[IOT] IRP-IOT - Agenda for plenary call January 10, 2023, 18:00 UTC

Bernard Turcotte turcotte.bernard at gmail.com
Mon Jan 9 18:29:55 UTC 2023


All,

Firstly, happy new year to all.

Second, please find the agenda for the January 10, 2023, 18:00 UTC plenary
call below.

Third, please find below a copy of Susan's Straw Person email from January
4th.

Agenda:


   1. Review agenda and updates to SOIs
   2. Review action items:
      1. Sam to provide information on costs awards from pre-Transition
      (2016) IRPs, which may assist with this discussion
   3. Discussion of Straw Man proposal
   4. Next call - to be confirmed


On Wed, Jan 4, 2023 at 12:43 PM Susan Payne <susan.payne at comlaude.com>
wrote:

> Hi all
>
> I hope that those of you who celebrated have had an enjoyable and relaxing
> holiday season.
>
>
>
> Following on from the email exchange and subsequent discussion on our call
> last month, I have put together what I hope can be the basis for resolving
> the initiation-related issues we have been discussing.  As always, the
> views of group members do range across the spectrum, on topics such as the
> initiation fee, and so the attached is an effort at finding a compromise
> that we can hopefully all live with.
>
>
>
> This is a strawperson, and so is open to further discussion and revision,
> but we have now spent some time discussing initiation and, I believe, the
> various views have been well-aired.  I would like us to wrap up our
> discussion on this after the next call if at all possible.  With that in
> mind, please do share any feedback in advance of next Tuesday’s call.
>
>
>
> Susan
>
>
>
> Susan Payne
> Head of Legal Policy
> Com Laude
> *T* +44 (0) 20 7421 8250
> *Ext* 255
>
> <https://comlaude.com/>
>
> *From:* IOT <iot-bounces at icann.org> *On Behalf Of *Susan Payne via IOT
> *Sent:* 06 December 2022 17:19
> *To:* Flip Petillion <fpetillion at petillion.law>; McAuley, David
> <dmcauley at Verisign.com>; silber.mike at gmail.com; Malcolm at linx.net;
> iot at icann.org
> *Subject:* Re: [IOT] IRP-IOT action items/next steps on Initiation
>
>
>
> Malcolm, David, Mike and Flip
>
> Thanks so much for your thoughtful comments.  I hope that those of us who
> can make today’s call can continue with this fruitful discussion and
> hopefully near or reach a possible compromise.  It seems to me we may be
> able to build something based loosely on Mike’s proposal as a starting
> point.
>
>
>
> Regarding the thoughts on a loser pays element to the costs and expenses
> of the IRP, I do appreciate and tend to share those views.  Coming from a
> UK law background, it is entirely the norm (certainly in litigation) for a
> successful party to recover their costs from the loser, subject to an
> assessment of reasonableness of the figures and a judicial discretion to
> alter that norm based on the behaviour of the winning party.  Nevertheless,
> I do not think that we have the scope to follow that approach here, whether
> for non-commercial Claimants only or for all Claimants, since we must work
> within the terms of the Bylaws.  Bylaws 4.3(r) could be clearer in other
> regards, but I don’t believe there is disagreement over the intent that
> parties should bear their own legal costs except where the losing party’s
> defence or claim is deemed by the panel to be frivolous or abusive:
>
>
>
> ICANN shall bear all the administrative costs of maintaining the IRP
> mechanism, including compensation of Standing Panel members. Except as
> otherwise provided in Section 4.3(e)(ii), each party to an IRP proceeding
> shall bear its own legal expenses, except that ICANN shall bear all costs
> associated with a Community IRP, including the costs of all legal counsel
> and technical experts. Nevertheless, except with respect to a Community
> IRP, the IRP Panel may shift and provide for the losing party to pay
> administrative costs and/or fees of the prevailing party in the event it
> identifies the losing party's Claim or defense as frivolous or abusive.
