[gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018

Fri Aug 10 19:47:41 UTC 2018

Without commenting on the specific opentime decision, I will note that the
URS was, I believe, designed to be a system where the respondents didn't
necessarily need to have lawyers to defend themselves, so I'm not sure the
"they should have had better counsel" argument holds up. Also, I believe
that the burden of proof in URS cases is meant to lie with the trademark
holders...

On Fri, Aug 10, 2018 at 2:34 PM, <gmlevine at researchtheworld.com> wrote:

> I just want to jump in for the record regarding <opentime.com>.  I have
> no skin in this exchange.  The topic started out with URS decisions and
> suddenly swerved to "wrong" UDRP decisions.  The <opentime.com> decision
> is not a "wrong" decision if by wrong one means that the record was crystal
> clear in Respondent's favor. As I read Georges' decision, Respondent's
> representative did less than a stellar job in presenting a defense: "Given
> the misrepresentations, conflicting and unsubstantiated statements, and
> lack of explanations by Respondent, this Panel based on the evidentiary
> record place before it, has doubts about the credibility of Respondent's
> claim of prior use of OPEN TIME and thus concludes that Complainant has
> prior and superior rights in OPENTIME."  I take the decision to be a
> cautionary tale, one that defense counsel should pay attention to and learn
> from. Fortunately, Kyle Burns went to litigation counsel who understand how
> to marshal a defense (or in this case since the matter was settled by
> declaration that the registration was not unlawful, a proper claim under
> the ACPA).  Gmlevine
>
> -----Original Message-----
> From: gnso-rpm-wg <gnso-rpm-wg-bounces at icann.org> On Behalf Of
> Nahitchevansky, Georges
> Sent: Thursday, August 9, 2018 6:16 PM
> To: George Kirikos <icann at leap.com>; gnso-rpm-wg at icann.org
> Subject: Re: [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
>
> George K.  You miss the point.  No one is arguing against discussing the
> issue on what a decision should contain or addressing the 7% issue.  The
> renumeration point goes to the point of how detailed, etc a decision has to
> be in an expedited matter where a Panelist gets paid very little and has to
> turn around a decision quite quickly.  It's all about finding a workable
> balance if you want quality panelists.
>
> On your panelist point, there is something that some do not seem to
> appreciate or want to understand.  A panelist usually spends much time
> reviewing a matter and the submissions made.  As with any case, the claims
> will ultimately rise or fall on the parties' submissions and evidence and
> on how well the parties marshal/present their evidence and arguments.
> Ultimately, many of the decisions will turn on the evidence presented to
> the Panel and on the quality and credibility of such evidence.
>
> Georges Nahitchevansky
> Kilpatrick Townsend & Stockton LLP
> The Grace Building | 1114 Avenue of the Americas | New York, NY
> 10036-7703
> office 212 775 8720 | fax 212 775 8820
> ghn at kilpatricktownsend.com | www.kilpatricktownsend.com
>
>
> -----Original Message-----
> From: gnso-rpm-wg <gnso-rpm-wg-bounces at icann.org> On Behalf Of George
> Kirikos
> Sent: Thursday, August 9, 2018 5:43 PM
> To: gnso-rpm-wg at icann.org
> Subject: Re: [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
>
> As Michael correctly noted, *all* cases should have reasons to support the
> determination. That's basic quality control that is missing here.
>
> Georges N is trying to mix in panelist remuneration to the debate, which
> is not relevant. I'm sure he considers himself a "good"
> panelist, but even he makes mistakes in judgment, which isn't correlated
> to what he's paid. Case in point is the OpenTime.com UDRP:
>
> http://www.wipo.int/amc/en/domains/search/text.jsp?case=D2016-2328
>
> which he ordered transferred to the complainant (in a long decision, which
> took time to write presumably). As it turns out, this went to court, and
> the outcome was that the domain stays with the domain owner (see attached
> judgment). So, I don't think "getting it right" is correlated in any way
> with the remuneration. You can be paid a lot and "get it wrong", or you can
> be paid peanuts but "get it right" -- it's all about one's standards.
