[Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3

Graeme Bunton gbunton at tucows.com
Tue Apr 28 21:17:12 UTC 2015

Thanks to all WG members for a very productive call earlier today(and to 
Steve for his chairing acumen).  The co-chairs and staff met this 
afternoon to tie down two loose ends from the call.

Regarding the deadline for public comments on the Initial Report, we 
recognize there is considerable support for extending the public comment 
period to 60 days instead of the standard 40 days on which we have all 
been planning.   We are prepared to agree to this, but with the caveat 
that this will have repercussions on the pace and intensity of our work 
once public comments have been received. Specifically, if the public 
comment deadline is extended until July 3 (60 days after our publication 
date of May 4), we will need to plan on at least weekly calls throughout 
July and August, some of which may need to be more than an hour in 
length, to review these comments and move toward a Final Report.  
Otherwise, we jeopardize the prospects for getting the Final Report in 
front of the GNSO council no later than the Dublin ICANN meeting.  As 
was noted on the call today, many additional steps need to take place 
even after this WG issues its Final Report before any new accreditation 
system can be implemented, so the time pressure imposed by the 
expiration of the Interim Specification at the end of next year is 
already real.

Also, as previously announced over the past few weeks, if any WG members 
(or group of members) wish to submit a brief separate or additional 
statement for inclusion in the package posted for public comment next 
Monday, such statements need to be received by staff no later than 
Thursday, April 30.

Lastly, the other loose end involves proposed revisions to section 1.3.3 
of the Initial Report, which were presented on the call earlier today 
but which we did not have time to discuss fully.  We agree that this 
section could benefit from some revision, but believe it should take the 
form of greater concision, not additional presentation of arguments for 
the divergent positions.  Thus we suggest that section 1.3.3 be revised 
to read as follows:


    Although the WG agreed that the mere fact that a domain name is
    registered by a commercial entity or by anyone conducting commercial
    activity should not preclude the use of P/P services , there was
    disagreement over whether domain names that are actively used for
    commercial transactions (e.g. the sale or exchange of goods or
    services) should be prohibited from using P/P services. While most
    WG members did not believe such a prohibition is necessary or
    practical, some members believed that registrants of such domain
    names should not be able to use or continue using proxy or privacy

    For those that argued that it is necessary and practical to limit
    access to P/P services to exclude commercial entities, the following
    text was proposed to clarify and define their position: “domains
    used for online financial transactions for commercial purpose should
    be ineligible for privacy and proxy registrations.”

    Public comment is therefore specifically invited on the following

      * Should registrants of domain names associated with commercial
        activities and which are used for online financial transactions
        be prohibited from using, or continuing to use, privacy and
        proxy services?
      * If so, will it be useful to adopt a definition of “commercial”
        or “transactional” to define those domains for which P/P service
        registrations should be disallowed? And if so, what should the
        definition(s) be?”
      * Will it be necessary to make a distinction in the WHOIS data
        fields to be displayed as a result?


Graeme Bunton & Steve Metalitz

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

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