>
>
>
> Obviously I am open to discussing this is that is not an agreed
> understanding.  I will note however, that this was the understanding of the
> IRP panel in .WEB.  I did previously include a link to the .WEB decision,
> which I found to be very helpful, but for convenience on today’s call, I
> have pulled out a few key paragraphs from that decision into the attached
> document.
>
>
>
> Susan Payne
> Head of Legal Policy
> Com Laude
> *T* +44 (0) 20 7421 8250
> *Ext* 255
>
> <https://comlaude.com/>
>
> *From:* IOT <iot-bounces at icann.org> *On Behalf Of *Flip Petillion via IOT
> *Sent:* 06 December 2022 14:27
> *To:* McAuley, David <dmcauley at Verisign.com>; silber.mike at gmail.com;
> Malcolm at linx.net
> *Cc:* iot at icann.org
> *Subject:* Re: [IOT] IRP-IOT action items/next steps on Initiation
>
>
>
> All:
>
>
>
> Here are some thoughts. Apologies, but I don't have time to prepare a more
> detailed overview.
>
>
>
> I believe it is worth reminding the CCWG-Accountability Recommendation on
> accessibility and costs:
>
>
>
> [image: Text Description automatically generated]
>
>
>
> With respect to the loser pays/fee shifting, I see no basis to distinguish
> between non-profits and for-profits.
>
>
>
> The way that cost the loser pays/fee shifting has been transposed into
> Articles 4(3)(e)(ii) and 4(3)(r) of the Bylaws seems unbalanced and in
> contradiction with the stated purposes of the IRP (Article 4(3)(a) of the
> Bylaws).
>
>
>
> Article 4(3)(e)(ii) provides that, in certain circumstances (i.e., non
> good faith participation to CEP), the IRP Panel shall award to ICANN all
> reasonable fees and costs incurred by ICANN, including legal fees.
>
>
>
> There is no such provision for a reimbursement of all reasonable fees and
> costs incurred by a Claimant. Yet the IRP is a system to ensure ICANN’s
> compliance. As a result, ICANN is the main beneficiary of IRP rulings.
> Without a balanced cost shifting model, the system risks to install
> unwarranted burdens for Claimants who risk paying the bill for enhancing
> ICANN’s accountability.
>
>
>
> Article 4(3)(r) *in fine* provides for possible fee shifting in the event
> of frivolous or abusive claims or defenses. To date, there is no cost
> shifting case law. That could be because the burden of Article 4(3)(r) is
> too high.
>
>
>
> In international arbitration, the principle of *costs follow the event* is
> well accepted (with fairness adjustments). The requirement of frivolous or
> abusive claims or defenses seems at odds with this principle and with the
> stated purposes of an IRP. According to these stated purposes, IRPs are
> aimed at securing the “accessible, transparent, efficient, consistent,
> coherent, and just resolution of Disputes” and to lead to final resolutions
> “consistent with international arbitration norms”. Deviating from the *costs
> follow the event *principle to ICANN’s benefit risks making IRPs less
> accessible, less just, and not consistent with international arbitration
> norms.
>
>
>
> In my experience, adherence to the *costs follow the event *principle has
> never incentivized a commercial entity to engage in imprudent management or
> in making intemperate legal expenses. Efficiency as to time and costs is an
> important driver in international arbitration, which always forms part of
> the decision-making matrix. Even when an arbitral tribunal decides to shift
> costs, it will have no scruples about rejecting the reimbursement of
> excessive or unnecessary legal costs.
>
>
>
> Instead of trying to re-invent the wheel, I would make a plea of
> confirming ourselves to well-established norms of international arbitration
> and adapting where necessary to serve the stated purposes of an IRP. In my
> view, the stated purpose of making IRPs accessible favours adherence to the *costs
> follow the event *principle, provided Claimants are offered some
> protection in line with the stated purpose of IRPs to ensure ICANN’s
> accountability to the global Internet community and Claimants.
>
>
>
> I’ll try to join you in the call tonight.
