[Gnso-ppsai-pdp-wg] Our Statement/Kiran's Statement

James M. Bladel jbladel at godaddy.com
Sat May 2 17:58:53 UTC 2015


Understood. 

If the individual attorneys are unable/unwilling to disclose the names of
the clients whose support they are lending to the statement, then I
recommend we fall back to their posted SOIs. Which takes us back to a
single entry for the firm itself.

Thanks—

J.


On 5/2/15, 12:54 , "Kiran Malancharuvil"
<Kiran.Malancharuvil at markmonitor.com> wrote:

>Most lawyers don't disclose their clientele list.
>
>If they are individuals members of the IPC or BC, and they are listed
>consistently with that membership and therefore the capacity of their
>participation at ICANN, that is the right way to represent themselves.
>
>Oftentimes, because of internal big firm conflicts, etc., it is
>inappropriate to ask a firm to be listed as a firm.
>
>Kiran Malancharuvil
>Internet Policy Counselor
>MarkMonitor
>415-419-9138 (m) 
>
>Sent from my mobile, please excuse any typos.
>
>> On May 2, 2015, at 10:48 AM, James M. Bladel <jbladel at godaddy.com>
>>wrote:
>> 
>> It does help clarify, but does not address the inconsistency.
>> 
>> Why would we not list the clients’ names, rather than their
>> representatives? Or one listing for the entire firm?
>> 
>> J.
>> 
>> 
>> On 5/2/15, 12:30 , "Kiran Malancharuvil"
>> <Kiran.Malancharuvil at markmonitor.com> wrote:
>> 
>>> James/Mary/Staff,
>>> 
>>> Perhaps the complexities of representation and membership in the
>>>various
>>> constituencies of the CSG isn't clear.
>>> 
>>> There are some members who are individuals, and are categorized as such
>>> (e.g: outside counsel who represent their client interests through
>>> individual participation in the group - firm name provided as guidance)
>>> and others who are businesses or organizations that appoint a
>>> representative (e.g.: firms who are represented as an entity with a
>>> single representative, corporations who are members as a business,
>>> membership organizations such as AIPLA, etc.).
>>> 
>>> Where support is given to this statement as a company, company names
>>>are
>>> stated. Where support is given as individual representatives,
>>>individual
>>> names are the more appropriate and accurate way to list.
>>> 
>>> Hope this helps clear things up. Thanks for the opportunity to clarify.
>>> 
>>> Kiran Malancharuvil
>>> Internet Policy Counselor
>>> MarkMonitor
>>> 415-419-9138 (m)
>>> 
>>> Sent from my mobile, please excuse any typos.
>>> 
>>> On May 2, 2015, at 10:17 AM, James M. Bladel
>>> <jbladel at godaddy.com<mailto:jbladel at godaddy.com>> wrote:
>>> 
>>> Mary/Staff -
>>> 
>>> These message are inconsistent.  Please confirm: Are we listing the
>>>names
>>> of individuals, or companies?
>>> 
>>> J.
>>> 
>>> 
>>> From: Kiran Malancharuvil
>>> 
>>><Kiran.Malancharuvil at markmonitor.com<mailto:Kiran.Malancharuvil at markmoni
>>>to
>>> r.com>>
>>> Date: Friday, May 1, 2015 at 20:25
>>> To: Susan Kawaguchi <susank at fb.com<mailto:susank at fb.com>>, "Prosser,
>>> Susan" <susan at domaintools.com<mailto:susan at domaintools.com>>, Frank
>>> Michlick <frank at domaincocoon.com<mailto:frank at domaincocoon.com>>,
>>> "mary.wong at icann.org<mailto:mary.wong at icann.org>"
>>> <mary.wong at icann.org<mailto:mary.wong at icann.org>>
>>> Cc: PPSAI WG 
>>> <gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>>
>>> Subject: Re: [Gnso-ppsai-pdp-wg] Our Statement/Kiran's Statement
>>> 
>>> Mary,
>>> 
>>> Can you also add Jim Bikoff, David Heasley and Val Sherman from Smith,
>>> Gambrell and Russell to the statement?  Please retain “on behalf of the
>>> proponents of the transactional distinction.”