>
> For a given remuneration, panelists are expected to do the job with
> diligence, which includes giving reasons so that both sides (and the
> public) understand why the determination was made. Panelists shouldn't cut
> corners as some form of protest over pay that they willingly agreed to do
> for the job. Given how short URS complaints are (500 words max) and typical
> reading speed (100+ words per minute), the actual hourly rate of URS
> panelists is not insignificant (I believe they are batched in groups of 5
> cases per panelist, too). Most responses start off with a standard
> template, so it should only take minutes to do proper reasons in most cases
> (especially the "slam dunk"
> ones).
>
> Sincerely,
>
> George Kirikos
> 416-588-0269
> http://www.leap.com/
>
>
> On Thu, Aug 9, 2018 at 5:14 PM, Nahitchevansky, Georges <
> ghn at kilpatricktownsend.com> wrote:
> > The issue of costs is that Panelists get paid a fairly low amount from
> > the
> > $300 or so filing.  If you want decent panelists, we  can’t make the
> > process so burdensome that folks do not want to get involved.  I
> > recognize that being a panelist is more or less pro bono work, but the
> > more requirements you impose on the decision the more burdensome it
> > will become (particularly as this is an expedited proceeding with a
> short turn-around time frame).
> > The bottom line is that in 93% of the cases (or even your 87% number)
> > there were details provided (some more robust than others) – so
> > panelists are as a whole providing decisions where the logic can be
> > ascertained.  We just need to come up with something easy and workable
> > to address the 7% issue (or 13% by your count) in the context of an
> expedited proceeding.
> >
> >
> >
> > Georges Nahitchevansky
> > Kilpatrick Townsend & Stockton LLP
> > The Grace Building | 1114 Avenue of the Americas | New York, NY
> > 10036-7703 office 212 775 8720 | fax 212 775 8820
> > ghn at kilpatricktownsend.com | My Profile | vCard
> >
> > From: Tushnet, Rebecca <rtushnet at law.harvard.edu>
> > Sent: Thursday, August 9, 2018 4:32 PM
> >
> >
> > To: Nahitchevansky, Georges <ghn at kilpatricktownsend.com>; Ariel Liang
> > <ariel.liang at icann.org>; gnso-rpm-wg at icann.org
> > Subject: Re: ACTIONS & NOTES: RPM PDP WG 08 August 2018
> >
> >
> >
> > I would think that the rules should aim for decisions that meet
> > minimal standards for everyone, not just for most people.  I have
> > heard cost mentioned before, but I'm not sure what makes the 87% of
> > decisions with at least a sentence explaining the basis for decision
> > more costly or noticeably harder to create (especially if standard
> > forms are provided), since I presume that the panelist has a basis for
> > decision in his or her mind and thus doesn't need to do more work to
> > generate that reason. Does NAF charge more for decisions that specify
> their reasoning?
> >
> > ________________________________
> >
> > From: Nahitchevansky, Georges <ghn at kilpatricktownsend.com>
> > Sent: Thursday, August 9, 2018 4:02:07 PM
> > To: Tushnet, Rebecca; Ariel Liang; gnso-rpm-wg at icann.org
> > Subject: RE: ACTIONS & NOTES: RPM PDP WG 08 August 2018
> >
> >
> >
> > Thank you for your comments.  Well, while the sky is falling is
> > obviously not the standard but saying and acting as though something
> > is a significant due process issue, when it isn’t, is quite
> > misleading.  I think we can agree that what should be in a decision
> > should be discussed (as noted in the documents already), but that has
> > to be tempered by the fees being charged for a URS, the fees paid to
> > panelists from such and the time needed to draft a decision.  I just
> > thought I would make this clear because some editorializing was being
> thrown out up front.  Your welcome!
> >
> >
> >
> > Georges Nahitchevansky
> > Kilpatrick Townsend & Stockton LLP
> > The Grace Building | 1114 Avenue of the Americas | New York, NY
> > 10036-7703 office 212 775 8720 | fax 212 775 8820
> > ghn at kilpatricktownsend.com | My Profile | vCard
> >
> > From: Tushnet, Rebecca <rtushnet at law.harvard.edu>
> > Sent: Thursday, August 9, 2018 3:35 PM
> > To: Nahitchevansky, Georges <ghn at kilpatricktownsend.com>; Ariel Liang
> > <ariel.liang at icann.org>; gnso-rpm-wg at icann.org
> > Subject: Re: ACTIONS & NOTES: RPM PDP WG 08 August 2018
> >
> >
> >
> > I'm happy to take this up on the merits (among other things, I don't
> > recall saying the sky was falling or understanding that there was
> > consensus that sky disaster was the standard for recommending fixes)
> > but I expect we will repeat ourselves a lot when we get to the "for WG
> > Discussion" parts. My current request is for this suggestion/potential
> > recommendation, which is already present in the document, to be
> > repeated or otherwise cross-referenced so that it is part of more than
> > Defenses in the main document.  Thank you!
