[gnso-rds-pdp-wg] international law enforcement association resolution regarding domain registration data
Stephanie Perrin
stephanie.perrin at mail.utoronto.ca
Thu Apr 27 16:31:19 UTC 2017
Ethics. Competition. Consumer Trust. Accountability to the end user
and to other business interests, in short. This is not to denigrate the
issues you raise, merely to mention that there are others.
Stephanie Perrin
On 2017-04-27 07:36, Paul Keating wrote:
> "Privacy laws in one part of the world are a factor we need to be
> aware of, among other factors. “
>
> This seems to be the entire driving force behind considering a more
> restrictive (gated) access to WHOIS. If there are other reasons
> please let me know.
>
>
>
>
>
> From: <gnso-rds-pdp-wg-bounces at icann.org
> <mailto:gnso-rds-pdp-wg-bounces at icann.org>> on behalf of Michele
> Blacknight <michele at blacknight.com <mailto:michele at blacknight.com>>
> Date: Thursday, April 27, 2017 at 9:21 AM
> To: Greg Shatan <gregshatanipc at gmail.com
> <mailto:gregshatanipc at gmail.com>>, Volker Greimann
> <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>>
> Cc: RDS PDP WG <gnso-rds-pdp-wg at icann.org
> <mailto:gnso-rds-pdp-wg at icann.org>>
> Subject: Re: [gnso-rds-pdp-wg] international law enforcement
> association resolution regarding domain registration data
>
> Greg
>
> As a business owner I need to make sure that I’m not exposing
> myself or the company to unnecessary risk.
>
> While big corporations might be comfortable spending large amounts
> of money on “creative” tax arrangements that isn’t really an
> option for smaller companies like ourselves.
>
> Regards
>
>
> Michele
>
> --
>
> Mr Michele Neylon
>
> Blacknight Solutions
>
> Hosting, Colocation & Domains
>
> https://www.blacknight.com/
>
> https://blacknight.blog/
>
> https://ceo.hosting/
>
> Intl. +353 (0) 59 9183072
>
> Direct Dial: +353 (0)59 9183090
>
> -------------------------------
>
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business
> Park,Sleaty
>
> Road,Graiguecullen,Carlow,R93 X265,
>
> Ireland Company No.: 370845
>
> *From: *<gnso-rds-pdp-wg-bounces at icann.org
> <mailto:gnso-rds-pdp-wg-bounces at icann.org>> on behalf of Greg
> Shatan <gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>>
> *Date: *Wednesday 26 April 2017 at 23:38
> *To: *Volker Greimann <vgreimann at key-systems.net
> <mailto:vgreimann at key-systems.net>>
> *Cc: *RDS PDP WG <gnso-rds-pdp-wg at icann.org
> <mailto:gnso-rds-pdp-wg at icann.org>>
> *Subject: *Re: [gnso-rds-pdp-wg] international law enforcement
> association resolution regarding domain registration data
>
> We also need to be very clear about the limits of the legal
> requirements of applicable law, and the various options available
> for dealing with the law. There's no need to overcomply. Indeed
> it would be quite unreasonable to do so.
>
> Just as paying the lowest calculable income tax is perfectly
> legitimate, so is complying with the law in the least disruptive
> way possible.
>
> Greg
>
>
> *Greg Shatan
> *C: 917-816-6428
> S: gsshatan
> Phone-to-Skype: 646-845-9428
> gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>
>
> On Wed, Apr 26, 2017 at 1:06 PM, Volker Greimann
> <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>> wrote:
>
> I wish it were so simple. "Doing harm" is not necessary to be
> in violation with applicable law. Just like jaywalking,
> speeding on an empty road or crossing a red light carries a
> fine regardless of whether harm was done, privacy law too does
> not care about an actual harm.
>
> We need to be very clear about the legal requirements when we
> define the limits of what can be done with the data we
> collect, and by whom.
>
> Volker
>
> Am 26.04.2017 um 18:43 schrieb John Horton:
>
> Greg, well said. And Tim, well said. And I'll strongly +1
> Michael Hammer as well. I agree with the "do no harm"
> philosophy -- I'm not convinced that some of the proposed
> changes (e.g., those outlined in the EWG report) wouldn't
> cause more harm than the existing, admittedly imperfect,
> system. As I've said before, the importance of tools like
> Reverse Whois isn't only direct -- it's derivative as
> well. (If you enjoy the benefits of those of us who fight
> payment fraud, online abuse and other sorts of
> malfeasance, you have reverse Whois among other tools to
> thank.) Privacy laws in one part of the world are a factor
> we need to be aware of, among other factors.
