[gnso-rds-pdp-wg] international law enforcement association resolution regarding domain registration data
John Bambenek
jcb at bambenekconsulting.com
Thu Apr 27 21:06:31 UTC 2017
Asked and answered elsewhere. If you define the purpose of RDS as
merely the ability to convey to a buyer a domain name, then yes, all of
this is suspect. But that isn't the purpose of ICANN and to many of us,
not the only, sole purpose of WHOIS.
On 4/27/2017 4:02 PM, Ayden Férdeline wrote:
>>
>> the consumer is free to choose which lane they want to be in, and the
>> rest of us can use that data how we see fit.
>>
> This is not a solution that would satisfy the spirit of the GDPR, because:
>
> * We must describe a purpose before we collect data.
> * Once a purpose is ascribed, the data collected must only be used
> for that purpose.
> * Obtaining consent is one way to justify the processing of their
> personal data, but consent is not a waiver for disproportionate or
> unlawful processing.
>
> - Ayden
>
>
>> -------- Original Message --------
>> Subject: Re: [gnso-rds-pdp-wg] international law enforcement
>> association resolution regarding domain registration data
>> Local Time: 27 April 2017 7:34 PM
>> UTC Time: 27 April 2017 18:34
>> From: gnso-rds-pdp-wg at icann.org
>> To: gnso-rds-pdp-wg at icann.org
>>
>>
>> That was why I advocate whois privacy (or equivalent). WHOIS would
>> still be public be some elements need to be public (nameservers) or
>> it just doesn't work... the consumer is free to choose which lane
>> they want to be in, and the rest of us can use that data how we see fit.
>>
>>
>> On 4/27/2017 1:17 PM, tisrael at cippic.ca wrote:
>>> Hi there,
>>>
>>> Sorry to interject here.
>>>
>>> I think a governance exercise here must look beyond what the law
>>> strictly allows in terms of formulating WHOIS and to how a given
>>> WHOIS configuration will impact on recognized legal privacy protections.
>>>
>>> So, in Canada, our courts have built legal protections and
>>> safeguards into the civil discovery process that determine under
>>> what conditions anonymous online activity can be identified.
>>> Similarly, we have constitutional protections that prevent private
>>> entities from voluntarily identifying anonymous online actors to law
>>> enforcement if certain procedural steps aren't met.
>>>
>>> Making WHOIS public by default would effectively bypass all of these
>>> safeguards. Surely that, then, also has to be a consideration in a
>>> governance process of this sort?
>>>
>>> Best regards,
>>> Tamir
>>>
>>>
>>> On 2017-04-27 2:07 PM, Paul Keating wrote:
>>>> All good questions but I would like to start with the scope of the.
>>>> Urrent laws as it applies to current Whois data.
>>>>
>>>> Sincerely,
>>>> Paul Keating, Esq.
>>>>
>>>> On Apr 27, 2017, at 7:47 PM, allison nixon <elsakoo at gmail.com
>>>> <mailto:elsakoo at gmail.com>> wrote:
>>>>
>>>>> I'm sure everyone's schedules are quite busy, and they will manage.
>>>>>
>>>>> We need a proper legal authority here because it's potentially
>>>>> falsely being presumed that the use of WHOIS data is illegal and
>>>>> noncompliant in the first place. We simply do not know if that is
>>>>> a factual premise. We also need to take into account laws other
>>>>> than the EU privacy laws, and laws outside the EU. A number of
>>>>> exemptions exist within these privacy laws and those people
>>>>> throwing around the legal arguments accusing this of being illegal
>>>>> don't seem to ever mention that fact. We need an unbiased legal
>>>>> expert.
>>>>>
>>>>> What if a country is trying to enforce a law that is deemed
>>>>> distasteful (violates human rights, etc), and their registrant is
>>>>> located within the country? does the gatekeeper have grounds to
>>>>> deny them the ability to enforce their own laws against their own
>>>>> people, and if so when?
>>>>>
>>>>> How does WHOIS play into other areas of compliance, such as
>>>>> know-your-customer, complying with sanctions, anti-money
>>>>> laundering, HIPPAA, PCI, etc? Is complying to one law more
>>>>> important than complying to another, if one had to choose?
>>>>>
>>>>> Will the gatekeeper comply with anti-trust laws?
>>>>>
>>>>> How does privacy law prohibit information collection on
>>>>> registrants yet collect detailed PII info on queriers and subject
>>>>> them to audit? What happens if the gatekeeper is hacked into for
>>>>> those audit logs? What happens if the gatekeeper receives a
>>>>> national security letter?
>>>>>
>>>>> All of these are legal questions that need to be answered without
>>>>> bias and with full understanding of the facts.
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> On Thu, Apr 27, 2017 at 12:42 PM, Stephanie Perrin
>>>>> <stephanie.perrin at mail.utoronto.ca
>>>>> <mailto:stephanie.perrin at mail.utoronto.ca>> wrote:
>>>>>
>>>>> And we need to have a lengthy discussion about precisely who
>>>>> that legal expert might be. It appears that many of our
>>>>> members are prepared to reject the views of the Data
>>>>> Protection Authorities themselves, who took the time out of
>>>>> their extraordinarily busy schedules to come and speak with us
>>>>> in Copenhagen.
