[GNSO-RPM-WG] DEADLINE COB 25 Sept - ACTION ITEM: Sunrise Recommendation #2 and Small Team 2 Suggested Language:
Kathy Kleiman
kathy at kathykleiman.com
Fri Sep 25 22:17:15 UTC 2020
One of my concerns, and I raise this as a member of the WG, I wonder
about the proposal below: "The IRT should explore the possibility of a
third party challenge mechanism as one of the possible means."
Is it appropriate to leave to an IRT - an implementation team run by
ICANN - the creation of a new 3rd party mechanism for challenges? To
me, this is the essence of the task given to a GNSO policy process; it
is something we have always done together through the multistakeholder
process. It's how we did the UDRP, the URS and the TM-PDDRP.
I continue to ponder. Have a good weekend, All!
Kathy
----- Original Message -----
From: "McAuley David"
To:"gnso-rpm-wg at icann.org"
Cc:
Sent:Fri, 25 Sep 2020 18:54:48 +0000
Subject:Re: [GNSO-RPM-WG] DEADLINE COB 25 Sept - ACTION ITEM: Sunrise
Recommendation #2 and Small Team 2 Suggested Language:
Thank you, Mary, Ariel, and Julie,
Below are my comments regarding the draft Final Report language for
Sunrise Recommendation 2, as well as the small team’s additional
proposed draft language proposing an independent enforcement
mechanism. I raised these issues on the Registries Stakeholder Group
call two days ago and used that discussion to help inform my comments.
But these comments are personal and not officially on behalf of my
employer or of the RySG.
First, with respect to the Final Report language on Sunrise
Recommendation #2 and the original implementation guidance, I fully
support the addition of the word ‘intentionally’ in the
Recommendation prior to the word “circumventing”. A registry
operator should not face potential enforcement action for unintended
consequences.
Further, I believe that the implementation guidance language needs to
be tightened up to clarify that the “Discriminatory pricing
practices” referenced at the second bullet listing non-exhaustive
examples of practices that may circumvent an RPM means
discriminating against a trademark holder in the sunrise period via
extremely high premium pricing, followed by a much lower subsequent
land rush or GA price that has resulted in bad faith registration
and subsequent infringing use by registrants other than the mark
holder. The sunrise registration RPM is meant to give a mark holder
first opportunity to register a domain corresponding to its exact mark
to prevent its bad faith registration and use by a cybersquatter, but
that must be balanced against the fact that many trademarks consist of
generic dictionary words that have inherent value and can be used by
other potential registrants in a non-infringing manner, justifying a
substantial premium price.
Further, the premium price level in and of itself cannot be sole
basis for a Compliance enforcement action as that would violate the
“picket fence” that prohibits GNSO policy from prescribing or
limiting the pricing of registry services. As this type of price
discrimination leading to subsequent infringement will only become
evident after the sunrise registration period has ended, the IRT will
need to give consideration as to what appropriate enforcement against
such registry operation practices should consist of.
Second, I oppose the additional implementation guidance language from
Small Team 2. While I applaud the team for its efforts, I cannot
support a new enforcement mechanism wholly separate from ICANN
Compliance. In my opinion, this is very far from the idea that went
out to public comment – the idea of revising a registry agreement
provision for future new gTLDs to elevate the general requirement on a
registry to implement applicable policies to a specific requirement to
refrain from circumventing new gTLD RPMs. The proposal would give to
the IRT unchecked and inappropriate policy-making discretion to create
a new enforcement mechanism absent any showing that the implementation
of Sunrise Recommendation #2 will be insufficient to curb suspect
practices. Further, the PDDRP is already available against a registry
operator who encourages infringing second level registrations, and the
recommendation we have agreed upon to allow unrelated rights holders
to bring a combined PDDRP action against a registry operator will make
it easier to demonstrate a pattern of intentional circumvention of the
sunrise RPM resulting in harm to them. It seems to me that if this
additional language is added to the existing language and perfected
implementation guidance, then there will be a strong possibility that
the entire Sunrise Recommendation #2 will end up lacking consensus
support and not proceed to Council.
Best regards,
David
David McAuley
Sr International Policy & Business Development Manager
Verisign Inc.
