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

Williams, Todd Todd.Williams at turner.com
Mon Sep 22 21:12:57 UTC 2014

Thanks Graeme.  I want to make sure I understand your point on Questions 4 and 5 – which are basically just asking p/p providers for statistics on how often they disclose customer/beneficial user information to third-party complainants (percentage-wise), and who those complainants are (LEA, 3P IP complainants, etc.).

Are you saying that if I as a customer ask my p/p provider how many times they’ve disclosed my contact information to complainants – and if so, to whom – most providers would respond that it’s exceedingly difficult to track that information, and that therefore they don’t know?

From: gnso-ppsai-pdp-wg-bounces at icann.org [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Graeme Bunton
Sent: Monday, September 22, 2014 4:50 PM
To: Keith Kupferschmid; PPSAI WG
Subject: Re: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG call earlier today

Hi Keith,

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

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 capture.

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<mailto:keithk at SIIA.net>>
To: "Mary Wong" <mary.wong at icann.org<mailto:mary.wong at icann.org>>; "PPSAI WG" <gnso-ppsai-pdp-wg at icann.org<mailto: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> [mailto: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.

  1.  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?)
  2.  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”)?
  3.  What are provider “standards" for determining disclosure to third parties?
  4.  Can providers give the WG some general information about the percentage of requests for disclosure that are successful
  5.  For Q4, do providers also have information about the type of claims those relate to e.g. If they are from LEA, 3P IP claim etc.?
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<mailto:mary.wong at icann.org>

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