerable value.  ____
> >>
> >> __ __
> >>
> >> Allan____
> >>
> >> __ __
> >>
> >> *From:*cwg-rfp3-bounces at icann.org <mailto:cwg-rfp3-bounces at icann.org>
> >> <mailto:cwg-rfp3-bounces at icann.org <mailto:cwg-rfp3-bounces at icann.org>>
> >> [mailto:cwg-rfp3-bounces at icann.org <mailto:cwg-rfp3-bounces at icann.org>
> >> <mailto:cwg-rfp3-bounces at icann.org 
> <mailto:cwg-rfp3-bounces at icann.org>>] *On Behalf Of *Burr, Becky
> >> *Sent:* November-05-14 10:01 AM *To:* Becky Burr; Dwi Elfrida
> >> Martina *Cc:* RFP3
> >>
> >>
> >> *Subject:* Re: [CWG-RFP3] Is there is a more suitable legal
> >> jurisdiction for anIANA subsidiary?____
> >>
> >> __ __
> >>
> >> Team -____
> >>
> >> __ __
> >>
> >> Jurisdiction issues are very complex. I believe that it would be
> >> extremely helpful for us (as well as for many other work streams)
> >> to develop a shared  perspective on the basic rules and issues.
> >> Although there are many lawyers participating, we would probably
> >> get the most benefit from an independent/neutral provider.  If this
> >> is of interest, I would be happy to work with the co-chairs and
> >> other interested folks to put materials and a webinar
> >> together.____
> >>
> >> __ __
> >>
> >> J. Beckwith Burr____
> >>
> >> *Neustar, Inc. /* Deputy General Counsel and Chief Privacy
> >> Officer____
> >>
> >> 1775 Pennsylvania Avenue NW, Washington, DC 20006____
> >>
> >> Office: + 1.202.533.2932 
> <tel:%2B%201.202.533.2932><tel:%2B%201.202.533.2932>  Mobile:
> >> +1.202.352.6367 <tel:%2B1.202.352.6367>  / becky.burr at neustar.biz 
> <mailto:becky.burr at neustar.biz>
> >> <mailto:becky.burr at neustar.biz <mailto:becky.burr at neustar.biz>> / 
> www.neustar.biz <http://www.neustar.biz>
> >> <http://www.neustar.biz>____
> >>
> >> __ __
> >>
> >> *From: *<Burr>, Becky Burr <becky.burr at neustar.biz 
> <mailto:becky.burr at neustar.biz>
> >> <mailto:becky.burr at neustar.biz <mailto:becky.burr at neustar.biz>>> 
> *Date: *Wednesday, November 5,
> >> 2014 at 9:24 AM *To: *Dwi Elfrida Martina <dwi.elfrida at gmail.com 
> <mailto:dwi.elfrida at gmail.com>
> >> <mailto:dwi.elfrida at gmail.com <mailto:dwi.elfrida at gmail.com>>> *Cc: 
> *RFP3 <cwg-rfp3 at icann.org <mailto:cwg-rfp3 at icann.org>
> >> <mailto:cwg-rfp3 at icann.org <mailto:cwg-rfp3 at icann.org>>> *Subject: 
> *Re: [CWG-RFP3] Is there is
> >> a more suitable legal jurisdiction for anIANA subsidiary?____
> >>
> >> __ __
> >>
> >> Several independent review panels have held that ICANN is subject
> >> to international law. ____
> >>
> >> __ __
> >>
> >>
> >>
> >> Becky Burr ____
> >>
> >> Sent from my iPhone____
> >>
> >>
> >> On Nov 5, 2014, at 03:50, Dwi Elfrida Martina
> >> <dwi.elfrida at gmail.com <mailto:dwi.elfrida at gmail.com> 
> <mailto:dwi.elfrida at gmail.com <mailto:dwi.elfrida at gmail.com>>> wrote:____
> >>
> >> Hi, ____
> >>
> >> my name is Dwi Elfrida, I am from Indonesia. in respond to optioned
> >> 2 from Robert, and thanks to bring the jurisdiction issue up, in my
> >> opinion to tie up IANA legal status to ICANN's legal status might a
> >> faster way to reach IANA's legislation. But, it wouldn't be
> >> solution for many parties who questioned IANA's independency from
> >> the US government authority, as I know, for some parties the good
> >> news (main spirit)  of  transition of IANA stewardship is to
> >> internationalized IANA, means to dismiss the image of single
> >> authority of the US government over IANA. Meanwhile, some parties
> >> are still debated the ICANN's legislation that cannot be counted as
> >> International law, as all cases of TLD (mostly gTLD) will be
> >> processed in the US by using the US law. Therefore, the government
> >> of France (at ICANN meeting in London) was still calling the issue
> >> of making ICANN as International organization legalized by
> >> International law. And this idea seems like supported by some
> >> governments in Europe, and other part of this world. Indeed,
> >> placing IANA's functions and office from the US to other part of
> >> this world, is not the solution as well, because it is not the
> >> matter or territory, but the matter of legislation system, which
> >> law that suitable enough to validate IANA? do we agree to use the
> >> US legislation system like has been used by the ICANN, or do we
> >> agree to use International law, then how will we make it happen?