>
> On Wed, Apr 26, 2017 at 9:07 AM nathalie coupet via
> gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org
> <mailto:gnso-rds-pdp-wg at icann.org>> wrote:
>
> +1
>
> Nathalie
>
> On Wednesday, April 26, 2017 12:02 PM, Victoria
> Sheckler <vsheckler at riaa.com
> <mailto:vsheckler at riaa.com>> wrote:
>
> +1
>
> Sent from my iPhone
>
>
> On Apr 26, 2017, at 8:56 AM, Greg Shatan
> <gregshatanipc at gmail.com
> <mailto:gregshatanipc at gmail.com>> wrote:
>
> Thanks for weighing in, Tim. Since this is a
> multi_stakeholder_ process, everyone is assumed to
> come in with a point of view, so don't be shy. At
> the same time, if stakeholders cling dogmatically
> to their points of view the multistakeholder model
> doesn't work.
>
> As for being out on a limb:
>
> * We haven't decided what data will be "private"
> and for which registrants (e.g., based on
> geography or entity status)
> * We haven't decided there will be "gated"
> access and what that might mean, both for
> policy and practicality
> * The question shouldn't be whether we will be
> "allowing third parties access to harvest,
> repackage and republish that data," but how we
> should allow this in a way that balances
> various concerns. Eliminating reverse Whois
> and other such services is not a goal of this
> Working Group.
>
> Our job should be to provide the greatest possible
> access to the best possible data, consistent with
> minimizing risk under reasonable interpretations
> of applicable law. We need to deal with existing
> and incoming privacy laws (and with other laws) as
> well, but not in a worshipful manner; instead it
> should be in a solution-oriented manner. This is
> not, after all, the Privacy Working Group. I'll
> +1 Michael Hammer: Rather than starting from a
> model of justifying everything and anything from a
> privacy perspective, I would suggest that it would
> be much more appropriate, other than technical
> changes such as moving towards using JSON, to
> require justification and consensus for any
> changes from the existing model(s) of WHOIS.
>
> Finally, while our purpose is not to maintain
> anyone's economic interest, economic interests may
> well be aligned with policy interests. Assuming
> that economic interests are at odds with policy
> interests is just as dangerous as assuming that
> policy interests are served by maximizing economic
> interests.
>
> Greg
>
>
> *Greg Shatan
> *C: 917-816-6428 <tel:%28917%29%20816-6428>
> S: gsshatan
> Phone-to-Skype: 646-845-9428
> <tel:%28646%29%20845-9428>
> gregshatanipc at gmail.com
> <mailto:gregshatanipc at gmail.com>
>
> On Wed, Apr 26, 2017 at 11:28 AM, Dotzero
> <dotzero at gmail.com <mailto:dotzero at gmail.com>> wrote:
>
> Adding to what Tim and Allison wrote.
>
> As a starting point, I've had an account with
> DomainTools in the past and will likely have
> one in the future, although I don't currently
> have one.
>
> There are other organizations and individuals
> which consume/aggregate whois data so I don't
> think that for the purposes of this discussion
> the focus should be on just DomainTools. I
> know researchers and academics who use this
> data to analyze all sorts of things. As has
> been pointed out, there are all sorts of folks
> staking out positions because of their
> economic (and other) interests without
> necessarily being transparent about those
> interests.
>
> It should be remembered that the Internet is
> an agglomeration of many networks and
> resources, some public and some private. At
> the same time, it is simply a bunch of
> technical standards that people and
> organizations have agreed to use to interact
> with each other. In many cases, the ultimate
> solution to abuse is to drop route. To the
> extent that good and granular information is
> not readily available, regular (innocent)
> users may suffer as owners and administrators
> of resources act to protect those resources
> and their legitimate users from abuse and
> maliciousness. The reality is that most users
> of the internet utilize a relatively small
> subset of all the resources out there. For
> some, a service like Facebook IS the Internet.
>
> It may also incite a tendency towards
> returning to a model of walled gardens. At
> various points I have heard discussions about
> the balkanization of the internet, with things
> like separate roots, etc. People should think
> very carefully about what they are asking for
> because they may not be happy with it if they
> actually get it.