703-948-4154
FROM: GNSO-RPM-WG ON BEHALF OF Julie Hedlund
SENT: Wednesday, September 23, 2020 11:58 AM
TO: gnso-rpm-wg at icann.org
SUBJECT: [EXTERNAL] [GNSO-RPM-WG] DEADLINE COB 25 Sept - ACTION ITEM:
Sunrise Recommendation #2 and Small Team 2 Suggested Language:
Dear all,
Per the WG Co-Chairs, please note the deadline for this action:
_PLEASE SEND COMMENTS IF ANY TO THIS LIST NOT LATER THAN COB FRIDAY,
25 SEPTEMBER._
Note also that the WG discussion of Sunrise Recommendation #2 and the
original Implementation Guidance language will be on the agenda for
the WG meeting on TUESDAY, 29 SEPTEMBER, to be followed by a separate
discussion of the Sub Team 2 suggested Implementation Guidance
language.
As a reminder, here is a link to Sunrise Recommendation #2 and the
original Implementation Guidance language:
https://docs.google.com/document/d/12w5W2bQcviAqLwoDVB0vVK0n7SKj3fzP48NQyEW-1Q4/edit?usp=sharing
[1].
Also as a reminder, here is the proposed Implementation Guidance
language for Sunrise Recommendation #2 from Small Team 2:
Suggestion Language from Small Team 2: “Implementation Guidance to
Sunrise Recommendation 2: The IRT should explore the possibility of
a third party challenge mechanism as one of the possible means, among
others (for example, direct enforcement by ICANN Compliance) to
implement this Recommendation to enforce the implementation of this
recommended new RA provision. Any such third party challenge
mechanism should include appropriate safeguards for registries.”
Kind regards,
Mary, Ariel, and Julie
FROM: GNSO-RPM-WG on behalf of Julie Hedlund
DATE: Tuesday, September 22, 2020 at 4:09 PM
TO: "gnso-rpm-wg at icann.org [4]"
SUBJECT: [GNSO-RPM-WG] REMINDER - ACTION ITEM: Sunrise Recommendation
#2 and Small Team 2 Suggested Language:
Dear All,
_PLEASE SEE THE ACTION ITEM BELOW AND POST ANY COMMENTS TO THIS LIST
ASAP._
Kind regards,
Mary, Ariel, and Julie
FROM: GNSO-RPM-WG on behalf of Julie Hedlund
DATE: Thursday, September 17, 2020 at 5:07 PM
TO: "gnso-rpm-wg at icann.org [8]"
SUBJECT: [GNSO-RPM-WG] ACTION ITEM: Sunrise Recommendation #2 and
Small Team 2 Suggested Language:
Dear All,
Please see the action item below from the WG meeting on 17 September:
Sunrise Recommendation #2 and Small Team 2 Suggested Language:
ACTION ITEM: DISCUSS WG SUGGESTED REVISIONS TO THE RECOMMENDATION AND
IMPLEMENTATION GUIDANCE ALONG WITH THE SUGGESTED LANGUAGE FROM SMALL
TEAM 2.
Please see the suggested revisions to Sunrise Recommendation #2 in
the Google document at:
https://docs.google.com/document/d/12w5W2bQcviAqLwoDVB0vVK0n7SKj3fzP48NQyEW-1Q4/edit?usp=sharing
[docs.google.com] [10].
Please also review the following Suggested Language from Small Team:
Suggestion Language from Small Team 2: “Implementation Guidance to
Sunrise Recommendation 2: The IRT should explore the possibility of
a third party challenge mechanism as one of the possible means, among
others (for example, direct enforcement by ICANN Compliance) to
implement this Recommendation to enforce the implementation of this
recommended new RA provision. Any such third party challenge
mechanism should include appropriate safeguards for registries.”
_PLEASE POST ANY COMMENTS OR QUESTIONS FOR DISCUSSION TO THIS LIST
ASAP._
Kind regards,
Mary, Ariel, and Julie
FROM: GNSO-RPM-WG on behalf of Julie Hedlund
DATE: Thursday, September 17, 2020 at 2:49 PM
TO: "gnso-rpm-wg at icann.org [13]"
SUBJECT: [GNSO-RPM-WG] Notes and Action Items: RPM PDP WG Meeting 17
September 2020
Dear All,
Please see below the action items captured by staff from the RPM
PDP Working Group call held on 17 September 2020 at 17:00 UTC. Staff
will post these to the wiki space. _PLEASE NOTE THAT THESE __ARE
HIGH-LEVEL NOTES AND ARE NOT MEANT AS A SUBSTITUTE FOR THE RECORDING,
CHAT ROOM, OR TRANSCRIPT__._ The recording, Zoom chat, transcript and
attendance records are posted on the wiki at:
https://community.icann.org/display/RARPMRIAGPWG/2020-09-17+Review+of+all+Rights+Protection+Mechanisms+%28RPMs%29+in+all+gTLDs+PDP+WG
[15].
