[Gnso-impl-thickwhois-rt] [for iRT review] Draft Thick Whois Transition Policy for .COM, .NET, and .JOBS
gtheo
gtheo at xs4all.nl
Tue Sep 13 10:47:20 UTC 2016
Hi all,
A few thoughts here from my side.
It appears the GNSO draft memo is either not very clear, or it is me
having a very different thought process compared to Marc and Steve here.
The discussion about safe harbor or Russian law is not so relevant to
me. These things happen and will continue to happen as our governments
are set in an age of quarrel constantly changing their laws and policies
and bickering amongst eachother.
If I zoom out and look at this from a more high-level perspective I see
the following.
I see a ton of Registries in very different jurisdictions.
I see a ton of Registrars in very different jurisdictions.
That the current Thick WHOIS Registries and their Registrars have not
run into trouble is amazing. I think it is pretty risky and just asking
for trouble at some point, as there is no procedure in place to address
issues for Registrars or Registries.
Moving .com to a Thick WHOIS Registry, in my opinion is adding more risk
and liability.
Anyways this is my thought process here.
I would like to note, that we now base our actions on the legal review
from 2015. Yet, I also observe that .Amsterdam is the first geo gTLD
registry that openly admits, that according to them the current Thick
WHOIS model is causing them massive headaches to comply with the law.
Other geo TLD Registries like Nominet and Afnic, etc are monitoring very
closely how the progress is going for .Amsterdam as they are in the same
boat.
To be clear here, these geo gTLD operators have removed all personal
identifiable WHOIS data from their respective ccTLDs when it comes to
the public WHOIS they operate years ago.
Thanks,
Theo
Metalitz, Steven schreef op 2016-09-12 11:39 PM:
> Thanks for providing these responses Marc. Let me offer some quick
> reactions that could provide a basis for discussion if we do reach
> this item on tomorrow’s agenda.
>
> First, I take your point that the validity of consent as a basis for
> processing was addressed in the two memos from national data
> protection authorities that are referenced in your draft letter, and
> that those memos were issued after and in reaction to the invalidation
> of the Safe Harbor by the Court of Justice of the European Union.
> However, that invalidation did not by itself change the data
> protection law of any EU Member State with regard to consent as a
> basis for processing. Furthermore, I think your e-mail
> mischaracterizes what the June 2015 legal review said about Safe
> Harbor. It referred to it solely in the context in which “the data
> processing under thick Whois is based upon legitimate interests” of
> a party, rather than upon consent. It was for that reason that the
> review recommended consent as “the most suitable approach.” If
> the Safe Harbor is only relevant in the context of a possible basis
> for processing which is not relied upon, then it is hard to see how
> invalidation of the Safe Harbor brings any of the conclusions of the
> legal review into question. This seems consistent with the fact that
> your company, for example, apparently did not rely upon the Safe
> Harbor to justify its receipt of PII from European registrars in Whois
> data in the thick registries that it operates. If that is the case,
> then it is hard to see how invalidation of the Safe Harbor changes the
> substantive legal situation.
>
> Second, you are of course correct that the EU is not the only
> jurisdiction whose law may be relevant here but I think you may be
> blurring the distinction between privacy legislation such as the
> European Data Protection Directive, and data localization requirements
> such as the Russian law; it was specifically the Russian Localization
> Law that the legal review characterized as the “subject of
> significant uncertainty as to its scope, applicability and
> requirements,” but which it ultimately concluded would not be likely
> to present a problem so long as the personal data was also stored in
> Russia and there was consent of the data subject for “onward
> transfers from Russia.” Both of these features are fully consistent
> with thick Whois architecture. I am still not clear whether you are
> contesting this analysis or what you think has changed since it was
> delivered to us.
>
> Finally, I am not sure what you are suggesting the IRT do beyond just
> “throwing the issue back over the wall” to the GNSO council, but I
> am sure we will be able to discuss this in more detail on tomorrow’s
> or a future call.
>
> Steve Metalitz
>
> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>
> T: 202.355.7902 | met at msk.com
>
> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [1]
>
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>
> FROM: Anderson, Marc [mailto:mcanderson at verisign.com]
> SENT: Monday, September 12, 2016 4:58 PM
> TO: gnso-impl-thickwhois-rt at icann.org; Metalitz, Steven; 'gtheo'
> SUBJECT: RE: [Gnso-impl-thickwhois-rt] [for iRT review] Draft Thick
> Whois Transition Policy for .COM, .NET, and .JOBS
>
> Steve, thank you for the reminder. I see that Dennis has responded
> indicating it’s on the agenda but listed as an “if time permits”
> item. Would it maybe make sense to bump this up in priority making
> sure we have time to discuss?