>
> Best
>
>
>
> Flip
>
>
>
>
>
>
>
> Flip Petillion
>
> fpetillion at petillion.law
>
> +32484652653
>
> www.petillion.law
>
>
>
> [image: id:image001.png at 01D3691D.DA7539C0] <https://www.petillion.law/>
>
>
>
>   Attorneys – Advocaten – Avocats
>
>
>
>
>
> *From: *IOT <iot-bounces at icann.org> on behalf of "McAuley, David via IOT"
> <iot at icann.org>
> *Reply to: *"McAuley, David" <dmcauley at Verisign.com>
> *Date: *Tuesday, 6 December 2022 at 12:46
> *To: *"silber.mike at gmail.com" <silber.mike at gmail.com>, "Malcolm at linx.net"
> <Malcolm at linx.net>
> *Cc: *"iot at icann.org" <iot at icann.org>
> *Subject: *Re: [IOT] IRP-IOT action items/next steps on Initiation
>
>
>
> Thank you, Malcolm and Mike.
>
>
>
> I agree with how Mike approaches these matters, subject to these further
> comments:
>
>
>
>    1. Needy claimants should be able to bring IRPs and I encourage ICANN
>    to pay special heed to Bylaw 4.3(y) regarding meaningful participation by
>    those who might otherwise be excluded.
>
>
>
>    1. I agree that costs and fees are best handled by the panel and
>    Mike’s guardrails of fairness and equity seem right, as does note of having
>    rules that conform with international arbitration norms.
>
>
>
>    1. I am not convinced that non-commercial claimants should be able to
>    capture all of their costs if they prevail unless ICANN was frivolous in
>    its defense. Parties who are able typically shoulder their own costs and
>    this helps ensure that the costs incurred remain subject to prudent
>    management.
>
> Sorry I will not be able to attend today.
>
>
>
> Best wishes,
>
> David
>
>
>
> David McAuley
>
> Policy Director
>
> Verisign, Inc.
>
>
>
> *From:* Mike Silber <silber.mike at gmail.com>
> *Sent:* Tuesday, December 6, 2022 6:22 AM
> *To:* Malcolm Hutty <Malcolm at linx.net>
> *Cc:* McAuley, David <dmcauley at Verisign.com>; susan.payne at comlaude.com;
> iot at icann.org
> *Subject:* [EXTERNAL] Re: [IOT] IRP-IOT action items/next steps on
> Initiation
>
>
>
> *Caution:* This email originated from outside the organization. Do not
> click links or open attachments unless you recognize the sender and know
> the content is safe.
>
> Hi Malcom
>
>
>
> I think you make several excellent points below. At the same time I think
> you are ascribing certain intent to some of David’s statements that may be
> unwarranted. Rather than responding in-line [to avoid picking nits] or
> speaking for David [as he can respond if he feels it is required] I will
> top post.
>
>
>
> My personal view [recognising that i have been observing in the background
> and may not be totally current]:
>
>
>
>    - a party intending to use the IRP (“applicant”) should pay a filing
>    fee. The filing fee should be a first gate to limit trivial or vexatious
>    use of the process, but not so onerous to prevent use of the process.
>    Deserving [needy] applicants should be entitled to seek a waiver of the fee
>    from the panel;
>    - a successful applicant should be entitled to have the filing fee
>    refunded;
>    - the question of costs and fees is best dealt with by the panel
>    having regard to fairness and equity with the IRP process giving some
>    limited guidance which could be:
>
>
>    - commercial applicants should pay their own costs [they will
>       presumably get commercial benefit from a positive outcome] and only be
>       entitled to a refund of those costs if ICANN’s opposition is frivolous or
>       vexatious;
>       - non-commercial applicants must apply to the panel for their costs
>       to be met, which may be granted in whole or in part;
>       - ICANN pays its own costs and is only able to claim back costs
>       from an (i) unsuccessful; *and* (ii) frivolous or vexatious
>       applicant [an applicant who is unsuccessful but not frivolous or vexatious
>       should nt be act risk of a claim for ICANN’s costs];
>       - ICANN should pay all the panel / IRP process costs [except for
>       the initial filing fee] and is only entitled to claim a refund of costs if
>       a finding is made that the claim is frivolous or vexatious; and
>       - a party’s costs include both internal, legal and administrative
>       costs [courier, translation etc] and should follow the above process.