Best Regards,
Julie
Julie Hedlund, Policy Director
==
NOTES & ACTION ITEMS
ACTIONS:
Sunrise Recommendation #2 and Small Team 2 Suggested Language:
ACTION ITEM: DISCUSS WG SUGGESTED REVISIONS TO THE RECOMMENDATION AND
IMPLEMENTATION GUIDANCE ALONG WITH THE SUGGESTED LANGUAGE FROM SMALL
TEAM 2.
Suggested Language from Small Team 1 on ALP relating to Sunrise
Questions #3 and #4:
ACTION ITEM: STAFF WILL CHECK WITH GDS TO SEE IF THIS RECOMMENDATION
IS FEASIBLE.
URS Final Recommendation (was #1):
ACTION ITEM: MINOR CHANGE IN THE CONTEXTUAL LANGUAGE – CHANGE FROM
“THE WORKING GROUP AFFIRMS” TO “THE WORKING GROUP FURTHER
NOTES”.
New URS Final Recommendation:
ACTION ITEM: REMOVE THE QUOTED TEXT FROM PURPOSE 6-PA5 AND MOVE IT
TO A FOOTNOTE FOR REFERENCE.
NOTES:
1. Updates to Statements of Interest: No updates provided.
2. Sunrise Recommendation #2 and Small Team 2 Suggested Language;
see: Suggested Language from Small Team 2
[16] andhttps://docs.google.com/document/d/12w5W2bQcviAqLwoDVB0vVK0n7SKj3fzP48NQyEW-1Q4/edit?usp=sharing
[docs.google.com] [17]
-- Concerns raised by Maxim Alzoba about the two examples that they
are too broad.
-- Further to my point, as was noted earlier, this is a high-level
policy recommendation; the IRT will be tasked with implementing this
recommendation and our guidance should be sufficient to allow the IRT
to craft an appropriately tailored RA amendment and (hopefully a
challenge mechanism with appropriate safeguards built in so as to not
inhibit legitimate registry activities
-- I agree (I think) with Jason insofar as implementing this
recommendation may necessitate a third party challenge mechanism akin
to the PDDRP or pICDRP so aggrieved TM owners can challenge a registry
activity and there can be a ruling as to whether the activity is
legitimate or not.
-- Concerns about misinterpretation if we are not clear.
-- Perhaps we can just add a third bullet that says, “registry
activities that have a bona fide legitimate basis or rationale are
explicitly not intended to be inhibited by this provision”.
-- As a staff suggestion for your consideration — perhaps we can
include something to this effect: “The Working Group notes that this
recommendation is not intended to preclude or restrict Registry
operator’s legitimate business practice and pricing practice that
are compliant with ICANN policies and procedures.”?
-- Add to bullet point 1 (slightly revised)-- adding: "without
countervailing rationale and/or reasonable activity by registries,
including handling of dictionary terms.”
-- Suggest addition to the Recommendation: “The Working Group
recommends that the Registry Agreement for future new gTLDs include a
provision stating that a Registry Operator shall not operate its TLD
in such a way as to have the effect of [intentionally] circumventing
the mandatory RPMs imposed by ICANN or restricting brand owners’
reasonable use of the Sunrise rights protection mechanism.” Text in
brackets.
-- Don’t think adding “intentionally” in the rec helps us
because it doesn’t really address Maxim’s concern, because
reserving a name intentionally as part of an ALP or something is still
intentional.
ACTION ITEM: DISCUSS SUGGESTED LANGUAGE FROM SMALL TEAM 1 ON THE
LIST.
Suggestion Language from Small Team 2: “Implementation Guidance to
Sunrise Recommendation 2: The IRT should explore the possibility of
a third party challenge mechanism as one of the possible means, among
others (for example, direct enforcement by ICANN Compliance) to
implement this Recommendation to enforce the implementation of this
recommended new RA provision. Any such third party challenge
mechanism should include appropriate safeguards for registries.”