>
> Rather than starting from a model of
> justifying everything and anything from a
> privacy perspective, I would suggest that it
> would be much more appropriate, other than
> technical changes such as moving towards using
> JSON, to require justification and consensus
> for any changes from the existing model(s) of
> WHOIS.
>
> Michael Hammer
>
> On Wed, Apr 26, 2017 at 10:27 AM, allison
> nixon <elsakoo at gmail.com
> <mailto:elsakoo at gmail.com>> wrote:
>
> Thank you for your email Tim.
>
> Full disclosure(because I believe in being
> transparent about this sort of thing), we
> do business with Domaintools and use their
> tools to consume whois data.
>
> "i'll close by saying I think Allison's
> point about economic value has merit. yes,
> the point of the WG is not to protect
> anyone's economic interest. I agree 100%
> with that statement and will disagree with
> anyone who thinks the future of
> DomainTools or other commercial service
> should have one iota of impact on this
> discussion."
>
> I will however disagree vehemently with
> you on this point. It is obvious that many
> of the arguments to cut off anonymous
> querying to WHOIS data are economically
> motivated. Financial concerns are cited
> numerous times in approved documents. I
> also believe the "vetting" process is
> likely to become a new revenue stream for
> someone as well. A revenue stream with
> HIGHLY questionable privacy value-add.
>
> Every dollar of income for the Domaintools
> company and others like it come from their
> clients, who see a multiplier of value
> from it. That means for every dollar spent
> on the entire whois aggregator industry
> means that a much larger amount of money
> is saved through prevented harms like
> fraud, abuse, and even fake medications
> which kill people.
>
> I think it is extremely important to
> identify what critical systems rely on
> whois (either directly or downstream), and
> determine if we are ready to give up the
> utility of these systems.
>
> We also need to identify the value of the
> ability to anonymously query whois and
> what that loss of privacy will mean as
> well. While I obviously do not make many
> queries anonymously(although our vendor
> has their own privacy policy), I
> understand this is important especially to
> those researching more dangerous actors.
> Why would $_COUNTRY dissidents want to
> query domains when their opponents would
> surely be hacking into the audit logs for
> this?
>
> On Apr 25, 2017 11:41 PM, "Chen, Tim"
> <tim at domaintools.com
> <mailto:tim at domaintools.com>> wrote:
>
> "And I hope more stakeholders in this
> multi-stakeholder process will come
> forward with their own perspectives,
> as they will differ from mine."
>
> happy to do so. DomainTools is clearly
> a stakeholder in this debate. and we
> have a fair amount of experience
> around the challenges, benefits and
> risks of whois data aggregation at scale.
>
> from the beginning of this EWG/RDS
> idea we've stood down bc i didn't
> believe our opinion would be seen as
> objective-enough given our line of
> business. but it is apparent to me
> having followed this debate for many
> weeks now, that this is a working
> group of individuals who all bring
> their own biases into the debate.
> whether they care to admit that to
> themselves or not. so we might as
> well wade in too. bc I think our
> experience is very relevant to the
> discussion.
>
> i'll do my best to be as objective as
> I can, as a domain registrant myself
> and as an informed industry participant.
>
> since our experience is working with
> security minded organizations, that is
> the context with which I will comment.
>
> since this is an ICANN working group,
> I start with the ICANN mission
> statement around the security and
> stability of the DNS. I find myself
> wanting to fit this debate to that as
> the north star. i do not see the RDS
> as purpose driven to fit the GDPR or
> any region-specific legal resolution.
> but I do see those as important
> inputs to our discussion.
>
> from a security perspective, my
> experience is that the benefits of the
> current Whois model, taken with this
> lens, far outweigh the costs. again,
> I can only speak from my experience
> here at DomainTools, and obviously
> under the current Whois regime. This
> is not to say it cannot be improved.
> From a data accuracy perspective alone
> there is enormous room for improvement
> as I think we can all agree. every
> day I see the tangible benefits to
> security interests, which for the most
> part are "doing good", from the work
> that we do. when I compare that to
> the complaints that we get bc "my PII
> is visible in your data", it's not
> even close by my value barometer
> (which my differ from others'). this
> is relevant bc any future solution
> will be imperfect as I have mentioned
> before. as Allison and others point
> out we need to measure the harm done
> by any new system that may seek to
> solve one problem (privacy?) and
> inadvertently create many more. since
> this group is fond of analogies I'll
> contribute one from the medical oath
> (not sure if this is just U.S.)