>>> 
>>> Thanks,
>>> 
>>> Kiran
>>> 
>>> From: Kiran Malancharuvil
>>> Sent: Friday, May 01, 2015 9:34 AM
>>> To: 'Susan Kawaguchi'; Prosser, Susan; Frank Michlick;
>>> mary.wong at icann.org<mailto:mary.wong at icann.org>
>>> Cc: gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>
>>> Subject: RE: [Gnso-ppsai-pdp-wg] Our Statement/Kiran's Statement
>>> 
>>> Fantastic.  Mary, please add the signatories mentioned (LegitScript,
>>> DomainTools, Facebook) as well as MarkMonitor (company name, not
>>> individual) “on behalf of the proponents of the transactional
>>> distinction.”
>>> 
>>> Thanks,
>>> 
>>> Kiran
>>> 
>>> 
>>>From:gnso-ppsai-pdp-wg-bounces at icann.org<mailto:gnso-ppsai-pdp-wg-bounce
>>>s@
>>> icann.org> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of
>>> Susan Kawaguchi
>>> Sent: Friday, May 01, 2015 9:27 AM
>>> To: Prosser, Susan; Frank Michlick
>>> Cc: gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>
>>> Subject: Re: [Gnso-ppsai-pdp-wg] Our Statement/Kiran's Statement
>>> 
>>> Facebook can also be added to the supplemental statement
>>> Susan Kawaguchi
>>> Domain Name Manager
>>> Facebook Legal Dept.
>>> 
>>> Phone - 650 485-6064
>>> 
>>> From: <Prosser>, Susan
>>> <susan at domaintools.com<mailto:susan at domaintools.com>>
>>> Date: Friday, May 1, 2015 at 9:12 AM
>>> To: Frank Michlick
>>><frank at domaincocoon.com<mailto:frank at domaincocoon.com>>
>>> Cc: "gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>"
>>> <gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>>
>>> Subject: Re: [Gnso-ppsai-pdp-wg] Our Statement/Kiran's Statement
>>> 
>>> DomainTools can be added as a reference to Kiran's supplemental
>>>statement
>>> as well.
>>> 
>>> -Susan
>>> 
>>> 
>>> On Fri, May 1, 2015 at 7:14 AM, Frank Michlick
>>> <frank at domaincocoon.com<mailto:frank at domaincocoon.com>> wrote:
>>> Kiran,
>>> 
>>> I appreciate that you were able to put this together under the time
>>> restrictions in place. Thank you also to John Horton who added his
>>> company name to the list.
>>> 
>>> If you cannot name companies though due to the need to get approval,
>>> maybe you could name the individuals (or they could speak up here) that
>>> support/worded the statement.
>>> 
>>> So far we've got:
>>> 
>>> * Kiran Malancharuvil, Internet Policy Counselor, MarkMonitor
>>> * Legitscript
>>> 
>>> I do think that any statement included with this report should be
>>> attributable to the supporters/authors so the reader can take the
>>> background into account when reviewing the statements. Comments that
>>>are
>>> not clearly attributable, could  potentially weigh less in the eye of
>>> the reader.
>>> 
>>> @Staff: Is there a way for you to include the authors/proponents in a
>>> statement after its submission?
>>> 
>>> Best regards,
>>> /Frank
>>> --
>>> Registrar Consultant - DomainCocoon Inc.
>>> 
>>>> On 2015-05-01 9:34 AM, Kiran Malancharuvil wrote:
>>>> They are referenced as we had time to reference them in the
>>>>submission.
>>>> 
>>>> Keep in mind that we are, for the most part not individuals, but
>>>> companies and constituencies. Using company names is not feasible when
>>>> we are given two days to seek approval for a consolidated statement.
>>>> 
>>>> If you want to know who was a proponent of this distinction, you can
>>>>go
>>>> back to transcripts and the list to parse out that information.
>>>> 
>>>> K
>>>> 
>>>> Kiran Malancharuvil
>>>> Internet Policy Counselor
>>>> MarkMonitor
>>>> 415-419-9138<tel:415-419-9138> (m)
>>>> 
>>>> Sent from my mobile, please excuse any typos.
>>>> 
>>>>> On May 1, 2015, at 6:30 AM, Michele Neylon - Blacknight
>>>>> <michele at blacknight.com<mailto:michele at blacknight.com>> wrote:
>>>>> 
>>>>> Kiran
>>>>> 
>>>>> So who are the proponents of this position and how should they be
>>>>> referenced?