_-- Why would the proposed additional implementation guidance
language be a beneficial addition to the existing implementation
guidance_? Answer: Takes some of the burden off of Compliance.
_-- Does the phrase “explore the possibility of a third party
challenge mechanism” encompass and authorize the IRT’s adoption
and implementation of such a mechanism if it is found to be
possible?_ Answer: To amend the language to “explore and if
possible implement”.
_-- Would the challenge mechanism be operative against ICANN, a
registry alleged to have circumvented a RPM, or both_? Answer: It
would be against the registry that is alleged to have circumvented
it. There already is a way to challenge staff and Board actions.
_-- This would not be a mechanism as a way for ICANN Org Compliance
to enforce – this would be a separate mechanism?_ Answer: Correct.
Discussion:
-- Opposed to this language. Sunrise Rec #2 itself is still
vague.
-- Registries agree by contract to comply, but IRTs cannot develop
consensus policies or revise contract terms – so this is out of
scope.
-- This is putting one vagueness on top of another.
-- What authority does an IRT have to do these types of things.
-- Didn't an IRT create the URS, PDDRP, PICDRP, to name a few?
-- Sunrise Rec #2 seems to beg for a third-party challenge mechanism.
-- 1. Clause could include a clause to include a challenge
mechanism. 2. IRTs do this sort of thing all the time (e.g. the
AGB and all of the challenge mechanisms with it).
-- Idea is that there would be an independent panel that an aggrieved
party could go to – so not relying on ICANN Compliance and could be
an independent review.
-- Why isn't a complaint to ICANN compliance sufficient here? I agree
with David that it's especially problematic to move from "vague
standard applied by single decisionmaker" to "vague standard applied
by various possible decisionmakers"
-- Would this be a time-sensitive mechanism?
-- Because in response to the complaints over the years on sunrise
circumvention, ICANN has consistently said they could do nothing about
it.
-- Circumvention itself is not defined, so cannot be enforced.
-- ICANN compliance would need to have a role, in a similar way it
does in a PICDRP for instance; an independent panel would actually
perform the substantive review and ICANN compliance would implement a
panel finding, for example.
-- If Rec 2 is "start doing something about it" then why isn't ICANN
compliance the appropriate place?
-- URS and PDDRP are not Consensus Policy either. They were created
during implementation of the 2007 GNSO PDP on New gTLDs.
-- Divergence in the WG on this suggested text.
ACTION ITEM: DISCUSS THE SUGGESTED LANGUAGE ON THE LIST.
3. Suggested Language from Small Team 1 on ALP relating to Sunrise
Questions #3 and #4; see:
http://mm.icann.org/pipermail/gnso-rpm-wg/2020-September/004505.html
[18]
“The Working Group recommends guidance to the Implementation Review
Team that the Approved Launch Program (ALP) Application Review
Guidelines be reviewed and clarified in order to address feedback
obtained by the working group regarding the length of time and
complexity of process involved in seeking to obtain approval for an
ALP, and in particular recommends that the IRT consider the following:
1. Where ICANN can not make a determination regarding an ALP
application it will notify the Registry Operator to that effect within
45 days stating explicit reasons for needing more time and further,
provide a decision date projection plan within a time period not to
exceed another 30 days. There should be a reasonable expectation that
all negotiations should be completed within a 7 month period.
2. Where ICANN determines to decline an ALP application or make a
request for further information ICANN will include a full explanation
of the aspects of the ALP application ICANN deems to be acceptable
and the aspects ICANN deems to be unacceptable.”
Discussion:
-- The reference to an ALP being adopted is in the TMCH procedures if
approved it is outside of or in contravention of Sunrise. This is
directly related to the operation of the Sunrise.
-- TMCH RPMs Requirements document that is incorporated by reference
into the AGB and the RA
(http://newgtlds.icann.org/en/about/trademark-clearinghouse/rpm-requirements-14may14-en.pdf
[19]) 4.5 deals with Launch Programs, specifically 4.5.2:
Registry Operator MAY, prior to the start date of its Sunrise Period,
apply to ICANN for approval to conduct a registration program not
otherwise permitted by these TMCH Requirements. Such a registration
program application could, for example, provide for authorization to
implement programs set forth in Registry Operator’s application for
the TLD, which, if set forth in reasonable detail in the application
for the TLD, will carry a presumption of being approved, unless ICANN
reasonably determines that such requested registration program could
contribute to consumer confusion or the infringement of intellectual
property rights. If Registry Operator seeks ICANN’s approval of a
program under this Section 4.5.2, and such requested registration
program is substantially similar to a...”