>
> On your first question the relevance of the Safe Harbor invalidation
> and development of Privacy Shield is that these developments have led
> regulators in the EU to also question the validity of consent-based
> transfers, particularly in the context of large and/or repeated
> transfers of personal data. Considering that both the RA and the RAA
> “require” consent from the registrant, this development is
> particularly noteworthy. I think it’s notable that the ICANN
> memorandum references three “instruments to provide for an adequate
> level of data protection on part of the data recipient located outside
> of the EEA”, one being Safe Harbor. The invalidation of Safe Harbor
> and the emergence of Privacy Shield seems a relevant privacy issue not
> anticipated by the Working Group or the ICANN memorandum for that
> matter.
>
> On question two, in addition to Russian laws which the ICANN
> memorandum notes were “still the subject of significant uncertainty
> as to its scope, applicability and requirements”, I understand that
> data localization laws exist in countries such as South Korea,
> Indonesia, Vietnam, and Brazil (for example), but the applicability
> and requirements associated with these laws (and other similar laws
> around the world) weren’t addressed in the ICANN memorandum, which
> focused on the EU. The primary point the draft makes in this regard
> is that data protection regulations exist in other jurisdictions
> beyond the EU that may have a direct impact on thick Whois policies
> and procedures, and should be a consideration for all thick registries
> and registrars and in particular for those completing the thick
> transition.
>
> For question three, my first thought was that our obligation on the
> IRT is just to inform (notify) the GNSO Council so that appropriate
> action can be taken. That seems like the easy way out though and that
> we shouldn’t just be throwing this over the wall so to speak. We
> could ask the GNSO Council to provide direction on if additional
> policy considerations are required.
>
> Thank you,
>
> Marc
>
> FROM: gnso-impl-thickwhois-rt-bounces at icann.org
> [mailto:gnso-impl-thickwhois-rt-bounces at icann.org] ON BEHALF OF
> Metalitz, Steven
> SENT: Monday, September 12, 2016 2:32 PM
> TO: 'gtheo'
> CC: gnso-impl-thickwhois-rt at icann.org
> SUBJECT: Re: [Gnso-impl-thickwhois-rt] [for iRT review] Draft Thick
> Whois Transition Policy for .COM, .NET, and .JOBS
>
> I have not yet seen any agenda for tomorrow’s call but assuming that
> it includes a discussion of the Verisign draft letter to GNSO council,
> it would be great to have Verisign’s responses to the questions
> about it that I posed two weeks ago. See below.
>
> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>
> T: 202.355.7902 | met at msk.com
>
> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [1]
>
> 1818 N Street NW, 8th Floor, Washington, DC 20036
>
> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR
> THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS
> MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS
> PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
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> PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE,
> AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM.
> THANK YOU.
>
> Metalitz, Steven schreef op 2016-09-08 05:25 PM:
>> Theo’s ruminations lead me to repeat the questions I posed to Marc
>> last week about his draft memo:
>>
>> (1) The first two developments to which you cite are the
>> invalidation of the US-EU Safe Harbor Program and the adoption of
> the
>> EU-US Privacy Shield framework to replace it. My impression is that
>> US registries generally did not rely upon the Safe Harbor in
>> processing thick Whois data (e.g., receiving Whois data containing
>> personally identifiable information from European registrars and
>> making it available through registry Whois), and so would not have
>> been directly impacted by its invalidation. Is my impression wrong?
>> If I am correct then what is the relevance of either the Safe Harbor
>> or the Privacy Shield in this context?
>>
>> (2) The last paragraph refers to data localization laws apart from
>> EU privacy/data protection laws. Can you be more specific? I note
>> that the Russian law was referenced in footnotes 2 and 10 of the
> legal
>> review provided to the IRT in June 2015, are there other issues not
>> covered by that analysis?
>>
>> (3) If the IRT were to send this letter, the GNSO council might
>> well ask what (if anything) we are asking them to do. How would you
>> respond?
>>
>> In particular, If I understand Theo correctly, his answer to #3
> would
>> be “please tear up the consensus policy recommended by the Working
>> Group, adopted by the GNSO Council, and approved by the ICANN board,
>> it is obsolete, and let’s not waste [further] time implementing
>> it.” Is that reading correct, and do others in the IRT support
>> that?