>
>
>
> Regards
>
>
>
> Mike
>
>
>
> On 5 Dec 2022, at 18:32, Malcolm Hutty via IOT <iot at icann.org> wrote:
>
>
>
> Dear all,
>
>
>
> David wrote:
>
> Presumably, a prevailing party will make a claim for such costs or fees,
> the losing party will have an opportunity to challenge the claim, and we
> should trust the panel to make an appropriate ruling. I believe that here
> too they should act consistent with international arbitration norms (see
> also Bylaw 4.3(a)(viii)).
>
>
>
> I think this notion that a prevailing party will have to claim for costs
> and fees, while typical for litigation in a court of law, is a big part of
> what the IRP was intended to avoid.
>
>
>
> The idea was that ICANN would have an independent review process that
> claimants could access to resolve disputes. Nothing in the bylaws
> authorises ICANN (or its provider) to condition access this process on
> payment of fees, just as there is no suggestion that you have to pay to
> file a Request for Reconsideration or to use the services of the Ombudsman.
>
>
>
> Moreover, in David’s formulation, if a Claimant loses, then they’re not
> the prevailing party and would not be able to claim for costs and fees.
> This is quite different to the bylaws requirement that ICANN pays the costs
> of the IRP, with them only being shifted when the claim was frivolous or
> vexatious.
>
>
>
> David asserts that the bylaws language requiring ICANN to pay the costs of
> the IRP mechanism only applies to some intangible costs that form a
> ‘mechanism’ that somehow exclude the actual operation of that mechanism. I
> find that distinction artificial, a construct invented to support charging
> the Claimant, but without foundation in the bylaws.
>
>
>
> We should always look to the Bylaws themselves to understand what is
> required.
>
>
>
> David’s assertion that the ‘IRP mechanism’ and the process of hearing a
> dispute are distinct is actually contradicted directly by the bylaws
> themselves: Bylaw 4.3(r) states quite explicitly that the fees of the
> panellists who hear the dispute are included in the definition of
> administrative costs. Yet these fees are incontrovertibly the cost of
> hearing one individual dispute. So any possible suggestion that the costs
> of hearing the dispute are outside the definition of “administrative costs”
> is directly excluded by the clear language of 4.3(r).
>
>
>
> This notion of an IRP mechanism as being something other than the process
> of hearing disputes arises only because we keep using shorthand: we talk of
> “the IRP” and forget what the IRP actuall is. We need to look back to the
> bylaws definition of the IRP to see what the “IRP” really means.
>
>
>
> Bylaws Article 4.3 (a) begins as follows:
>
> “ In addition to the reconsideration process described in *Section 4.2*,
> ICANN shall have a separate process for independent third-party review of
> Disputes (defined in *Section 4.3(b)(iii)*) alleged by a Claimant (as
> defined in *Section 4.3(b)(i)*) to be within the scope of the Independent
> Review Process ("*IRP*"). The IRP is intended to hear and resolve
> Disputes for the following purposes ("*Purposes of the IRP*"): […]”
>
>
>
> This is where IRP is defined: it is a defined term. It refers to “a
> separate process for independent third-party review of Disputes”.
> Accordingly when 4.3(r) speaks of ICANN paying for the ‘IRP mechanism’, it
> is referring to “the process for independent third-party review of
> Disputes”. The mechanism **is** the process: there is nothing else.
>
>
>
> Bylaw 4.3(r) requires ICANN to pay for the process of those Disputes being
> reviewed. That is what ‘IRP mechanism’ means. Which is entirely consistent
> with everything else that is said in the Bylaws, including the Purposes.
>
>
>
> Kind Regards,
>
>
>
> Malcolm.