> >> Our choice on IANA's legislation system will determine the law
> >> enforcement of IANA's policies in the future. ____
> >>
> >> Regards,____
> >>
> >> Dwi____
> >>
> >> __ __
> >>
> >> On Mon, Nov 3, 2014 at 11:33 PM, Greg Shatan
> >> <gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com> 
> <mailto:gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>>>
> >> wrote:____
> >>
> >> Boxbe
> >>
> >><https://urldefense.proofpoint.com/v2/url?u=https-3A__www.boxbe.com_overv
> >>iew&d=AAMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahO
> >>P8WDDkMr4k&m=k2GsV6WE92A31X-8yWSy_xDHzzCQkZmNP4-qSd-m8eA&s=dwXKcyJyHjOeOv
> >>MCvWgkHIQUnNb53ULq_5GsKBtjdqM&e=>Greg
> >>
> >>
> >Shatan (gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>
> >> <mailto:gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>>) 
> is not on your Guest List
> >>
> >><https://urldefense.proofpoint.com/v2/url?u=https-3A__www.boxbe.com_appro
> >>ved-2Dlist-3Ftc-5Fserial-3D19182912144-26tc-5Frand-3D1184408227-26utm-5Fs
> >>ource-3Dstf-26utm-5Fmedium-3Demail-26utm-5Fcampaign-3DANNO-5FMWTP-26utm-5
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> >>0Hpa_joycqSp3Z7zfl75E-l1fPnGYe97BVXeJCeLdI&e=>
> >>
> >>
> >| Approve sender
> >>
> >><https://urldefense.proofpoint.com/v2/url?u=https-3A__www.boxbe.com_anno-
> >>3Ftc-5Fserial-3D19182912144-26tc-5Frand-3D1184408227-26utm-5Fsource-3Dstf
> >>-26utm-5Fmedium-3Demail-26utm-5Fcampaign-3DANNO-5FMWTP-26utm-5Fcontent-3D
> >>001-26token-3DqXEye5ECFs8sowPv0-252F4O8pOgVuL-252FBmLxktanSEOAIoHm3oce3A-
> >>252BGf6umfpPHJkCc-26key-3DhXVOG4roryQLXAw-252BAJXI90w8csVOeh5xYEclQYt0Qbk
> >>-253D&d=AAMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYa
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> >>oU67ZKkRXsAZXkWFaXvH6ogLhFbsl8U&e=>
> >>
> >>
> >| Approve domain
> >>
> >><https://urldefense.proofpoint.com/v2/url?u=https-3A__www.boxbe.com_anno-
> >>3Ftc-5Fserial-3D19182912144-26tc-5Frand-3D1184408227-26utm-5Fsource-3Dstf
> >>-26utm-5Fmedium-3Demail-26utm-5Fcampaign-3DANNO-5FMWTP-26utm-5Fcontent-3D
> >>001-26dom-26token-3DqXEye5ECFs8sowPv0-252F4O8pOgVuL-252FBmLxktanSEOAIoHm3
> >>oce3A-252BGf6umfpPHJkCc-26key-3DhXVOG4roryQLXAw-252BAJXI90w8csVOeh5xYEclQ
> >>Yt0Qbk-253D&d=AAMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjD
> >>mrxdYahOP8WDDkMr4k&m=k2GsV6WE92A31X-8yWSy_xDHzzCQkZmNP4-qSd-m8eA&s=2jX-2m
> >>WyYFU7bmDZVRcEHQfGtVoCrA-zbiHakjXt0WM&e=>
> >>
> >>
> >____
> >>
> >> __ __
> >>
> >> All: ____
> >>
> >> __ __
> >>
> >> Here is Robert's second question (which I think also applies to the
> >> concept of a fully independent IANA): ____
> >>
> >> __ __
> >>
> >> *For  option #2.