>>
>> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>>
>> T: 202.355.7902 | met at msk.com
>>
>> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [2] [3]
>>
>> 1818 N Street NW, 8th Floor, Washington, DC 20036
>>
>> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY
> FOR
>> THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS
>> MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS
>> PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
>> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
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>> PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR
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>> AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR
> SYSTEM.
>> THANK YOU.
>>
>> FROM: gtheo [mailto:gtheo at xs4all.nl]
>> SENT: Thursday, September 08, 2016 6:57 AM
>> TO: Marika Konings; Metalitz, Steven; 'Volker Greimann'
>> CC: gnso-impl-thickwhois-rt at icann.org
>> SUBJECT: Re: [Gnso-impl-thickwhois-rt] [for iRT review] Draft Thick
>> Whois Transition Policy for .COM, .NET, and .JOBS
>>
>> Interesting review. After reading it I agree with Volker here.
>>
>> Few things that stood out.
>>
>> It seems the focus was put on the 95/46/EC Directive (makes sense)
> but
>> Safe Harbor was not included in. I am not sure if that was intended?
> I
>> would not be surprised that anyone ever thought that it would be a
>> possibility that it would be invalidated, and what the consequences
>> are.
>>
>> Anyways, we just need a good procedure for this IRT. The legal
> review
>> does not address the current impediment, so that is not up to us.
>>
>> What is up to us, maybe, are the benefits mentioned in the legal
>> review (page5)?
>>
>> Let me list them:
>> 1. A thick Whois model offers attractive archival and restoration
>> properties. If a registrar were to go out of business or experience
>> long-term technical failures rendering
>> them unable to provide service, registries maintaining thick Whois
>> have all the registrant information at hand and could transfer the
>> registrations to a different (or temporary) registrar so that
>> registrants could continue to manage their domain names.
>>
>> 2. A thick Whois model reduces the degree of variability in display
>> formats.
>>
>> 3. Establishing requirements such as collecting uniform sets of
>> data, and display standards, improves consistency across all gTLDs
> at
>> all levels and result in better access to Whois data for all users
> of
>> Whois databases (e.g. law enforcement, Intellectual Property
> holders,
>> etc).
>>
>> 4. The uptime of the registry with respect to Whois data has
>> typically been found to be better (at least marginally) than the
>> registrar.
>>
>> I am not sure about the rest of you, but this re-enforces the point
>> that this migration has been in the freezer for too long.
>>
>> Point 1, that's why we have escrow obligations. The reasoning in
>> point 1 is not sustainable for the future I am afraid.
>> Point 2 and 3, This has been addressed by the RAA 2013 and the AWIP
>> policy released in 2015.
>> Point 4, I suspect with RDAP this problem will also be solved.
>> Beside the RAA 2013 also addresses this with an SLA.
>>
>> One could almost argue there are no benefits. Not sure if you guys
>> want to circle back on this one and include this in a side note for
>> the comment period.
>>
>> Also, interesting to read but, out of scope for this IRT (I think)
> is
>> the RDAP solution (page 12 of the legal review)? It could be me, but
>> it almost looks like if there was a quick procedure and workable
>> procedure then the technical issue would be solved also, and it
> would
>> solve our impediment.
>>
>> Thank you for making it this far.
>>
>> Theo
>>
>> theo geurts schreef op 2016-09-07 10:22 PM:
>>
>>> Thanks, Marika,
>>>
>>> I'll give that one a read tomorrow. Though I think Volker is right.
>>> Seems we are operating under old marching orders, Steve already
>>> warned
>>> us that this thing has taken way too long. The draft Verisign
>>> prepared
>>> does actually highlight the current situation. And to be fair? How
>>> many people would have thought that Safe Harbor would have been
>>> invalidated? Not me for sure. But I also did not predict the brexit
>>> or
>>> Trump running for president.
>>>
>>> In addition to this, I think we are in agreement here. It is not up
>>> to
>>> this IRT. We can only signal the GNSO that most likely we have a
>>> few
>>> impediments.
