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

Volker Greimann vgreimann at key-systems.net
Tue Mar 18 15:11:36 UTC 2014

Am I seeing this correctly? There are four members of the same law firm 
on this WG, supporting each others positions?


Am 17.03.2014 21:08, schrieb Valeriya Sherman:
> 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 
> [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] *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> 
> [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.
> _______________________________________________
> Gnso-ppsai-pdp-wg mailing list
> Gnso-ppsai-pdp-wg at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg

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