>>>>>
>>>>> Stephanie Perrin
>>>>>
>>>>>
>>>>> On 2017-04-27 09:14, Gomes, Chuck via gnso-rds-pdp-wg wrote:
>>>>>>
>>>>>> We as a WG have not requested funds for a legal expert, but I
>>>>>> don’t know what staff has built into the Draft FY18 budget.
>>>>>>
>>>>>>
>>>>>>
>>>>>> Marika – Did the Policy Team build any funds into the Draft
>>>>>> FY18 budget for legal experts?
>>>>>>
>>>>>>
>>>>>>
>>>>>> Note that this is a very time sensitive issue because the
>>>>>> comment period on the Draft FY18 Operating Plan and Budget
>>>>>> ends tomorrow.
>>>>>>
>>>>>>
>>>>>>
>>>>>> Lisa/Marika/Amr – Please prepare a draft comment on the
>>>>>> Budget that the Leadership Team or me as Chair could send on
>>>>>> Friday in this regard. If funds have not been proposed for
>>>>>> such expenses, I think we should at a minimum raise the issue
>>>>>> in the public comment forum even if there is not time to
>>>>>> propose specific details.
>>>>>>
>>>>>>
>>>>>>
>>>>>> Chuck
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> *From:*gnso-rds-pdp-wg-bounces at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg-bounces at icann.org>
>>>>>> [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of
>>>>>> *Paul Keating
>>>>>> *Sent:* Thursday, April 27, 2017 7:55 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:* [EXTERNAL] Re: [gnso-rds-pdp-wg] international law
>>>>>> enforcement association resolution regarding domain
>>>>>> registration data
>>>>>>
>>>>>>
>>>>>>
>>>>>> Has the WG requested funds to retain a legal expert to
>>>>>> educate us on the actual laws at issue?
>>>>>>
>>>>>>
>>>>>>
>>>>>> *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: *Thursday, April 27, 2017 at 12:38 AM
>>>>>> *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 <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 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>
>>>>>> ______________________________
>>>>>> _________________
>>>>>> gnso-rds-pdp-wg
>>>>>> mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <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.
>>>>>>
>>>>>>
>>>>>> ______________________________
>>>>>> _________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <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>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> ______________________________
>>>>>> _________________
>>>>>>
>>>>>>
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <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>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> ______________________________
>>>>>> _________________
>>>>>>
>>>>>>
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/
>>>>>> listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>>
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>>
>>>>>> _______________________________________________
>>>>>>
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>>
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>> --
>>>>>>
>>>>>> 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
>>>>>>
>>>>>> Umsatzsteuer ID.: DE211006534
>>>>>>
>>>>>>
>>>>>>
>>>>>> Member of the KEYDRIVE GROUP
>>>>>>
>>>>>> www.keydrive.lu <http://www.keydrive.lu>
>>>>>>
>>>>>>
>>>>>>
>>>>>> 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.
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>>
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list gnso-rds-pdp-wg at icann.org
>>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>>
>>>>>> _______________________________________________
>>>>>> gnso-rds-pdp-wg mailing list
>>>>>> gnso-rds-pdp-wg at icann.org <mailto:gnso-rds-pdp-wg at icann.org>
>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>> _______________________________________________
>>>>> gnso-rds-pdp-wg mailing list gnso-rds-pdp-wg at icann.org
>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>> <https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg>
>>>>>
>>>>> --
>>>>> _________________________________ Note to self: Pillage BEFORE
>>>>> burning.
>>>>> _______________________________________________ gnso-rds-pdp-wg
>>>>> mailing list gnso-rds-pdp-wg at icann.org
>>>>> <mailto:gnso-rds-pdp-wg at icann.org>
>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>> _______________________________________________
>>>> gnso-rds-pdp-wg mailing list
>>>> gnso-rds-pdp-wg at icann.org
>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>> --
>>> Tamir Israel Staff Lawyer Samuelson-Glushko Canadian Internet Policy
>>> & Public Interest Clinic (CIPPIC) University of Ottawa | Faculty of
>>> Law | CML Section 57 Louis Pasteur Street Ottawa | ON | K1N 6N5 ☎:
>>> (613) 562-5800 ext. 2914 Fax: (613) 562-5417 PGP Key: 0x7F01E2C7
>>> <https://cippic.ca/documents/keys/tisrael@cippic.ca-pub.txt> PGP
>>> Fingerprint: 871C 31EC B6CC 3029 A1A1 14C4 D119 76EC 7F01 E2C7 *♺ Do
>>> you really need to print this email? / Est-ce nécessaire d’imprimer
>>> ce courriel?*
>>> _______________________________________________
>>> gnso-rds-pdp-wg mailing list
>>> gnso-rds-pdp-wg at icann.org
>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/gnso-rds-pdp-wg/attachments/20170427/bc7e14c7/attachment-0001.html>
More information about the gnso-rds-pdp-wg
mailing list