[Gnso-ppsai-pdp-wg] For your review - updated template Cat B - question 2

[John Horton]

We also concur with those points.

John Horton
President, LegitScript



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On Mon, Mar 17, 2014 at 1:17 PM, GBarnett at sgbdc.com <GBarnett at sgbdc.com>wrote:

>  As Val mentioned, I agree with Todd's and Steve's points, and those
> noted in Val's email.
>
>
>
> Griffin
>
>
>
> Griffin M. Barnett
>
> Silverberg, Goldman & Bikoff, LLP
>
> 1101 30th Street NW
>
> Suite 120
>
> Washington, DC 20007
>
> (202) 944-3307
>
> gbarnett at sgbdc.com
>
>
>
>
>
>
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [mailto:
> gnso-ppsai-pdp-wg-bounces at icann.org] *On Behalf Of *Valeriya Sherman
> *Sent:* Monday, March 17, 2014 4:09 PM
> *To:* Metalitz, Steven; 'Williams, Todd'; Marika Konings;
> gnso-ppsai-pdp-wg at icann.org
>
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat
> B - question 2
>
>
>
> I, Jim Bikoff, David Heasley, and Griffin Barnett agree with Todd's
> assessment:
>
>
>
> Contact information that is ultimately revealed is valuable only if it is
> accurate.
>
>
>
> The validation/verification requirements should be consistent with the
> 2013 RAA requirements, but should go above and beyond those requirements to
> ensure the accuracy of contact information.
>
>
>
> Registrars already send an annual Whois Data Reminder Policy
> notification to registrants, reminding them to provide accurate and
> up-to-date information.
>
>
>
> Similarly, the privacy/proxy customer's contact information should be
> verified upon initial registration of the domain name (either by the
> registrar or the Privacy/Proxy Service Provider) and periodically
> thereafter by automated annual email re-verification notifications that
> require an affirmative response by the P/P customer.  Absence of a response
> would trigger a follow-up, reminding the privacy/proxy customer to provide
> accurate and up-to-date information.
>
>
> Regards,
>
>
>
> Valeriya Sherman
> Silverberg, Goldman & Bikoff, L.L.P.
> 1101 30th Street, N.W.
> Suite 120
> Washington, D.C. 20007
> Tel 202.944.2330
> Cell 303.589.7477
> vsherman at sgbdc.com <vsherman at law.gwu.edu>
>     ------------------------------
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> gnso-ppsai-pdp-wg-bounces at icann.org] on behalf of Metalitz, Steven [
> met at msk.com]
> *Sent:* Monday, March 17, 2014 6:13 AM
> *To:* 'Williams, Todd'; Marika Konings; gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat
> B - question 2
>
> I agree with Todd's characterization of the status of this discussion, and
> that the questions he highlights are still open.
>
>
>
> Another aspect of the second question below is how the p/p service
> provider should handle situations in which the contact information supplied
> by the customer cannot be verified. In the parallel situation involving
> non-proxy registrations, the RAA specification calls either for suspension
> of the registration, or "manual verification," which is not defined. How
> should this apply in the p/p service scenario?
>
>
>
> Steve Metalitz
>
>
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> mailto:gnso-ppsai-pdp-wg-bounces at icann.org<gnso-ppsai-pdp-wg-bounces at icann.org>]
> *On Behalf Of *Williams, Todd
> *Sent:* Friday, March 14, 2014 4:53 PM
> *To:* Marika Konings; gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat
> B - question 2
>
>
>
> Thanks Marika.  I missed part of the call on Tuesday where this may have
> been discussed, but I don't see how the draft preliminary recommendation
> follows from the attached Word document, insofar as it concludes that p/p
> customer data should be validated and verified in a manner consistent with
> the requirements outlined in the 2013 RAA.  I thought the current posture
> was that the WG has basically agreed to the 2013 RAA requirements as a
> floor, but that there was not yet agreement on: 1) whether
> validation/verification requirements should go beyond the 2013 RAA; and 2)
> if so, how.
>
>
>
> On the first question (2013 RAA vs. "more"), it appears that more of the
> responses in the attached argue for "more" than not.  That also seems to
> have been an open topic in our email threads (see attached).  Just to
> reiterate from that thread, the basic argument on the "more" side (which I
> agree with) is that in order to partially offset the delay that will
> inevitably occur when accessing p/p data, the "more" should consist of
> whatever reasonable validation/verification steps can be taken to increase
> the likelihood  that the information ultimately obtained will be accurate
> enough to facilitate contact.  I suppose that if we ultimately settle on a
> "reveal" procedure that is essentially instantaneous in certain cases (once
> we get to discussing "reveal" procedures), that may mitigate this concern.
> But absent assurances on that point, I would think we need to address it.
>
>
>
> On the second question: the attached appears to include multiple proposals
> as to what may or may not ultimately comprise the "more" (*e.g.*, email
> *and* phone vs. or; periodic/annual re-verification vs. re-verification
> with information suggesting the contact information is incorrect; etc.).
> Have we debated the relative merits of those?  Are some more likely to be
> effective than others?  I have my thoughts, but I'm curious to hear what
> everybody else thinks.
>
>
>
> Thanks all.
>
>
>
> Todd.
>
>
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> mailto:gnso-ppsai-pdp-wg-bounces at icann.org<gnso-ppsai-pdp-wg-bounces at icann.org>]
> *On Behalf Of *Marika Konings
> *Sent:* Thursday, March 13, 2014 7:04 AM
> *To:* gnso-ppsai-pdp-wg at icann.org
> *Subject:* [Gnso-ppsai-pdp-wg] For your review - updated template Cat B -
> question 2
>
>
>
> Dear All,
>
>
>
> Following our call earlier this week, please find attached the updated
> template for Category B - question 2. To facilitate your review, I've
> posted below the draft preliminary recommendation in which we've aimed to
> capture the conversation to date taking into account the language of the
> Whois Accuracy Specification Program of the 2013 RAA. If you are of the
> view that this does not accurately capture the WG's view to date and/or
> have specific suggestions for changes / edits, please share those with the
> mailing list. Also, if there are any other issues that need to be addressed
> in relation to this question and/or the preliminary recommendation, please
> share those as well.
>
>
>
> Best regards,
>
>
>
> Marika
>
>
>
> *Draft Preliminary Recommendation - Category B - question 2 (Should
> ICANN-accredited privacy/proxy service providers be required to conduct
> periodic checks to ensure accuracy of customer contact information; and if
> so, how?)*
>
>
>
> The WG recommends that proxy and privacy customer data be validated and
> verified in a manner consistent with the requirements outlined in Whois
> Accuracy Specification Program of the 2013 RAA. The WG furthermore agrees
> that in the cases where validation and verification of the P/P customer
> data was carried out by the registrar, reverification by the P/P service of
> the same, identical, information should not be required.
>
>
>
> Similar to ICANN's Whois Data Reminder Policy (
> http://www.icann.org/en/resources/registrars/consensus-policies/wdrp),
> the P/P provider should be required to inform the P/P customer annually of
> his/her requirement to provide accurate and up to date contact information
> to the P/P provider. If the P/P provider has any information suggesting
> that the P/P customer information is incorrect (such as P/P service
> receiving a bounced email notification or non-delivery notification message
> in connection with compliance with data reminder notices or otherwise) for
> any P/P customer, the P/P provider must verify or re-verify, as applicable,
> the email address(es). If, within fifteen (15) calendar days after
> receiving any such information, P/P service does not receive an affirmative
> response from the P/P customer providing the required verification, the P/P
> service shall verify the applicable contact information manually.
>
> _______________________________________________
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