>>>>> 
>>>>> In the case of Kathy & Co they are named clearly in the submission
>>>>> 
>>>>> Regards
>>>>> 
>>>>> Michele
>>>>> 
>>>>> 
>>>>> --
>>>>> Mr Michele Neylon
>>>>> Blacknight Solutions
>>>>> Hosting, Colocation & Domains
>>>>> http://www.blacknight.host/
>>>>> http://blog.blacknight.com/
>>>>> http://www.blacknight.press - get our latest news & media coverage
>>>>> http://www.technology.ie
>>>>> Intl. +353 (0) 59 9183072<tel:%2B353%20%280%29%2059%20%209183072>
>>>>> Direct Dial: +353 (0)59 9183090<tel:%2B353%20%280%2959%209183090>
>>>>> Social: http://mneylon.social
>>>>> Random Stuff: http://michele.irish
>>>>> -------------------------------
>>>>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business
>>>>> Park,Sleaty
>>>>> Road,Graiguecullen,Carlow,Ireland  Company No.: 370845
>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>>> On 01/05/2015 04:47, "Kiran Malancharuvil"
>>>>>> 
>>>>>><Kiran.Malancharuvil at markmonitor.com<mailto:Kiran.Malancharuvil at markm
>>>>>>on
>>>>>> itor.com>> wrote:
>>>>>> 
>>>>>> Incidentally, I would note that the characterization of the
>>>>>>statement
>>>>>> as "Kirans statement" is incorrect. As stated before in several
>>>>>>messes
>>>>>> and as made clear in the text, the statement is from the proponents
>>>>>>of
>>>>>> the transactional distinction.
>>>>>> 
>>>>>> Kiran Malancharuvil
>>>>>> Internet Policy Counselor
>>>>>> MarkMonitor
>>>>>> 415-419-9138<tel:415-419-9138> (m)
>>>>>> 
>>>>>> Sent from my mobile, please excuse any typos.
>>>>>> 
>>>>>>> On Apr 30, 2015, at 8:19 PM, Mary Wong
>>>>>>> <mary.wong at icann.org<mailto:mary.wong at icann.org>> wrote:
>>>>>>> 
>>>>>>> We will reflect this change in the final text, thanks.
>>>>>>> 
>>>>>>> Cheers
>>>>>>> Mary
>>>>>>> 
>>>>>>> Mary Wong
>>>>>>> Senior Policy Director
>>>>>>> Internet Corporation for Assigned Names & Numbers (ICANN)
>>>>>>> Telephone: +1 603 574 4892<tel:%2B1%20603%20574%204892>
>>>>>>> Email: mary.wong at icann.org<mailto:mary.wong at icann.org>
>>>>>>> 
>>>>>>> 
>>>>>>> 
>>>>>>> 
>>>>>>> 
>>>>>>> 
>>>>>>> -----Original Message-----
>>>>>>> From: Kiran Malancharuvil
>>>>>>> 
>>>>>>><Kiran.Malancharuvil at markmonitor.com<mailto:Kiran.Malancharuvil at mark
>>>>>>>mo
>>>>>>> nitor.com>>
>>>>>>> Date: Thursday, April 30, 2015 at 22:30
>>>>>>> To: Kathy Kleiman
>>>>>>> <kathy at kathykleiman.com<mailto:kathy at kathykleiman.com>>
>>>>>>> Cc: 
>>>>>>> "gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>"
>>>>>>> <gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>>
>>>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] Our Statement/Kiran's Statement
>>>>>>> 
>>>>>>>> We changed that to "these members of the PPSAI working group."
>>>>>>>> 
>>>>>>>> Kiran Malancharuvil
>>>>>>>> Internet Policy Counselor
>>>>>>>> MarkMonitor
>>>>>>>> 415-419-9138<tel:415-419-9138> (m)
>>>>>>>> 
>>>>>>>> Sent from my mobile, please excuse any typos.
>>>>>>>> 
>>>>>>>> On Apr 30, 2015, at 7:26 PM, Kathy Kleiman
>>>>>>>> 
>>>>>>>> 
>>>>>>>><kathy at kathykleiman.com<mailto:kathy at kathykleiman.com><mailto:kathy
>>>>>>>>@k
>>>>>>>> athykleiman.com<mailto:kathy at kathykleiman.com>>> wrote:
>>>>>>>> 
>>>>>>>> Hi John,
>>>>>>>> Thanks, but I think the "and" is correct and I would leave "as
>>>>>>>>is."