>>>
>>> Best regards,
>>>
>>> Theo
>>>
>>> On 7-9-2016 16:53, Marika Konings wrote:
>>>
>>> And it can be found here:
>>>
>>>
>>
> https://community.icann.org/download/attachments/52889541/ICANN%20Memorandum%20to%20the%20IRT%20-%20Thin%20to%20Thick%20WHOIS%20Transition_Final_2015-06-08.pdf?version=1&modificationDate=1434138098000&api=v2.
>>>
>>>
>>> Best regards,
>>>
>>> Marika
>>>
>>> MARIKA KONINGS
>>>
>>> Senior Policy Director & Team Leader for the GNSO, Internet
>>> Corporation for Assigned Names and Numbers (ICANN)
>>>
>>> Email: marika.konings at icann.org
>>>
>>> _ _
>>>
>>> _Follow the GNSO via Twitter @ICANN_GNSO_
>>>
>>> _Find out more about the GNSO by taking our interactive courses [10
>>> [1]]
>>> and visiting the GNSO Newcomer pages [11]._
>>>
>>> FROM: <gnso-impl-thickwhois-rt-bounces at icann.org> on behalf of
>>> "Metalitz, Steven" <met at msk.com>
>>> DATE: Wednesday 7 September 2016 at 08:44
>>> TO: 'Volker Greimann' <vgreimann at key-systems.net>, gtheo
>>> <gtheo at xs4all.nl>
>>> CC: "gnso-impl-thickwhois-rt at icann.org"
>>> <gnso-impl-thickwhois-rt at icann.org>
>>> SUBJECT: Re: [Gnso-impl-thickwhois-rt] [for iRT review] Draft Thick
>>> Whois Transition Policy for .COM, .NET, and .JOBS
>>>
>>> That legal review was undertaken more than a year ago.
>>>
>>> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>>>
>>> T: 202.355.7902 | met at msk.com
>>>
>>> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [2] [2] [1 [3]]
>>>
>>> 1818 N Street NW, 8th Floor, Washington, DC 20036
>>>
>>> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY
>>> FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS.
>>> THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH
> IS
>>> PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT
> AN
>>> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
>>> DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
>>> PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR
>>> TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM
>>> YOUR SYSTEM. THANK YOU.
>>>
>>> FROM: Volker Greimann [mailto:vgreimann at key-systems.net]
>>> SENT: Wednesday, September 07, 2016 10:44 AM
>>> TO: Metalitz, Steven; gtheo
>>> CC: gnso-impl-thickwhois-rt at icann.org
>>> SUBJECT: Re: [Gnso-impl-thickwhois-rt] [for iRT review] Draft Thick
>>> Whois Transition Policy for .COM, .NET, and .JOBS
>>>
>>> Partially. As the thick whois WG clearly recommended that a legal
>>> review be undertaken with regard to the impact of any
> implementation
>>> on local privacy legislations, the question of available
> excemptions
>>> may well become relevant to such a review.
>>>
>>> Best,
>>>
>>> Volker
>>>
>>> Am 07.09.2016 um 16:38 schrieb Metalitz, Steven:
>>>
>>> Agree that this issue is outside the scope of this group.
>>>
>>> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>>>
>>> T: 202.355.7902 | met at msk.com
>>>
>>> MITCHELL SILBERBERG & KNUPPLLP | WWW.MSK.COM [2] [2] [1 [3]]
>>>
>>> 1818 N Street NW, 8th Floor, Washington, DC 20036
>>>
>>> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY
>>> FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED
>>> RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION,
>>> AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS
>>> MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT
>>> ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS
>>> MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY
>>> REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL
>>> ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.
>>>
>>> FROM: gnso-impl-thickwhois-rt-bounces at icann.org
>>> [mailto:gnso-impl-thickwhois-rt-bounces at icann.org] ON BEHALF OF
>>> Volker Greimann
>>> SENT: Wednesday, September 07, 2016 9:28 AM
>>> TO: gtheo
>>> CC: gnso-impl-thickwhois-rt at icann.org
>>> SUBJECT: Re: [Gnso-impl-thickwhois-rt] [for iRT review] Draft
>>> Thick Whois Transition Policy for .COM, .NET, and .JOBS
>>>
>>> Well, I agree that we need a workable process for obtaining an
>>> excemption, but that is a discussion for another group, I guess.
>>> An
>>> Implementation Advisory Group, if you will. I hear there may soon
>>> be
>>> another one of those. ;-)
>>>
>>> Best,
>>>
>>> Volker
>>>
>>> Am 07.09.2016 um 15:18 schrieb gtheo:
>>>
>>> That might be a way forward Volker.