> >
> > ________________________________
> >
> > From: Nahitchevansky, Georges <ghn at kilpatricktownsend.com>
> > Sent: Thursday, August 9, 2018 3:27:09 PM
> > To: Tushnet, Rebecca; Ariel Liang; gnso-rpm-wg at icann.org
> > Subject: RE: ACTIONS & NOTES: RPM PDP WG 08 August 2018
> >
> >
> >
> > Rebecca:
> >
> >
> >
> > I do not disagree with the notion that we should discuss what a
> > decision should contain, but I don’t think we have a consensus as to
> > what that should be in the URS context (given the pricing of URS
> > proceedings).  Moreover, a review of the URS cases makes your 13%
> > number and comment of “significant due process and implementation
> > issues” point questionable.  At NAF for example, there were 827 cases
> that that your research assistants reviewed.
> > I found a total of about 103 that your team flagged as having no
> > articulated decisions.  I would agree that in 58 cases the decisions
> > lacked details, but in 45 cases there were details that sufficiently
> > let you know what the case was about and the basis of the resolution.
> > I am sure we can argue about these 45 cases and whether they should
> > say more, but ultimately we are really only talking about 58 cases
> > that actually do not have any specific details and just provide the
> > standard and a resolution (although I note that most of these cases
> > involve domain names based on fairly well known marks such as NISSAN,
> > DATSUN, TEXACO, BLOOMBERG, BNP PARIBAS etc., so you pretty much know
> > what trademark was involved.).  In all, we are really talking about 7%
> of the cases that have no details, which is not significant.
> >
> >
> >
> > Again, we can discuss what the decisions should provide, but I don’t
> > think we ought to be qualifying this as a “significant” issue per se
> > (as 93% of them have details).  There are other issues being
> > considered in the URS review that have better percentage numbers as an
> > issue that are viewed as not being significant per se. The point is
> > that the URS looks to be working appropriately and there are probably
> > some tweaks and refinements needed but this is not sky is falling issue.
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> > From: gnso-rpm-wg <gnso-rpm-wg-bounces at icann.org> On Behalf Of
> > Tushnet, Rebecca
> > Sent: Thursday, August 9, 2018 1:22 PM
> > To: Ariel Liang <ariel.liang at icann.org>; gnso-rpm-wg at icann.org
> > Subject: Re: [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
> >
> >
> >
> > My apologies for missing the meeting.  Comment on the big document:
> >
> > This is currently only covered under Defenses but I would put it for
> > discussion/recommendations under 2. Examiners’ Guide/3. Other Issues
> > because it goes beyond defenses: Decisions should contain basic
> > information, including what the trademark is, what the finding of
> > abuse is and/or what findings are on any defenses—13% of decisions did
> > not, and this raises significant due process and implementation issues.
> >
> > ________________________________
> >
> > From: gnso-rpm-wg <gnso-rpm-wg-bounces at icann.org> on behalf of Ariel
> > Liang <ariel.liang at icann.org>
> > Sent: Wednesday, August 8, 2018 3:56:54 PM
> > To: gnso-rpm-wg at icann.org
> > Subject: [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
> >
> >
> >
> > Dear All,
> >
> >
> >
> > Please see below the action items and notes captured by staff from the
> > RPM PDP WG call held on 08 August 2018 (17:00-18:30 UTC). Staff have
> > posted to the wiki space the action items and notes.  Please note that
> > these will be high-level notes and are not meant as a substitute for
> > the recording. The recording, AC chat, and attendance records are posted
> on the wiki at:
> > https://community.icann.org/x/uwNpBQ
> >
> >
> >
> > Best Regards,
> >
> > Ariel
> >
> >
> >
> > Ariel Xinyue Liang
> >
> > GNSO Policy Support Specialist
> >
> > Internet Corporation for Assigned Names and Numbers (ICANN)
> >
> >
> >
> > ==
> >
> > ACTION ITEMS:
> >
> > Brian Beckham to send to the WG a WIPO FAQ with regard to “Doe
> Complaint”.