>>>>>>>> 
>>>>>>>> What I do object to though, is the conclusion of Kiran's statement
>>>>>>>> which,
>>>>>>>> although a Minority Statement, represents itself [as soliciting
>>>>>>>> input on
>>>>>>>> behalf of the entire PPSAI WG.
>>>>>>>> 
>>>>>>>> Steve, Graeme and Mary,
>>>>>>>> I strongly request a change of "The PPSAI Working Group therefore
>>>>>>>> desires
>>>>>>>> public comment" to "The drafters of this supplemental statement
>>>>>>>> desire
>>>>>>>> public comment..."
>>>>>>>>  (current text) "The PPSAI Working Group therefore desires public
>>>>>>>> comment on the issue of encouraging transparent, non-anonymous
>>>>>>>> WHOIS data
>>>>>>>> for persons and entities engaged in active transactional
>>>>>>>>commercial
>>>>>>>> activity and provides the above-referenced white
>>>>>>>> 
>>>>>>>> 
>>>>>>>>paper<https://www.legitscript.com/download/White_Paper_-_Commercial
>>>>>>>>_U
>>>>>>>> se_-_
>>>>>>>> Jurisdictional_Analysis-May_11_2014.pdf> as background for
>>>>>>>> consideration."
>>>>>>>> We (as a whole WG) desire public comment on the issue as framed in
>>>>>>>> the
>>>>>>>> main report.
>>>>>>>> 
>>>>>>>> Please confirm that this will change because Kiran's statement
>>>>>>>> speaks
>>>>>>>> only for its group.
>>>>>>>> Tx,
>>>>>>>> Kathy
>>>>>>>> :
>>>>>>>> Hi Kathy,
>>>>>>>> 
>>>>>>>> Thanks for this. No objection here. One clarification: Is "mothers
>>>>>>>> and
>>>>>>>> seniors" accurate, or should it be "mothers or seniors"? I think
>>>>>>>> the way
>>>>>>>> it is currently written, someone could interpret you to be talking
>>>>>>>> about
>>>>>>>> mothers who are also senior citizens, which can certainly be true
>>>>>>>> in the
>>>>>>>> literal sense, but I believe that your intent is to be broader and
>>>>>>>> note
>>>>>>>> that while some home-based business are (impliedly) merely run by
>>>>>>>> men or
>>>>>>>> young folk, that some home-based businesses are run by mothers,
>>>>>>>> while
>>>>>>>> others are run by seniors, irrespective of their gender. I just
>>>>>>>> wonder if
>>>>>>>> the disjunctive might be better than the conjunctive in this
>>>>>>>> particular
>>>>>>>> case?
>>>>>>>> 
>>>>>>>> Thanks!
>>>>>>>> 
>>>>>>>> John Horton
>>>>>>>> President and CEO, LegitScript
>>>>>>>> 
>>>>>>>> 
>>>>>>>> 
>>>>>>>> Follow LegitScript:
>>>>>>>> LinkedIn<http://www.linkedin.com/company/legitscript-com>  |
>>>>>>>> Facebook<https://www.facebook.com/LegitScript>  |
>>>>>>>> Twitter<https://twitter.com/legitscript>  |
>>>>>>>> YouTube<https://www.youtube.com/user/LegitScript>  |
>>>>>>>> Blog<http://blog.legitscript.com>  |
>>>>>>>> Google+<https://plus.google.com/112436813474708014933/posts>
>>>>>>>> 
>>>>>>>> On Thu, Apr 30, 2015 at 2:04 PM, Kathy Kleiman
>>>>>>>> 
>>>>>>>> 
>>>>>>>><kathy at kathykleiman.com<mailto:kathy at kathykleiman.com><mailto:kathy
>>>>>>>>@k
>>>>>>>> athykleiman.com<mailto:kathy at kathykleiman.com>>> wrote:
>>>>>>>> Dear Graeme, Steve, Mary and All,
>>>>>>>> Attached please find our supplemental statement for inclusion in
>>>>>>>>the
>>>>>>>> Interim Report. Mary, could you please use the attached Word
>>>>>>>> version as
>>>>>>>> it has the formatting and highlights we seek to show in the
>>>>>>>> published
>>>>>>>> version.
>>>>>>>> 
>>>>>>>> I include a pasted version below for easy reading.