>>>
>>>
>>
> https://www.icann.org/resources/pages/waiver-request-process-2013-09-13-en
>>>
>>>
>>> However, that one wasn't exactly "speedy". Took me two years to
>>>
>>> obtain
>>>
>>> one.
>>> The invalidation of Safe Harbor was rather sudden. Some
>>>
>>> governments
>>>
>>> displayed the last 12 months that things can change at record
>>>
>>> speed
>>>
>>> law wise.
>>>
>>> I guess the problem boils down to this.
>>> -Sudden changes in law putting migrated Registrar businesses at
>>>
>>> risk.
>>>
>>> -The procedure can take much longer than the proposed timeline.
>>> -There might be Registrars that cannot migrate.
>>>
>>> I am not sure, but I have the feeling that it is not up to the
>>>
>>> IRT to
>>>
>>> fix this as it is out of scope.
>>> Though Registrars who cannot migrate, we might want to mention
>>>
>>> RDAP.
>>>
>>> Even though that is already mentioned in the RDAP spec when it
>>>
>>> comes
>>>
>>> to Thin WHOIS Registries.
>>>
>>> Theo
>>>
>>> Volker Greimann schreef op 2016-09-07 01:24 PM:
>>>
>>> How about adding: "Further procedures for resolving conflicts
>>>
>>> with
>>>
>>> local privacy laws are included in the 2013 RAA Data Retention
>>> specification"?
>>>
>>> Am 07.09.2016 um 12:52 schrieb gtheo:
>>>
>>> Hello all,
>>>
>>> _1. Where a conflict exists between local privacy laws and
>>> requirements included in this Policy, ICANN's Procedure for
>>> Handling WHOIS Conflicts with Privacy Laws is available for
>>>
>>> Registry
>>>
>>> Operators and Registrars. _
>>>
>>> We didn't get around this yesterday, wich is fine. Let us see
>>>
>>> if we
>>>
>>> can have some discussion in advance about this as I am
>>>
>>> struggling
>>>
>>> with this section for a few now.
>>>
>>> The text itself is good, as in, this is what I expected after
>>>
>>> the
>>>
>>> discussions we had about this in the last few months.
>>>
>>> What I am not sure off is how to deal with this in the sense of
>>> moving forward to the comment period.
>>> The procedure is not working, but is outside of this IRT to
>>>
>>> address,
>>>
>>> yet this IRT relies on it.
>>>
>>> Are we going to put in a footnote in the report that says
>>>
>>> something
>>>
>>> like:
>>> _Outside the scope of the IRT to address, but we wish the
>>>
>>> Registrars
>>>
>>> and Registrants the best of luck!_
>>>
>>> Thanks,
>>> Theo
>>>
>>> Dennis Chang schreef op 2016-09-02 02:05 AM:
>>>
>>> Dear Thick Whois Policy Implementation Review Team,
>>>
>>> Attached for your review is our initial draft of the Thick
>>>
>>> Whois
>>>
>>> Transition Policy for .COM, .NET and .JOBS. The draft Policy
>>> includes
>>> the various elements discussed in our recent meeting on this
>>> topic.
>>>
>>> As you review the draft, you will find bracketed text in four
>>> sections: sections 2.9, 2.10, 3.4 and 3.5. These sections are
>>> bracketed because they reference the Registry Registration Data
>>> Directory Services Consistent Labeling and Display Policy and
>>>
>>> the
>>>
>>> Registration Data Access Protocol gTLD Profile. As you may be
>>> aware, a
>>> Request for Reconsideration (RfR) was submitted by the
>>>
>>> Registries
>>>
>>> Stakeholder Group in August regarding the Registry Registration
>>> Data
>>> Directory Services Consistent Labeling and Display Policy [1
>>>
>>> [1]]
>>>
>>> that was
>>> published on 26 July 2016. The RfR objects to the inclusion of
>>> RDAP in
>>> the Consensus Policy. While the RfR goes through its own
>>>
>>> process,
>>>
>>> we
>>> thought it was important to continue progressing the
>>> implementation
>>> project with the goal of opening Public Comment in September
>>>
>>> and
>>>
>>> announcing the Transition Policy by 1 February 2017 per our
>>> schedule.
>>> Therefore, the text is bracketed as it may need to be revisited
>>> pending the resolution of the RfR and we wanted to directly
>>>
>>> call
>>>
>>> the
>>> IRT's attention to it.