>
>
>
>
>
> --
>
> * Malcolm Hutty | Executive Director, Legal and Policy*
>
> T: +44 7789 987 023 | www.linx.net
> <http://secure-web.cisco.com/1gXx9xbCru0oZFI-I6cKHfFRzZEJ-IRIPzx0q-EjM2gMoAdTyFo_FX-O6lwVvRquI9YLJrCdQnSszD5STY3x1BoGInoPNWMOLYZJzOUfglxuuDMmUe2qejkTskCGtyUNyozbxhdc3itm1saMNr9-wXhcN4fjFKWSGBJpvyIe9wrsADkmLcpPC35AiYV1lMaKBYAgH0yxoA2W7hZ9ppxPDLvcOViSKGwUq6AQNxcSlf9EjZpWPBZbhLcig2JXbKWNZDIcgxRxCsEnrINITeiHSI3qRZdBFC8UgD9reu76GKaU/http%3A%2F%2Fwww.linx.net%2F>
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>
> *From:* IOT <iot-bounces at icann.org> *On Behalf Of *McAuley, David via IOT
> *Sent:* 05 December 2022 13:28
> *To:* susan.payne at comlaude.com; iot at icann.org
> *Subject:* Re: [IOT] IRP-IOT action items/next steps on Initiation
>
>
>
> Thank you, Susan.
>
>
>
> My thoughts are below since I need to send apologies for the meeting
> tomorrow. There is a conflicting meeting for the Community Representatives
> Group to nominate members of the IRP Standing Panel that I must attend.
>
>
>
> With respect to the issue of filing-fee costs, Bylaw 4.3(r) indicates that
> ICANN will bear the administrative costs of maintaining the IRP
> *mechanism*. In my opinion that does not include a complainant’s filing
> fee, which instead should be set (probably by ICDR) so as to conform to
> international arbitration norms (Bylaw 4.3(n)(i) and (ii)). Whatever is set
> as an initiation fee should not act as an unreasonable bar to filing
> complaints, I think, as that would probably not conform to such norms.
>
>
>
> On other costs that might routinely apply, I think that we should ensure
> that a clear and easily findable link to the schedule of applicable fees on
> the ICDR website be available. It should not take the labors of Hercules to
> find these fees.
>
>
>
> As for any other administrative costs and/or fees that might be shifted
> under Bylaw 4.3(r), I appreciate the thought you put into this as manifest
> in the google doc. But I tend to think it better not to try to
> anticipate/imagine such costs. Here, I think the principle in the bylaw is
> ok as written.
>
>
>
> Presumably, a prevailing party will make a claim for such costs or fees,
> the losing party will have an opportunity to challenge the claim, and we
> should trust the panel to make an appropriate ruling. I believe that here
> too they should act consistent with international arbitration norms (see
> also Bylaw 4.3(a)(viii)).
>
>
>
> Best wishes,
>
> David
>
>
>
> David McAuley
>
> Policy Director
>
> Verisign, Inc.
>
>
>
> *From:* IOT <iot-bounces at icann.org> *On Behalf Of *Susan Payne via IOT
> *Sent:* Friday, December 2, 2022 5:01 PM
> *To:* iot at icann.org
> *Subject:* [EXTERNAL] [IOT] IRP-IOT action items/next steps on Initiation
>
>
>
> *Caution:* This email originated from outside the organization. Do not
> click links or open attachments unless you recognize the sender and know
> the content is safe.
>
> Hi all
>
>
>
> On our last call, our discussion on initiation we pent much of our time
> focussed on the allocation of costs and fees, with reference to the
> language of Bylaws 4.3(r).  As a result of this, we had one action item for
> Sam, but also a task for all of us to try to give clarity for potential
> claimants on the costs they will be responsible for.
>
>
>
> We also captured a useful suggestion to use flashes to indicate an updated
> section (as the UN do), with respect to the planned improvements to the IRP
> website area which have been anticipated for some time now.