> "first, do no harm".
>
> i'll close by saying I think Allison's
> point about economic value has merit.
> yes, the point of the WG is not to
> protect anyone's economic interest. I
> agree 100% with that statement and
> will disagree with anyone who thinks
> the future of DomainTools or other
> commercial service should have one
> iota of impact on this discussion.
> but I also think "it's too expensive"
> or "it's too hard" are weak and
> dangerous excuses when dealing with an
> issue like this which has enormous and
> far reaching consequences for the very
> mission of ICANN around the security
> and stability of our internet.
>
> Tim
>
> On Mon, Apr 24, 2017 at 3:50 PM,
> allison nixon <elsakoo at gmail.com
> <mailto:elsakoo at gmail.com>> wrote:
>
> Thanks for the documentation in
> your earlier email. While I
> understand that's how things are
> supposed to work in theory, it's
> not implemented very widely, and
> unless there is enforcement, then
> it's unlikely to be useful at all.
>
> "as a given, we put ourselves in a
> certain position in terms of the
> actions we can and cannot
> recommend. We can make similar
> statements focused on registry
> operators, registrars, or any
> other stakeholder in this space.
> If we all approach this WG's task
> with the goal of not changing
> anything, we're all just wasting
> our time."
>
> There are things that people would
> be willing to change about WHOIS.
> Changes purely relating to the
> data format would not be as
> controversial. Changing to that
> RDAP json format would probably be
> an agreeable point to most here.
>
> There are two different major
> points of contention here. The
> first is the data format, second
> is the creation of a new monopoly
> and ceding power to it. By
> monopoly I mean- who are the
> gatekeepers of "gated" access?
> Will it avoid all of the problems
> that monopolies are historically
> prone to? Who will pay them? It
> seems like a massive leap of faith
> to commit to this without knowing
> who we are making the commitment to.
>
> "I do not believe it is this WG's
> responsibility to protect anyone's
>
> commercial services if those
> things are basically in response to
> deficiencies in the existing Whois
> protocol. "
>
> From my understanding of past
> ICANN working groups, registrars
> have fought against issues that
> would have increased their costs.
> And the destruction of useful
> WHOIS results(or becoming beholden
> to some new monopoly) stand to
> incur far more costs for far
> larger industries. So this
> shouldn't surprise you. If those
> economic concerns are not valid
> then I question why the economic
> concerns of registrars are valid.
>
> If entire industries are built
> around a feature you would
> consider a "deficiency", then your
> opinion may solely be your own.
> And I hope more stakeholders in
> this multi-stakeholder process
> will come forward with their own
> perspectives, as they will differ
> from mine.
>
> "Not trying to hamstring the WG.
> Just asking if this is not
> something that has already been
> solved.."
>
> Hi Paul,
>
> It's an interesting thought. This
> document was recommended to me as
> one that was approved in the past
> by the working group that outlined
> what the resulting system might
> look like. I'm still learning and
> reading about these working groups
> and what they do, and this
> document is massive.
>
> https://www.icann.org/en/syste
> m/files/files/final-report-06j
> un14-en.pdf
> <https://www.icann.org/en/system/files/files/final-report-06jun14-en.pdf>
>
> In the document, it says:
> /"Central to the remit of the EWG
> is the question of how to design a
> system that increases the accuracy
> of the data collected while also
> offering protections for those
> Registrants seeking to guard and
> maintain their privacy."/
>
> One of the things I notice is that
> any talk about actually increasing
> accuracy of whois info- via
> enforcement- is vigorously opposed
> in this group, and it's merely
> assumed that people will supply
> better quality data under the new
> system.
>
> Throughout the document it talks
> about use-cases and features
> (whois history, reverse query,
> etc), which are indeed identical
> to the features of the whois
> aggregators of current day. Such a
> system would replace them. Will
> the service quality be as good?
>
> On page 63 it gets into thoughts
> on who would be "accredited" to
> access the gated whois data. Every
> proposed scenario seems to
> recognize the resulting system
> will need to handle a large query
> volume from a large number of
> people, and one proposes
> accrediting bodies which may
> accredit organizations which may
> accredit individuals. It even
> proposes an abuse handling system
> which is also reminiscent in
> structure to how abuse is handled
> currently in our domain name
> system. Many of these proposed
> schemes appear to mimic the ways
> that the hosting industry and
> registrar industry operate, so we
> can expect that the patterns of
> abuse will be equally frequent,
> especially if higher quality data
> is supplied.