>>>
>>> We will review all contents of the document at our next IRT
>>> meeting as
>>> a team but please provide your comments in advance via email if
>>> possible.
>>>
>>> Thank you for your support!
>>>
>>> --
>>>
>>> Kind Regards,
>>>
>>> Dennis S. Chang
>>>
>>> GDD Services & Engagement Program Director
>>>
>>> +1 213 293 7889
>>>
>>> Skype: dennisSchang
>>>
>>> www.icann.org [3] [4] [2 [4]] [2 [4]] "One World, One Internet"
>>>
>>> Links:
>>> ------
>>> [1 [3]]
>>
>>
> https://www.icann.org/resources/pages/rdds-labeling-policy-2016-07-26-en
>>
>>
>>> _______________________________________________
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>>> Gnso-impl-thickwhois-rt at icann.org
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>>
>> --
>> Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
>>
>> Mit freundlichen Grüßen,
>>
>> Volker A. Greimann
>> - Rechtsabteilung -
>>
>> Key-Systems GmbH
>> Im Oberen Werk 1
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>> Email: vgreimann at key-systems.net
>>
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>> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook:
>> www.facebook.com/KeySystems [8] [9] [7 [9]]
>> www.twitter.com/key_systems [9] [10] [8 [10]]
>>
>> Geschäftsführer: Alexander Siffrin
>> Handelsregister Nr.: HR B 18835 - Saarbruecken
>> Umsatzsteuer ID.: DE211006534
>>
>> Member of the KEYDRIVE GROUP
>> www.keydrive.lu [10] [11] [9 [11]]
>>
>> Der Inhalt dieser Nachricht ist vertraulich und nur für den
>> angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe,
>> Veröffentlichung oder Weitergabe an Dritte durch den Empfänger
>> ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt
>> sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch
>> in Verbindung zu setzen.
>>
>> --------------------------------------------
>>
>> Should you have any further questions, please do not hesitate to
>> contact us.
>>
>> Best regards,
>>
>> Volker A. Greimann
>> - legal department -
>>
>> Key-Systems GmbH
>> Im Oberen Werk 1
>> 66386 St. Ingbert
>> Tel.: +49 (0) 6894 - 9396 901
>> Fax.: +49 (0) 6894 - 9396 851
>> Email: vgreimann at key-systems.net
>>
>> Web: www.key-systems.net [4] [5] [3 [5]] / www.RRPproxy.net [5] [6]
> [4 [6]]
>> www.domaindiscount24.com [6] [7] [5 [7]] / www.BrandShelter.com [7]
> [8] [6
>> [8]]
>>
>> Follow us on Twitter or join our fan community on Facebook and
>> stay updated:
>> www.facebook.com/KeySystems [8] [9] [7 [9]]
>> www.twitter.com/key_systems [9] [10] [8 [10]]
>>
>> CEO: Alexander Siffrin
>> Registration No.: HR B 18835 - Saarbruecken
>> V.A.T. ID.: DE211006534
>>
>> Member of the KEYDRIVE GROUP
>> www.keydrive.lu [10] [11] [9 [11]]
>>
>> This e-mail and its attachments is intended only for the person to
>> whom it is addressed. Furthermore it is not permitted to publish
>> any content of this email. You must not use, disclose, copy, print
>> or rely on this e-mail. If an addressing or transmission error has
>> misdirected this e-mail, kindly notify the author by replying to
>> this e-mail or contacting us by telephone.
>>
>> _______________________________________________
>> Gnso-impl-thickwhois-rt mailing list
>> Gnso-impl-thickwhois-rt at icann.org
>> https://mm.icann.org/mailman/listinfo/gnso-impl-thickwhois-rt
>>
>> --
>>
>> Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
>>
>> Mit freundlichen Grüßen,
>>
>> Volker A. Greimann
>>
>> - Rechtsabteilung -
>>
>> Key-Systems GmbH
>>
>> Im Oberen Werk 1
>>
>> 66386 St. Ingbert
>>
>> Tel.: +49 (0) 6894 - 9396 901
>>
>> Fax.: +49 (0) 6894 - 9396 851
>>
>> Email: vgreimann at key-systems.net
>>
>> Web: www.key-systems.net [4] [5] [3 [5]] / www.RRPproxy.net [5] [6]
> [4 [6]]
>>
>> www.domaindiscount24.com [6] [7] [5 [7]] / www.BrandShelter.com [7]
> [8] [6
>> [8]]
>>
>> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook:
>>
>> www.facebook.com/KeySystems [8] [9] [7 [9]]
>>
>> www.twitter.com/key_systems [9] [10] [8 [10]]
>>
>> Geschäftsführer: Alexander Siffrin
>>
>> Handelsregister Nr.: HR B 18835 - Saarbruecken
>>
>> Umsatzsteuer ID.: DE211006534
>>
>> Member of the KEYDRIVE GROUP
>>
>> www.keydrive.lu [10] [11] [9 [11]]
>>
>> Der Inhalt dieser Nachricht ist vertraulich und nur für den
>> angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe,
>> Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist
>> unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so
>> bitten wir Sie, sich mit uns per E-Mail oder telefonisch in
>> Verbindung zu setzen.