>>>>>>>> Best,
>>>>>>>> Kathy
>>>>>>>> 
>>>>>>>> 
>>>>>>>> 
>>>>>>>>-------------------------------------------------------------------
>>>>>>>>--
>>>>>>>> -----
>>>>>>>> -------
>>>>>>>> Statement of Kathy Kleiman, James Gannon and Stephanie Perrin,
>>>>>>>> Members of
>>>>>>>> the Noncommercial Stakeholders Group
>>>>>>>> 
>>>>>>>> We respectfully submit that Section 1.3.3, 1.3.3, Specific Topics
>>>>>>>>on
>>>>>>>> which there is currently no consensus within the WG, of this PPSAI
>>>>>>>> Executive Summary and Interim Report is incomplete.  There are a
>>>>>>>> number
>>>>>>>> of topics on which there is currently no consensus within the WG
>>>>>>>>and
>>>>>>>> which need considerable work. These are issues well known and
>>>>>>>>deeply
>>>>>>>> discussed.
>>>>>>>> For the purposes of clarity and to lend depth to the comments and
>>>>>>>> discussion to come, we submit this statement of how we would like
>>>>>>>> to see
>>>>>>>> Section 1.3.3 written.
>>>>>>>> 
>>>>>>>> 
>>>>>>>>-------------------------------------------------------------------
>>>>>>>>--
>>>>>>>> -----
>>>>>>>> -------------------------------------------
>>>>>>>> 1.3.3, Specific Topics on which there is currently no consensus
>>>>>>>> within
>>>>>>>> the WG
>>>>>>>> 1.3.3.1 REVEAL
>>>>>>>> The WG¹s has not yet reached final preliminary conclusions on key
>>>>>>>> details
>>>>>>>> of its ³Reveal² recommendations (See Annex E of the Interim
>>>>>>>>Report).
>>>>>>>> There are many details still under discussion and for which the WG
>>>>>>>> has
>>>>>>>> not reached consensus. These include:
>>>>>>>> 
>>>>>>>> -          What remedies should a Customer be allowed in the event
>>>>>>>> that a
>>>>>>>> Reveal Request was falsely made or the data was improperly used
>>>>>>>> (current
>>>>>>>> recommendations provide mechanism only for Provider action)?
>>>>>>>> 
>>>>>>>> -          Should Requestors be allowed to escalate each and every
>>>>>>>> rejection of a Reveal Request to a 3rd party forum, or should the
>>>>>>>> WG seek
>>>>>>>> to adopt reasonable standards and thresholds for such appeals to
>>>>>>>> avoid
>>>>>>>> unnecessary and time-consuming appeals?  (Note: a Request for
>>>>>>>> Reconsideration is already a part of the recommended process the
>>>>>>>>WG
>>>>>>>> has
>>>>>>>> agreed to by consensus.)
>>>>>>>> 
>>>>>>>> -          What rights and protections should a Customer be
>>>>>>>>allowed
>>>>>>>> and
>>>>>>>> encouraged to forth in her/his/its own defense to provide a
>>>>>>>> reasonable
>>>>>>>> defense for maintaining her/his/its privacy, even in the face of a
>>>>>>>> copyright or trademark infringement allegation?
>>>>>>>> 
>>>>>>>> -          How can Customers be protected from extraterritorial
>>>>>>>> requests
>>>>>>>> from Law Enforcement from outside their country, when the use of
>>>>>>>> their
>>>>>>>> domain name is for legal purposes in their own country, but
>>>>>>>>perhaps
>>>>>>>> purposes deemed illegal in other countries [Note: even Interpol
>>>>>>>> refuses
>>>>>>>> to act across national lines in matters of political, military,
>>>>>>>> religious
>>>>>>>> and racial issues because of the enormous differences of law.
>>>>>>>> Article 3,
>>>>>>>> Interpol Constitution]
>>>>>>>> Input and comments would be helpful on these issues.
>>>>>>>> 
>>>>>>>> 1.3.3.2 THE COMPLEXITIES OF INTRUDING INTO NATIONAL LAW
>>>>>>>> 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[1][1], 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
>>>>>>>> services. [1]
>>>>>>>> Other members of the WG noted that fundraising and membership
>>>>>>>> drives are
>>>>>>>> often performed by the very groups and organizations seeking
>>>>>>>> privacy/proxy registration for protection, including minority
>>>>>>>> political
>>>>>>>> groups, minority religious organizations, ethnic groups,
>>>>>>>> organizations
>>>>>>>> committed to change of racial policies, gender orientation groups,
>>>>>>>> and
>>>>>>>> publications engaged in freedom of expression. These groups and
>>>>>>>> their
>>>>>>>> representatives note that, in the laws of their countries, the
>>>>>>>>mere
>>>>>>>> collection of a donation or membership fee does not change their
>>>>>>>> status
>>>>>>>> from ³non-commercial² to commercial. Others noted that
>>>>>>>>³non-profit²
>>>>>>>> status is limited to only a few countries.
