[Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG call earlier today

Graeme Bunton gbunton at tucows.com
Mon Sep 22 20:49:56 UTC 2014

Hi Keith,

We've seen descriptions of their processes from GoDaddy, Tucows and 

What I think should be inferred though from our discussions and from 
those descriptions is that there are no established standards for 
disclosure because they are exceedingly difficult to craft.  In many 
respects, standards would make the jobs of our compliance teams 
significantly easier. However, in our years of doing business we have 
never come to a place where we've found a set of rules that we can apply 
to the variety of requests that we get.

This working group is attempting to codify rules (in a relatively short 
time frame) that service providers haven't been able to achieve 
individually.  This isn't to say we shouldn't try, but it's clearly not 
easy.  There are few black and white cases, and unending reams of gray 
requests, which is why we've heard so much about providers protecting 
their ability to exercise discretion.

As for the below questions:

1. I think I answered this previously in my description of our service.
2. is an idea we had previously considered, 'self-requested take-down' 
might be something we offer pending the outcome of this WG
3. We do not have one for private 3rd parties. Excluding LEA and UDRP

4. & 5.  Answers to these require the provider to be using some sort of 
ticketing/request system that allows tagging/categorization and 
reporting based on outcomes.   Many may not be big enough to have this 
sort of system in place, or have systems that don't offer these 
features.   This is probably exceedingly difficult information to 

Graeme Bunton
Manager, Management Information Systems
Manager, Public Policy
Tucows Inc.
PH: 416 535 0123 ext 1634

------ Original Message ------
From: "Keith Kupferschmid" <keithk at SIIA.net>
To: "Mary Wong" <mary.wong at icann.org>; "PPSAI WG" 
<gnso-ppsai-pdp-wg at icann.org>
Sent: 9/22/2014 1:58:36 PM
Subject: Re: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG 
call earlier today

>My apologies if I missed something, but I have not seen any responses 
>to the questions posed below.  I think it would be very helpful if the 
>P/P providers could respond to these questions prior to tomorrow’s 
>meeting if at all possible.
>Keith Kupferschmid
>From:gnso-ppsai-pdp-wg-bounces at icann.org 
>[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Mary Wong
>Sent: Tuesday, September 16, 2014 6:38 PM
>Subject: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG 
>call earlier today
>Dear WG members,
>With the Chairs’ consent, I’m sending on the questions that were asked 
>by several WG members during the call earlier today, in the hopes that 
>those members who are or know of P/P providers and their practices can 
>respond. If links to or copies of provider practices and policies can 
>be provided, that would be very helpful too.
>What are provider practices regarding customer notification when a 
>disclosure request is received, and is the customer given the 
>opportunity to respond? (Note - on the call, James had agreed to 
>provide information about DBP; Graeme and Michele had responded on 
>behalf of their respective companies – perhaps other providers besides 
>DBP can also step in here?)Does any provider offer its customer an 
>option other than disclosure or publication, e.g. an opportunity to 
>cancel the registration instead (i.e. what some WG members have 
>mentioned as a “takedown”)?What are provider “standards" for 
>determining disclosure to third parties? Can providers give the WG some 
>general information about the percentage of requests for disclosure 
>that are successfulFor Q4, do providers also have information about the 
>type of claims those relate to e.g. If they are from LEA, 3P IP claim 
>As also noted on the call, the Chairs will discuss some of the 
>responses and suggestions that were made, with a view toward hopefully 
>offering some kind of summary or recommendation in time for the call 
>next week.
>Thanks and cheers
>Mary Wong
>Senior Policy Director
>Internet Corporation for Assigned Names & Numbers (ICANN)
>Telephone: +1 603 574 4892
>Email: mary.wong at icann.org
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