>
> The proposed scenarios all paint a
> picture of "gated" access with
> very wide gates, while
> simultaneously representing to
> domain purchasers that their data
> is safe and privacy protected. And
> this is supposed to *reduce* the
> total number of privacy
> violations? This doesn't even
> appeal to me as a consumer of this
> data.
>
> Whoever sets up this system also
> stands to inherit a lot of money
> from the soon-to-be-defunct whois
> aggregation industry. They would
> certainly win our contract,
> because we would have no choice.
> All domain reputation services,
> anti-spam, security research, etc,
> efforts will all need to pay up.
>
> After being supplied with the
> above document, I also saw a copy
> of a rebuttal written by a company
> that monitors abusive domains. I
> strongly agree with the sentiments
> in this document and I do not see
> evidence that those concerns have
> received fair consideration. While
> I do not see this new gatekeeper
> as an existential threat, I do see
> it as a likely degradation in the
> utility i do see from whois. To be
> clear, we do not do any business
> with this company.
>
> http://mm.icann.org/pipermail/
> input-to-ewg/attachments/20130
> 823/410038bb/LegitScriptCommen
> tsonICANNEWGWhoisReplacementSt
> ructure-0001.pdf
> <http://mm.icann.org/pipermail/input-to-ewg/attachments/20130823/410038bb/LegitScriptCommentsonICANNEWGWhoisReplacementStructure-0001.pdf>
>
> I also found John Bambenek's point
> in a later thread to be
> interesting- concentrating WHOIS
> knowledge solely to one
> organization allows the country it
> resides in to use it to support
> its intelligence apparatus, for
> example monitoring when its
> espionage domains are queried for,
> and targeting researchers that
> query them (since anonymous
> querying will be revoked). Nation
> states already use domains in
> operations so this monopoly is a
> perfect strategic data
> reserve. The fact that this system
> is pushed by privacy advocates is
> indeed ironic.
>
> None of those concerns appear to
> have been addressed by this group
> in any serious capacity. Before
> the addition of new members, I
> don't think many people had the
> backgrounds or skillsets to even
> understand why they are a concern.
> But I think this is a discussion
> worth having at this point in time
> for this group.
>
> On Mon, Apr 24, 2017 at 1:50 PM,
> Andrew Sullivan
> <ajs at anvilwalrusden.com
> <mailto:ajs at anvilwalrusden.com>>
> wrote:
>
> Hi,
>
> On Mon, Apr 24, 2017 at
> 07:25:47PM +0200, Paul Keating
> wrote:
> > Andrew,
> >
> > Thank you. That was helpful.
> >
> > ""Given this registrant,
> what other
> > domains are registered?" is
> a solved problem, and has been
> since the
> > early 2000s.2
> >
> > This is also traceable via
> alternative means such as
> consistencies in
> > various WHOIS fields such as
> email, address, name, etc.
>
> Well, sort of. The email,
> address, and name fields are
> _user_
> supplied. So they come from
> the other party to the
> transaction. The
> ROID is assigned by the
> registry itself. So once you
> have a match,
> you know that you are looking
> at the same object, only the same
> object, and all the same
> object(s).
>
> Email addresses in particular
> are guaranteed unique in the
> world at
> any given time (though not
> guaranteed as unique
> identifiers over
> time), so they may be useful
> for these purposes. Take it
> from someone
> named "Andrew Sullivan",
> however, that names are pretty
> useless as
> context-free identifiers :)
>
> > In reality finding out
> answers to questions such as
> > yours (above) requires
> investigation using a plethora
> of data.
>
> To be clear, finding out the
> answer to what I (meant to)
> pose(d)
> requires no plethora of data:
> it requires a single query and
> access to
> the right repository (the
> registry). In some
> theoretical system, the
> correct underlying database
> query would be something like
> this:
>
> SELECT domain_roid,
> domain_name FROM domains WHERE
> registrant_roid = ?;
>
> and you put the correct ROID
> in where the question mark is,
> and off
> you go. That will give you
> the list of all the domain
> names, and
> their relevant ROIDs,
> registered by a given
> registrant contact. At
> least one registry with which
> I am familiar once had a WHOIS
> feature
> that allowed something close
> to the above, only it would
> stop after
> some number of domains so as
> not to return too much data.