>
>
>
> *Action items from our previous call*
>
> Sam to provide information on costs awards from pre-Transition (2016)
> IRPs, which may assist with this discussion
>
>
>
> *Action for us all*
>
> Irrespective of where we come out on the narrow issue of the IRP filing
> fee, Kavouss raised a point on our last call which I think resonated with
> most of the group.  Participants and potential participants of an IRP need
> to know what costs they will be responsible for.  This is directly relevant
> to initiation because potential Claimants to an IRP should be aware of what
> they are committing to when they make the decision to proceed.  If Bylaws
> 4.3(r) is ambiguous – which, based on our discussions, does seem to be the
> case – then we must give them this clarity.  Even if we cannot be
> exhaustive as to all possible costs, we should be able to identify
> sufficient examples to serve as a guide for participants on what types of
> costs will fall to them.
>
>
>
> Below is a link to a Google Doc where I have started to capture types of
> costs that would likely be incurred in an IRP, and tried to identify who
> bears these costs, currently.  In order to make a start on this, I went
> back to the .WEB decision since this is a case decided under the new Bylaws
> and where there were some costs orders made, and I have included a footnote
> to explain where the costs addressed in that decision seem to give us some
> guidance.  As a result, for a few items I have indicated both that the
> Claimant initially paid and that this was later ordered to be reimbursed by
> ICANN. Indeed, the Claimant’s filing fee, which we have been discussing at
> length, does appear to have been reimbursed in the .WEB case.
>
>
>
>
> https://docs.google.com/document/d/1AUMSllaxG_9SicIEVoq4eHwzHn95D8rNPqjwIECNLvI/edit?usp=sharing
>
>
>
> I am putting this forward to get the ball rolling.  I am sure that there
> will be other costs/fees that I have not thought about, and I hope that
> others in the group will add to this, particularly those who are
> practitioners. I would also welcome input from IOT members who disagree
> with my characterisation of any of these items.  I am not a practitioner so
> may inadvertently have mischaracterised something.
>
>
>
> Susan Payne
> Head of Legal Policy
>
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> not accept any responsibility for viruses and it is your responsibility to
> scan or otherwise check this email and any attachments. The Com Laude Group
> does not accept liability for statements which are clearly the sender's own
> and not made on behalf of the group or one of its member entities. The Com
> Laude Group is a limited company registered in England and Wales with
> company number 10689074 and registered office at 28-30 Little Russell
> Street, London, WC1A 2HN England. The Com Laude Group includes Nom-IQ
> Limited t/a Com Laude, a company registered in England and Wales with
> company number 5047655 and registered office at 28-30 Little Russell
> Street, London, WC1A 2HN England; Valideus Limited, a company registered in
> England and Wales with company number 6181291 and registered office at
> 28-30 Little Russell Street, London, WC1A 2HN England; Demys Limited, a
> company registered in Scotland with company number SC197176 and registered
> office at 15 William Street, South West Lane, Edinburgh, EH3 7LL Scotland;
> Consonum, Inc. dba Com Laude USA and Valideus USA, a corporation
> incorporated in the State of Washington and principal office address at
> Suite 332, Securities Building, 1904 Third Ave, Seattle, WA 98101; Com
> Laude (Japan) Corporation, a company registered in Japan with company
> number 0100-01-190853 and registered office at 1-3-21 Shinkawa, Chuo-ku,
> Tokyo, 104-0033, Japan; Com Laude Domain ESP S.L.U., a company registered
> in Spain and registered office address at Calle Barcas 2, 2, Valencia,
> 46002, Spain. For further information see www.comlaude.com
> <https://secure-web.cisco.com/1fAS9w-NRUWTvfqlrwf9dqUaqT8nWymC_MP4NWXVwcfSqc1MsM7EOHuk4KBciMJ2ypcKZizxMVR5nJDnBt6CDGWMp9v4RWnyGgEJaQpRX9muHdjWic17n6fklslPhtD6zGkWT4IiC1QGBgBqJMfp45A6v1_dZTBn2iFgozcf9aERaQRFdT0Fpg7z_2gXXfG2lpLecgMkxzDxVgiWp4mEfAfkzv65CWBSYMQT0wkIb2SKCZlpvvR0a4Kp1igDf_O3euH0_0t_OWTXoLiXTfIeT8FzlvGfPc9ksMiZGXCtGVfM/https%3A%2F%2Fcomlaude.com>
>