> >>
> >> - Is there is a  jurisdiction that ICANN has (or can obtain) legal
> >> status might be more suitable to use to create IANA as a
> >> subsidiary. Such an option might allow for the link to be a
> >> subsidiary of ICANN, but sever the legal link to the US. A
> >> negative, of course, would be moving the function and existing
> >> staff to a new part of the world.*____
> >>
> >> __ __
> >>
> >> Comments and discussion?____
> >>
> >> __ __
> >>
> >> Greg____
> >>
> >>
> >> _______________________________________________ Cwg-rfp3 mailing
> >> list Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org> 
> <mailto:Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org>>
> >> https://mm.icann.org/mailman/listinfo/cwg-rfp3 
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_cwg-2Drfp3&d=AAMGaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=M4a9b8Uq2KA4oDOk0euAXMT1PLI3HMRhgFBQlTBhDc4&s=1q4MSVnKCzHCKceEcK_qGmF6fuL6Up4naoiv8GlOlv0&e=>
> >>
> >><https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailma
> >>n_listinfo_cwg-2Drfp3&d=AAMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GR
> >>laq8Mo8TjDmrxdYahOP8WDDkMr4k&m=k2GsV6WE92A31X-8yWSy_xDHzzCQkZmNP4-qSd-m8e
> >>A&s=dYjlRZKCFivOUjM8w-G3Ngmrm3uTYteQNcbUQCVgfQ0&e=>____
> >>
> >>
> >>
> >>
> >>
> >> -- ____
> >>
> >> Dwi Elfrida MS____
> >>
> >> _______________________________________________ Cwg-rfp3 mailing
> >> list Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org> 
> <mailto:Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org>>
> >>
> >>https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman
> >>_listinfo_cwg-2Drfp3&d=AAICAg&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRl
> >>aq8Mo8TjDmrxdYahOP8WDDkMr4k&m=k2GsV6WE92A31X-8yWSy_xDHzzCQkZmNP4-qSd-m8eA
> >>&s=dYjlRZKCFivOUjM8w-G3Ngmrm3uTYteQNcbUQCVgfQ0&e=____
> >>
> >>
> >>
> >> _______________________________________________ Cwg-rfp3 mailing
> >> list Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org> 
> <mailto:Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org>>
> >> https://mm.icann.org/mailman/listinfo/cwg-rfp3 
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_cwg-2Drfp3&d=AAMGaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=M4a9b8Uq2KA4oDOk0euAXMT1PLI3HMRhgFBQlTBhDc4&s=1q4MSVnKCzHCKceEcK_qGmF6fuL6Up4naoiv8GlOlv0&e=>
> >>
> >>
> >>
> >>
> >> _______________________________________________ Cwg-rfp3 mailing
> >> list Cwg-rfp3 at icann.org <mailto:Cwg-rfp3 at icann.org>
> >> https://mm.icann.org/mailman/listinfo/cwg-rfp3 
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_cwg-2Drfp3&d=AAMGaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=M4a9b8Uq2KA4oDOk0euAXMT1PLI3HMRhgFBQlTBhDc4&s=1q4MSVnKCzHCKceEcK_qGmF6fuL6Up4naoiv8GlOlv0&e=>
> >>
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> >_______________________________________________
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>
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