> > Renee Fossen to provide more information on HSTS-preloaded domain
> > suspension issues in the written responses.
> > Staff to recirculate the Super Consolidated URS Topics Table document
> > WG members to provide substantive comment and raise anything they
> > believe is missing on the WG mailing list by COB Tue, 14 Aug.
> > Co-Chairs will then discuss among themselves to determine further
> actions/process.
> > WG members to finish reviewing the rest of the Super Consolidated URS
> > Topics Table document, including page 24-35, during next week’s call.
> > Later period to discuss larger policy issues.
> >
> >
> >
> > NOTES:
> >
> > Review Agenda/Statements of Interest
> >
> > George Kirikos has become a member of the At-Large Community:
> > https://community.icann.org/display/gnsosoi/George+Kirikos+SOI
> >
> >
> >
> > General Comment on the Super Consolidated URS Topics Table Document
> >
> > The topics in the table were developed by the WG members and
> > deliberated on by the WG & URS Sub Teams. Each Sub Team then did very
> > substantial work on data collection and reviewing what came back.
> > While the actual Sub Team recommendations and suggestions captured in
> > this document are what is intended the WG should discuss - to see if
> > it wishes to develop policy or operational recommendations -
> > discussion over what should be on the actual list of topics should not
> > be reopened unless the WG agrees to do so. We encourage all WG members
> > to review all the previous reports from each Sub Team, and all the
> > documents they worked on. They are linked in this Super Consolidated
> document (page 2).
> > The Super Consolidated document is a summary of findings and
> > suggestions by the Sub Teams. The Table does not mean to
> > limit/restrict recommendations from the WG members. If there is any
> > issue overlapping with UDRP, can possibly be carried over to the phase
> II of the PDP.
> > Is it possible to add additional topics to the Super Consolidated
> > Table? One WG member said that access to the Courts, for example, is a
> > topic he raised, which isn't in the table. Statute of Limitations,
> > whether URS should apply to legacy gTLDs as a consensus policy, are
> > just a few of the topics not in the table. He brought it up in November
> 2017 (see:
> > https://mm.icann.org/pipermail/gnso-rpm-wg/2017-November/002585.html )
> > and it was reflected in a later document. That's a critical issue for
> > registrants. if they don't have access to the courts to challenge a
> > URS decision, then it's a huge denial of their rights.
> > While the chart is not meant to foreclose further discussion, it is a
> > good faith attempt at capturing the work of the sub teams.  The
> > purpose of today's, and likely the next few, calls was to make sure
> > this was an accurate and comprehensive reflection of our discussions
> > so far.  That said, WG members should bear in mind that we are seeking
> > consensus, so items which are unlikely to achieve that may not be
> > appropriate to reflect as a recommendation, but could be included in
> > public comments on the Initial Report.  Also, before adding items to
> > this chart, we will want to work with staff to see whether such topics
> > was previously discussed, and if so, the level of agreement/consensus.
> > In other words, it is not necessary final, but is equally an
> > opportunity to reintroduce topics which have been discussed, but for
> which consensus is/was not possible.
> > Could we create a list of "missing issues" -- a list of issues raised
> > in this call (and calls to follow); we can evaluate the nature and
> > weight of these ideas later.
> > Regarding the Action Items highlighted in column 3 of the table,
> > Providers ST will do a first pass of the responses from the Providers
> > to the follow-up questions, and then discuss the issues that they
> > identified and proposed suggestions with the full WG.
> >
> >
> >
> > Limited filing period (page 3)
> >
> > One WG member believes that there should be limitation for filing
> > period to bring URS Complaints, so the domain registered many years
> > ago would not be subject to unfair treatment. He said a registrant who
> > owns a domain for 20 years, for example, shouldn't have to be
> > concerned about a policy that can take their domain down with very short
> time period to respond.
> > Other WG members said this was discussed, and did not achieve agreement.