>>>>>>>> Further, many of organizations, small businesses, home-based
>>>>>>>> businesses
>>>>>>>> (including those run by mothers and seniors) conduct their
>>>>>>>>financial
>>>>>>>> transactions through 3rd party e-commerce companies, such as
>>>>>>>> PayPal, and
>>>>>>>> thus are not processing the financial transactions directly.
>>>>>>>> Accordingly,
>>>>>>>> many members in the WG submit there is no reason to breach the
>>>>>>>> proxy/privacy of organizations and businesses purely and solely
>>>>>>>>for
>>>>>>>> this
>>>>>>>> reason.
>>>>>>>> Many members many in the WG submit that content regulation is far
>>>>>>>> beyond
>>>>>>>> the scope of ICANN and properly the scope of national laws ­ some
>>>>>>>>of
>>>>>>>> which has taken initiatives in this area which are clearly defined
>>>>>>>> and
>>>>>>>> properly limited in scope and application (e.g., Germany).
>>>>>>>> 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: ³domains used for
>>>>>>>> online
>>>>>>>> financial transactions for commercial purpose should be ineligible
>>>>>>>> for
>>>>>>>> privacy and proxy registrations.²
>>>>>>>> This suggestion has been debated strongly by the members of the WG
>>>>>>>> and
>>>>>>>> has not reached consensus as others submitted that:
>>>>>>>> "Attempting to distinguish the end purposes of a domain
>>>>>>>> registration is
>>>>>>>> not practicable for the purposes of determining eligibility for
>>>>>>>> privacy/proxy services, and will unfairly discriminate against
>>>>>>>> vulnerable
>>>>>>>> groups, entrepreneurs, small businesses and organizations who wish
>>>>>>>> to
>>>>>>>> exercise their rights of freedom of expression rights on the
>>>>>>>> Internet.
>>>>>>>> Input requested on the full issues, including questions below:
>>>>>>>> €        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?
>>>>>>>> €        Is this type of content regulation outside of ICANN's
>>>>>>>> scope and
>>>>>>>> mandate and the proper province of national law?
>>>>>>>> 
>>>>>>>> 
>>>>>>>> ________________________________
>>>>>>>> 
>>>>>>>> [1] The WG notes that the WHOIS RT had specifically acknowledged
>>>>>>>> that P/P
>>>>>>>> services can be and are used to address legitimate interests, both
>>>>>>>> commercial and non-commercial.
>>>>>>>> 
>>>>>>>> 
>>>>>>>> _______________________________________________
>>>>>>>> Gnso-ppsai-pdp-wg mailing list
>>>>>>>> 
>>>>>>>> 
>>>>>>>>Gnso-ppsai-pdp-wg at icann.org<mailto:Gnso-ppsai-pdp-wg at icann.org><mai
>>>>>>>>lt
>>>>>>>> o: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
>>>>>>>> 
>>>>>>>> 
>>>>>>>> _______________________________________________
>>>>>>>> Gnso-ppsai-pdp-wg mailing list
>>>>>>>> 
>>>>>>>> 
>>>>>>>>Gnso-ppsai-pdp-wg at icann.org<mailto:Gnso-ppsai-pdp-wg at icann.org><mai
>>>>>>>>lt
>>>>>>>> o: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
>>>>>>>> _______________________________________________
>>>>>>>> Gnso-ppsai-pdp-wg mailing list
>>>>>>>> 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
>>>>>>> _______________________________________________
>>>>>>> Gnso-ppsai-pdp-wg mailing list
>>>>>>> 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
>>>>>> _______________________________________________
>>>>>> Gnso-ppsai-pdp-wg mailing list
>>>>>> 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
>>>> _______________________________________________
>>>> Gnso-ppsai-pdp-wg mailing list
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>>> 
>>> 
>>> _______________________________________________
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>>> 
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>> 



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