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> ------------------------------
>
> The contents of this email and any attachments are confidential to the
> intended recipient. They may not be disclosed, used by or copied in any way
> by anyone other than the intended recipient. If you have received this
> message in error, please return it to the sender (deleting the body of the
> email and attachments in your reply) and immediately and permanently delete
> it. Please note that Com Laude Group Limited (the “Com Laude Group”) does
> not accept any responsibility for viruses and it is your responsibility to
> scan or otherwise check this email and any attachments. The Com Laude Group
> does not accept liability for statements which are clearly the sender's own
> and not made on behalf of the group or one of its member entities. The Com
> Laude Group is a limited company registered in England and Wales with
> company number 10689074 and registered office at 28-30 Little Russell
> Street, London, WC1A 2HN England. The Com Laude Group includes Nom-IQ
> Limited t/a Com Laude, a company registered in England and Wales with
> company number 5047655 and registered office at 28-30 Little Russell
> Street, London, WC1A 2HN England; Valideus Limited, a company registered in
> England and Wales with company number 6181291 and registered office at
> 28-30 Little Russell Street, London, WC1A 2HN England; Demys Limited, a
> company registered in Scotland with company number SC197176 and registered
> office at 15 William Street, South West Lane, Edinburgh, EH3 7LL Scotland;
> Consonum, Inc. dba Com Laude USA and Valideus USA, a corporation
> incorporated in the State of Washington and principal office address at
> Suite 332, Securities Building, 1904 Third Ave, Seattle, WA 98101; Com
> Laude (Japan) Corporation, a company registered in Japan with company
> number 0100-01-190853 and registered office at 1-3-21 Shinkawa, Chuo-ku,
> Tokyo, 104-0033, Japan; Com Laude Domain ESP S.L.U., a company registered
> in Spain and registered office address at Calle Barcas 2, 2, Valencia,
> 46002, Spain. For further information see www.comlaude.com
> <https://comlaude.com>
> ------------------------------
> The contents of this email and any attachments are confidential to the
> intended recipient. They may not be disclosed, used by or copied in any way
> by anyone other than the intended recipient. If you have received this
> message in error, please return it to the sender (deleting the body of the
> email and attachments in your reply) and immediately and permanently delete
> it. Please note that Com Laude Group Limited (the “Com Laude Group”) does
> not accept any responsibility for viruses and it is your responsibility to
> scan or otherwise check this email and any attachments. The Com Laude Group
> does not accept liability for statements which are clearly the sender's own
> and not made on behalf of the group or one of its member entities. The Com
> Laude Group is a limited company registered in England and Wales with
> company number 10689074 and registered office at 28-30 Little Russell
> Street, London, WC1A 2HN England. The Com Laude Group includes Nom-IQ
> Limited t/a Com Laude, a company registered in England and Wales with
> company number 5047655 and registered office at 28-30 Little Russell
> Street, London, WC1A 2HN England; Valideus Limited, a company registered in
> England and Wales with company number 6181291 and registered office at
> 28-30 Little Russell Street, London, WC1A 2HN England; Demys Limited, a
> company registered in Scotland with company number SC197176 and registered
> office at 15 William Street, South West Lane, Edinburgh, EH3 7LL Scotland;
> Consonum, Inc. dba Com Laude USA and Valideus USA, a corporation
> incorporated in the State of Washington and principal office address at
> Suite 332, Securities Building, 1904 Third Ave, Seattle, WA 98101; Com
> Laude (Japan) Corporation, a company registered in Japan with company
> number 0100-01-190853 and registered office at 1-3-21 Shinkawa, Chuo-ku,
> Tokyo, 104-0033, Japan; Com Laude Domain ESP S.L.U., a company registered
> in Spain and registered office address at Calle Barcas 2, 2, Valencia,
> 46002, Spain. For further information see www.comlaude.com
> <https://comlaude.com>
>
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