> > That would only even be an option if the trademark pre-dated. This is
> > unlikely to be a situation in practice where a URS was brought because
> > it would probably not be a "slam dunk" case after 20 years unless
> > there had been a change of circumstances.
> > On the issue of delay and laches - as reported by the Docs Sub Team,
> > the data did not provide any basis for which a policy recommendation
> > should be made. The Providers and Practitioners Sub Teams also did not
> > uncover any specific issues that came to either practitioners' or
> providers' attention.
> >
> >
> >
> > Administrative Review (page 3-4)
> >
> > One WG member asked whether ICANN should bring Providers into
> > contractual relationship in order to enforce the URS Rules &
> > Procedures. Another member said it probably need to be ICANN’s legal
> > department to enforce the rules & procedure.
> > URS Providers have MoU with ICANN. Whether it is ICANN’s compliance
> > department or legal department to enforce the rules & procedures, it
> > should not be controversial that Providers must abide by them.
> > An MOU could be legally enforceable, depending on the circumstances.
> >
> >
> >
> > 500-word Complaint limit (page 4-5)
> >
> > ·        On 500-word Complaint Limit - Practitioners' survey results were
> > split (out of 12, 5 agree it's sufficient, 4 disagree); results
> > included feedback from some that the word limit was too low:
> > "arbitrary and often insufficient" and "should be slightly increased".
> >
> > ·        One member said he understands and generally agrees with the
> > decision not to suggest an expansion of the word limit, he wonders if
> > there aren't situations (multi- domain challenges, etc.) where a
> > Complainant or Respondent might be given the opportunity to request an
> > expansion. This point can be captured for decisional phase.
> >
> > ·        Another member suggested that perhaps providers can provide
> stats
> > on the average word length of complaints, to see how close to the 500
> > words they are at present. (i.e. a table of distributions, e.g. 10%
> > under 200 words, 20% between 201 and 300, etc.)
> >
> >
> >
> > Amending the Complaint in light of GDPR/Temp Spec (page 5-6)
> >
> > One member believes that 2-3 days might not be a good rule (e.g.
> > weekends, time to research, etc.). Maybe 5 business days.
> > WIPO’s approach to “doe complaints” has been very helpful and provides
> > some comfort that the lack of true registrant/registrant organization
> > data masked due to GDPR will not result in a deficient complaint for
> > an omitted respondent.
> > ACTION ITEM: Brian Beckham to send to the WG a WIPO FAQ with regard to
> > “Doe Complaint”.
> > Forum is asking for amendment of the complaint in UDRP - under the
> > rules that's not allowed in URS.
> >
> >
> >
> > SMD Files (page 6-7)
> >
> > SMD files are used for limited purpose of demonstrating the use.
> > Recollection is that SMD files would be passed to the Examiners and
> > relay the critical information related to the TM registration. That's
> > why some people are surprised by the limited info SMD files would
> provide.
> > The SMD files contain some basic human-readable information, with the
> > rest of the information coded. For example, the trademark itself is
> > human-readable but the applicable Nice classification is coded. A SMD
> > file is used by registries/registrars for validation, and as Greg
> > noted, to demonstrate use. From the TMCH provider:
> > http://www.trademark-clearinghouse.com/help/faq/which-information-does
> > -smd-file-contain If the intent of the STI was that the SMD file would
> > be a file summary, that got lost somewhere along the way, way before
> > the SMD file was designed by the TMCH providers.
> > Rules 3(b)(v) Specify the trademark(s) or service mark(s) on which the
> > complaint is based and the goods or services with which the mark is
> > used including evidence of use –which can be a declaration and a
> > specimen of current use in commerce - submitted directly or by
> > including a relevant SMD (Signed Mark Data) from the Trademark
> > Clearinghouse It might be useful to look at the spec that they relied
> > on.  But the real question is how should the examiner get the relevant
> > data about the Complainant’s mark. The SMD file is probably not the
> > answer, if it was ever intended to be.
> > the Examiner is not required to second-guess the SMD file. Its
> > existence is sufficient that the mark has had use validated by the TMCH.
