[Gnso-ppsai-pdp-wg] For your review - updated template Cat B - question 2
Graeme Bunton
gbunton at tucows.com
Tue Mar 18 02:41:53 UTC 2014
Agreeing with what James and Michele have stated here.
The suspension rates would be catastrophic, with no real gain over what
the 2013 RAA ensures.
Graeme
On 3/17/2014 6:24 PM, James M. Bladel wrote:
> Everyone, this part of Michele's post is key:
>
>> If there's a bounce or any other indication that the contact details
>> are invalid then let the 2013 RAA standards apply -- if any.
>>
>
>
> The 2013 RAA requires registrar to re-verify the contact information
> if the information is known to be invalid. A bounced or undeliverable
> reminder email certainly qualifies.
>
> But to take this further, and claim that non-response = invalid
> contact information is speculation and could have catastrophic
> implications. As Michele notes, registrars work our tails off to
> drive these response rates in to the high single digits or low teens.
>
> Suspending upwards of 80% of domain names would be prohibitively
> disruptive and I've seen nothing in this thread/PDP to justify such a
> radical proposal.
>
> Thanks--
>
> J.
>
> Sent from my iPad
>
> On Mar 17, 2014, at 15:13, "Michele Neylon - Blacknight"
> <michele at blacknight.com <mailto:michele at blacknight.com>> wrote:
>
>> I cannot agree with this.
>>
>> Just because somebody does not reply to an annual email does not mean
>> anything and expecting registrars or proxy / privacy providers to do
>> anything extra based on a lack of response is completely unreasonable.
>>
>> If there's a bounce or any other indication that the contact details
>> are invalid then let the 2013 RAA standards apply -- if any.
>>
>> But expecting registrars or privacy / proxy providers to do extra
>> validation simply because a customer hasn't responded to an annual
>> whois data reminder simply will not fly.
>>
>> We send out thousands of these reminders every year. Only a tiny
>> percentage of our clients ever reply to them -- and if their details
>> haven't changed why on earth would they have to?
>>
>> Regards
>>
>>
>> Michele
>>
>> --
>>
>> Mr Michele Neylon
>>
>> Blacknight Solutions
>>
>> Hosting & Colocation, Domains
>>
>> http://www.blacknight.co/
>>
>> http://blog.blacknight.com/
>>
>> http://www.technology.ie
>>
>> Intl. +353 (0) 59 9183072
>>
>> Locall: 1850 929 929
>>
>> Direct Dial: +353 (0)59 9183090
>>
>> Fax. +353 (0) 1 4811 763
>>
>> Twitter: http://twitter.com/mneylon
>>
>> -------------------------------
>>
>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business
>> Park,Sleaty
>>
>> Road,Graiguecullen,Carlow,Ireland Company No.: 370845
>>
>> *From:*gnso-ppsai-pdp-wg-bounces at icann.org
>> <mailto: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 8:09 PM
>> *To:* Metalitz, Steven; 'Williams, Todd'; Marika Konings;
>> gnso-ppsai-pdp-wg at icann.org <mailto: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 <mailto:vsherman at law.gwu.edu>
>>
>> ------------------------------------------------------------------------
>>
>> *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
>> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>] on behalf of Metalitz,
>> Steven [met at msk.com <mailto:met at msk.com>]
>> *Sent:* Monday, March 17, 2014 6:13 AM
>> *To:* 'Williams, Todd'; Marika Konings; gnso-ppsai-pdp-wg at icann.org
>> <mailto: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>[mailto: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
>> <mailto: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>[mailto: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 <mailto: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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>> Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>
>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
>
>
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--
_________________________
Graeme Bunton
Information Specialist
Tucows Inc.
PH: 416 535 0123 ext 1634
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