[Gnso-ppsai-pdp-wg] For review - updated templates Cat B, questions 1 and 2

Volker Greimann vgreimann at key-systems.net
Mon Mar 3 10:31:52 UTC 2014

Hi Steven,
> Even when this assertion is relevant, it may not be persuasive, for a 
> number of reasons.  For example, the Whois data reminder obligation 
> applies to the registrant of record.  In the case of a proxy service, 
> the registrant or record is the service, not its customer.  If a Whois 
> data reminder is sent to a non-proxy registrant and bounces back, then 
> the RAA requires the registrar to re-verify.  But a data reminder sent 
> to a proxy service will almost never bounce back, and therefore there 
> may be no RAA obligation to re-verify. This is so even if the customer 
> data provided to the service is inaccurate or outdated.   In this 
> circumstance it is up to the p/p service accreditation standards to 
> specify the conditions under which customer data must be re-verified.

This depends on how the service is set up. One could suggest that if 
such required messages from the registrar do not reach the registrant, 
it could become the providers' obligation to perform the information 
requirements on its own. The registrar could then rely on the provider 
to perform its duties under the accreditation agreement with ICANN just 
at it performs its own obligations under the RAA.

Please also remember that the registrars obligation only extends to the 
registrant of record, not to anyone who may use the domain name with 
permission of that registrant.

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