> I think the
> default was therefore LIMIT
> 50, but I also think the
> feature was
> eventually eliminated about
> the time that the ICANN
> community rejected
> IRIS as an answer to "the
> whois problem".
>
> What the above will of course
> not do is help you in the
> event Bob The
> Scammer has created dozens of
> different contacts for himself
> by (say)
> registering names through many
> different registrars. I do
> not believe
> that any registry is going to
> support such a use at least
> without
> access controls, because it
> can be expensive to answer
> such things.
> So, what you understood me to
> be asking, I think, is the
> question I
> did _not_ ask: given this
> human being or organization,
> what other
> domains are registered?" That
> does require a lot of
> different data,
> and it requires
> cross-organizational searches,
> and it requires sussing
> out when someone has lied
> also. Such research is, I
> agree, completely
> outside the scope of what any
> technical system will ever be
> able to
> offer reliably.
>
> > An entire
> > industry exists for this
> purpose and I don1t think we
> should be
> > considering replacing what
> has already been existing in
> the cyber security
> > marketplace.
>
> I do not believe it is this
> WG's responsibility to protect
> anyone's
> commercial services if those
> things are basically in
> response to
> deficiencies in the existing
> Whois protocol. In this case,
> however,
> that's not the problem.
> Linking data in multiple
> databases to a given
> real-world human being is hard
> even in systems without
> competition and
> multiple points of access.
> It's always going to require
> researchers
> for the domain name system.
>
> Best regards.
>
>
> A
>
> --
> Andrew Sullivan
> ajs at anvilwalrusden.com
> <mailto:ajs at anvilwalrusden.com>
> ______________________________
> _________________
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> <mailto:gnso-rds-pdp-wg at icann.org>
> https://mm.icann.org/mailman/l
> istinfo/gnso-rds-pdp-wg
> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>
>
>
> --
>
> ______________________________ ___
> Note to self: Pillage BEFORE burning.
>
>
> ______________________________
> _________________
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>
>
> --
>
> Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
>
> Mit freundlichen Grüßen,
>
> Volker A. Greimann
>
> - Rechtsabteilung -
>
> Key-Systems GmbH
>
> Im Oberen Werk 1
>
> 66386 St. Ingbert
>
> Tel.:+49 (0) 6894 - 9396 901 <tel:+49%206894%209396901>
>
> Fax.:+49 (0) 6894 - 9396 851 <tel:+49%206894%209396851>
>
> Email:vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>
>
> Web:www.key-systems.net <http://www.key-systems.net> /www.RRPproxy.net <http://www.RRPproxy.net>
>
> www.domaindiscount24.com <http://www.domaindiscount24.com> /www.BrandShelter.com <http://www.BrandShelter.com>
>
> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook:
>
> www.facebook.com/KeySystems <http://www.facebook.com/KeySystems>
>
> www.twitter.com/key_systems <http://www.twitter.com/key_systems>
>
> Geschäftsführer: Alexander Siffrin
>
> Handelsregister Nr.: HR B 18835 - Saarbruecken
>
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>
> Member of the KEYDRIVE GROUP
>
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>
> Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen.
>
> --------------------------------------------
>
> Should you have any further questions, please do not hesitate to contact us.
>
> Best regards,
>
> Volker A. Greimann
>
> - legal department -
>
> Key-Systems GmbH
>
> Im Oberen Werk 1
>
> 66386 St. Ingbert
>
> Tel.:+49 (0) 6894 - 9396 901 <tel:+49%206894%209396901>
>
> Fax.:+49 (0) 6894 - 9396 851 <tel:+49%206894%209396851>
>
> Email:vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>
>
> Web:www.key-systems.net <http://www.key-systems.net> /www.RRPproxy.net <http://www.RRPproxy.net>
>
> www.domaindiscount24.com <http://www.domaindiscount24.com> /www.BrandShelter.com <http://www.BrandShelter.com>
>
> Follow us on Twitter or join our fan community on Facebook and stay updated:
>
> www.facebook.com/KeySystems <http://www.facebook.com/KeySystems>
>
> www.twitter.com/key_systems <http://www.twitter.com/key_systems>
>
> CEO: Alexander Siffrin
>
> Registration No.: HR B 18835 - Saarbruecken
>
> V.A.T. ID.: DE211006534
>
> Member of the KEYDRIVE GROUP
>
> www.keydrive.lu <http://www.keydrive.lu>
>
> This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
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