>>
>> --------------------------------------------
>>
>> Should you have any further questions, please do not hesitate to
>> contact us.
>>
>> Best regards,
>>
>> Volker A. Greimann
>>
>> - legal department -
>>
>> Key-Systems GmbH
>>
>> Im Oberen Werk 1
>>
>> 66386 St. Ingbert
>>
>> Tel.: +49 (0) 6894 - 9396 901
>>
>> Fax.: +49 (0) 6894 - 9396 851
>>
>> Email: vgreimann at key-systems.net
>>
>> Web: www.key-systems.net [4] [5] [3 [5]] / www.RRPproxy.net [5] [6]
> [4 [6]]
>>
>> www.domaindiscount24.com [6] [7] [5 [7]] / www.BrandShelter.com [7]
> [8] [6
>> [8]]
>>
>> Follow us on Twitter or join our fan community on Facebook and stay
>> updated:
>>
>> www.facebook.com/KeySystems [8] [9] [7 [9]]
>>
>> www.twitter.com/key_systems [9] [10] [8 [10]]
>>
>> CEO: Alexander Siffrin
>>
>> Registration No.: HR B 18835 - Saarbruecken
>>
>> V.A.T. ID.: DE211006534
>>
>> Member of the KEYDRIVE GROUP
>>
>> www.keydrive.lu [10] [11] [9 [11]]
>>
>> This e-mail and its attachments is intended only for the person to
>> whom it is addressed. Furthermore it is not permitted to publish any
>> content of this email. You must not use, disclose, copy, print or
>> rely on this e-mail. If an addressing or transmission error has
>> misdirected this e-mail, kindly notify the author by replying to
>> this e-mail or contacting us by telephone.
>>
>> Links:
>> ------
>> [1] http://www.msk.com/
>> [2] http://www.icann.org
>> [3] http://www.key-systems.net
>> [4] http://www.RRPproxy.net
>> [5] http://www.domaindiscount24.com
>> [6] http://www.BrandShelter.com
>> [7] http://www.facebook.com/KeySystems
>> [8] http://www.twitter.com/key_systems
>> [9] http://www.keydrive.lu
>> [10] http://learn.icann.org/courses/gnso
>> [11]
>>
> http://gnso.icann.org/sites/gnso.icann.org/files/gnso/presentations/policy-efforts.htm#newcomers
>> _______________________________________________
>> Gnso-impl-thickwhois-rt mailing list
>> Gnso-impl-thickwhois-rt at icann.org
>> https://mm.icann.org/mailman/listinfo/gnso-impl-thickwhois-rt
>>
>> Links:
>> ------
>> [1] http://learn.icann.org/courses/gnso
>> [2] http://WWW.MSK.COM
>> [3] http://www.msk.com/
>> [4] http://www.icann.org
>> [5] http://www.key-systems.net
>> [6] http://www.RRPproxy.net
>> [7] http://www.domaindiscount24.com
>> [8] http://www.BrandShelter.com
>> [9] http://www.facebook.com/KeySystems
>> [10] http://www.twitter.com/key_systems
>> [11] http://www.keydrive.lu
>
> Links:
> ------
> [1] http://www.msk.com/
> [2] http://WWW.MSK.COM
> [3] http://www.icann.org
> [4] http://www.key-systems.net
> [5] http://www.RRPproxy.net
> [6] http://www.domaindiscount24.com
> [7] http://www.BrandShelter.com
> [8] http://www.facebook.com/KeySystems
> [9] http://www.twitter.com/key_systems
> [10] http://www.keydrive.lu
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