ACTION ITEM: STAFF WILL CHECK WITH GDS TO SEE IF THIS RECOMMENDATION
IS FEASIBLE.
4. URS Final Recommendations;
see: https://docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing
[docs.google.com] [20]
a. URS Final Recommendation (was #1):
-- Recommendation language stays as is.
-- Contextual language – inserted text to reflect the WG’s
agreement to include the EPDP Phase 1 Recommendation #27 Wave 1
Report.
ACTION ITEM: MINOR CHANGE IN THE CONTEXTUAL LANGUAGE – CHANGE FROM
“THE WORKING GROUP AFFIRMS” TO “THE WORKING GROUP FURTHER
NOTES”.
b. New URS Final Recommendation:
-- This is based on URS Question 1.
-- It is a new recommendation based on responses received in the
public comment.
-- The context comes from the WG discussion of URS Question 1.
-- The public comment review is based on the discussion of URS
Question 1 and suggestion for a recommendation.
Discussion:
-- Questions about the contextual language. Concern that the
reference to Purpose 6-PA5 is somehow binding.
-- Staff noted that it is not binding and there was no change to the
new recommendation resulting from the WG’s review of the ICANN
org’s EPDP Phase 1 Recommendation #27 Wave 1 Report.
ACTION ITEM: REMOVE THE QUOTED TEXT FROM PURPOSE 6-PA5 AND MOVE IT
TO A FOOTNOTE FOR REFERENCE.
Links:
------
[1]
https://docs.google.com/document/d/12w5W2bQcviAqLwoDVB0vVK0n7SKj3fzP48NQyEW-1Q4/edit?usp=sharing
[2] mailto:gnso-rpm-wg-bounces at icann.org
[3] mailto:julie.hedlund at icann.org
[4] mailto:gnso-rpm-wg at icann.org
[5] mailto:gnso-rpm-wg at icann.org
[6] mailto:gnso-rpm-wg-bounces at icann.org
[7] mailto:julie.hedlund at icann.org
[8] mailto:gnso-rpm-wg at icann.org
[9] mailto:gnso-rpm-wg at icann.org
[10]
https://secure-web.cisco.com/1FjwAVP01Qp6iUM2rsInfcO1zc3qY1OeyxbslL44ahBnD57v-M046VfYu9TfNqKCONUMMY0dfxlDuXZajozgyED333axf8f-WVQQRrFyY6WzBAX5yFBgAdujy8_c_CZZpcbjZ3L_GchivygKd48DmcY2P1hNUww0OkcBHItWltt66smISh5mbgf-eSG3auE7oM9VvRauAVsbfwmfFPxufoPxV7W4uhtTHoSdSe-FeHUyXsoWiioZ9rSHqdpUR9dfevov4joiW3qQQvF3rBHyywg/https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fdocs.google.com%2Fdocument%2Fd%2F12w5W2bQcviAqLwoDVB0vVK0n7SKj3fzP48NQyEW-1Q4%2Fedit%3Fusp%3Dsharing__%3B%21%21PtGJab4%21vwikSt_HHDU8CpTsVTNpVCKvvhfkw3RoDuQLZC9tK3qSp9Flz3aJeVIjw0KrKyJ30-ZjAqWjOA%24
[11] mailto:gnso-rpm-wg-bounces at icann.org
[12] mailto:julie.hedlund at icann.org
[13] mailto:gnso-rpm-wg at icann.org
[14] mailto:gnso-rpm-wg at icann.org
[15]