> >
> >
> >
> > Other Topics (page 7-8)
> >
> > These are policy proposals can be brought up when WG members are
> > proposing changes to the URS policy itself. Charter asks us to address
> > the question whether the URS should become a consensus policy
> > applicable to legacy domains. Charter is not specific regarding
> > whether such discussion should occur in phase I or phase II. This
> > feedback illustrates that the ST didn't get to propose policy changes,
> > it is for the WG to discuss and propose changes.
> > when we reference the STI and IRT reports, we need to keep in mind
> > they only had about 1-2 months to complete their work and produce a
> > report; they were not standard PDP working groups and had limited
> > charters and mandates, which were set by the Board This is feedback
> > from one Provider, who may want to grow their business.
> > Practitioners survey are from Complaints' side. Need to have a
> > balanced solution when considering the input.
> > There were plenty of practitioners that represent registrants in the
> > Subgroup, although their experience was largely with the UDRP.
> >
> >
> >
> > Duration of response period (Page 11)
> >
> > One member believes that if the URS continues in its current form, it
> > would affect valuable domain names. The ones the registrants that do
> > want to defend them, 14 days are not sufficient. 20 days may be more
> > appropriate. It should be based on the age of the domain name. If a
> > domain is 3 months, it will have a shorter period to respond. If you
> > own a domain name for 5-10 years, response period would be longer so
> less urgency.
> > Several other WG members disagree. The URS is supposed to be an
> > expedited proceeding so increasing the length of time of a streamlined
> > proceeding defeats the purpose.  At most, there could be an additional
> > 3 or 4 days extension period for cause. The point is that there are
> > enough circumstances that give rise to the URS 'quick response' that
> > we should NOT make assumptions into policy.  It is an assumption that
> > an "aged" domain would not require a fast response. In Mexico, we have
> > not been able to file a domain name case due to Courts ignorance about
> > the subject and also, because it could take years to be solved. We're
> > spinning out fo control - extending the time to respond to URS cases
> > just because a domain registration is not new defeats the purpose of
> > fast action to take down an infringing domain once it's discovered.
> > The URS is meant to address clear and convincing cases of
> > infringement. A person registers a domain name for less than $50 and
> > brand owner find out about at some point and then files an injunction in
> court for tens of thousands of dollars.  Where is the balance.
> >
> >
> >
> > Examiners Guide (page 13)
> >
> > The WIPO guidance for examiners took 1500 hours to develop.
> > The WIPO guidance is relevant to the URS, the elements are shown are
> > the same and the differences include the burden of proof, word limit,
> > etc. A lot of WIPO guidance goes to the shade of grey issues. URS is
> > for clear black/white cases, so if there is a URS guidance it would
> > likely be abbreviated.
> >
> >
> >
> > Duration of Suspension Period & Review of Implementation (page 21-23)
> >
> > One WG member suggests to find out how much cost for registries &
> > registrars to comply with the URS rules and procedures. Need to get
> > data/feedback from the registries/registrars.
> > Other WG members are not sure "cost of implementation of URS" for
> > Registries/Registrars is relevant to effectiveness of URS. We don't
> > need to do a cost/benefit analysis (the costs & benefits aren't
> > ICANN's), the providers, registrars, registries need to be asked if
> > they are overburdened by the costs of compliance.
> > There is an action item to contact the registries/registrars about
> > these issues. Timing TBD due to Sunrise & Claims survey launch.
> >
> >
> >
> > Other topics (page 23-24)
> >
> > One WG member thinks the HSTS issue is not difficult to fix. The
> > Providers need to improve their technical applicability to resolve the
> > issue. Renee Fossen from Forum disagrees.
> > ACTION ITEM: Renee Fossen to provide more information on
> > HSTS-preloaded domain suspension issues in the written responses.
> >
> >
> >
> >
> >
> > NEXT STEPS
> >
> > ACTION ITEM: Staff to recirculate the Super Consolidated URS Topics
> > Table document and ask all WG members to provide substantive comment
> > and raise anything they believe is missing on the WG mailing list by COB
> Tue, 14 Aug.
> > Co-Chairs will then discuss among themselves to determine further
> > actions/process.
> > ACTION ITEM: WG to finish reviewing the rest of the Super Consolidated
> > URS Topics Table document, including page 24-35. Later period to
> > discuss larger policy issues.
> >
> >
> >
> >
> >
> > ________________________________
> >
> >
> > Confidentiality Notice:
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