https://secure-web.cisco.com/1pj-qVlupt78WOggqQBVxVYjoZzhpAILr_Kjzlnz0Q9dNOBFXaq031gYNHOThZiA6e4f06uthLyxmlMQlQyX7x95gLj9tD_66uMXKEik9YoAiBiXvZC1NtWzldGG_KJCEjz0LMqAAk1cc6wlMGN0DDzCrYDEoTEXgIXWIKE_kt082hEcRI7jM79jKpx8n2wT14ADjZBeRagmXdKLtuKqXvnAm-GD48SuByL7FiCTiwv_xKRc8GXV4mztb5JEhEBm8FmjynZGadWfwt1XqQSdSgA/https%3A%2F%2Fcommunity.icann.org%2Fdisplay%2FRARPMRIAGPWG%2F2020-09-17%2BReview%2Bof%2Ball%2BRights%2BProtection%2BMechanisms%2B%2528RPMs%2529%2Bin%2Ball%2BgTLDs%2BPDP%2BWG
[16]
http://secure-web.cisco.com/1ZQHItR6-GcLnN7flaJYMavZ68Kd0x80R9l3ty5lI1SXM8VSs6FTVOvAHMFPGuO7cR6uW0wVUHDXL7XZO75Vw5yLVktwjziIWj8UCsy6dIEsWDbbNWfxbFShegcxhuPKTncvHLslev5_i4x7cbs01L7gkAVqqGWKWTDAXDaBK8PmDKnJP6UGqJaGU4Qu2D_8e2bes3_3TgTx0xtf4av017a-equPtfELedejZkuoocPN3p_bmlZAmdYJ84EXzPZNG6xk4P7tuPbvnEGuI7xmxMA/http%3A%2F%2Fmm.icann.org%2Fpipermail%2Fgnso-rpm-wg%2F2020-September%2F004503.html
[17]
https://secure-web.cisco.com/1GPaEQhm9H9M25BLwa6LTCBf6l5NTIJUjWXk8Zkqr68yF-83WCmBUl9ynxjpPoL6xQyzqVAJcrAMKgjTkuKdOyL6xKU0zJd5rCnZXil0t4B9GiOFI6JFefvmU-jt5OCaNW21l2NCFt_C6a_4MB5UPQpMB5HmqIVFGwV8CSHs3N9MAnEjNJcM0ar3fXmJTPKo199BfwgnB-sKmhnL9PVW0wFkTzwxVf7xR6MfGlm8mmRDQhyf435K0Z4Og7CPtxK7nLoGp3Hb9hTY6anlR1s1JEQ/https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fdocs.google.com%2Fdocument%2Fd%2F12w5W2bQcviAqLwoDVB0vVK0n7SKj3fzP48NQyEW-1Q4%2Fedit%3Fusp%3Dsharing__%3B%21%21PtGJab4%21vrG9bvGPh6CAcYH6gGtmazbvnCJsGe-fWqDidShS5tf9gWqE4k8oCMDj3vR6cqfVi26trKkD_g%24
[18]
http://secure-web.cisco.com/15s2A-_YSAltxsDRZbXGvAtbln5h7Y5BRK79nsX0sMyJLss1egyxr67iWrtpy3yoMtiGMGy58vZ6jCfjWSRTtmhEls37XpITRmZ0pk1dV0gy4xtVr2i4rCCHxU6Fk0vq3v1ahcw9f06x08EqL886eTn_kATT63sNDfH3osAcZcWZ_O0LFBKVGFZ0cLsqM6KyTHo3QJ6AE9hvRbmNY25yUiX0uy9lSYKzKUkf5zwGvAtfkX6J6srbPI7gFB4a-z4FruA7SVpXSsI1sKGhk4pjZ6g/http%3A%2F%2Fmm.icann.org%2Fpipermail%2Fgnso-rpm-wg%2F2020-September%2F004505.html
[19]
http://newgtlds.icann.org/en/about/trademark-clearinghouse/rpm-requirements-14may14-en.pdf
[20]
https://secure-web.cisco.com/14aelGQ2vVVG29EjXESQVYNQs8xt9zypPgviL8EBr2fngGWYOCHDRoOf7DW5Sk_GgcTcmY63YfPxByVbVoNuD-0jcm8nJVEg7Myz4XyiCLE3rvNMhYcu4JI3kDy2e1CfGg2bQ4kvpNkXzAomSW4IhEyPX5xf9V6NQn-j1vkR_zN7xSqPOOpI5srhAFJ1nto6q2uYDOwFnpW3X26TFgvDjOvJfVmLq4cNHMgTls4ORiSC29BTAHvKu82zV42FbPW2PWl95W4izkyGOI41qKjLR2A/https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fdocs.google.com%2Fdocument%2Fd%2F1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY%2Fedit%3Fusp%3Dsharing__%3B%21%21PtGJab4%21vrG9bvGPh6CAcYH6gGtmazbvnCJsGe-fWqDidShS5tf9gWqE4k8oCMDj3vR6cqfVi25zeqf2-g%24
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