Just a quick one, Bill. We do have escalated sanctions in the recommendations.<br><br><div class="gmail_quote">On 1 December 2011 04:41, Smith, Bill <span dir="ltr"><<a href="mailto:bill.smith@paypal-inc.com">bill.smith@paypal-inc.com</a>></span> wrote:<br>
<blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex;">>From my perspective this sets appropriately sets the stage. I'm sure we can whack and whittle at he words and "improve" them. I think we do need some companion language that builds of some of our (informal?) findings that a set of sliding/escalating consequences for failure to act is required. Without that, nothing in the ICANN contracts compels anyone contracted part, direct or otherwise, to do anything. That needs to be corrected.<br>
<div class="HOEnZb"><div class="h5"><br>
On Nov 30, 2011, at 7:34 PM, "Nettlefold, Peter" <<a href="mailto:Peter.Nettlefold@dbcde.gov.au">Peter.Nettlefold@dbcde.gov.au</a>> wrote:<br>
<br>
> Classification: UNCLASSIFIED<br>
><br>
> Hi Seth,<br>
><br>
> Thanks very much for taking the pen on this difficult issue.<br>
><br>
> From my perspective, this is a very good attempt to articulate findings and recommendations, and I am happy to work with this position.<br>
><br>
> I will wait to hear from others before diving into detail too much, to get a sense if this is an approach we can work with.<br>
><br>
> Thanks again.<br>
><br>
> Peter<br>
><br>
> ----- Original Message -----<br>
> From: Seth M Reiss [mailto:<a href="mailto:seth.reiss@lex-ip.com">seth.reiss@lex-ip.com</a>]<br>
> Sent: Thursday, December 01, 2011 02:26 PM<br>
> To: 'Smith, Bill' <<a href="mailto:bill.smith@paypal-inc.com">bill.smith@paypal-inc.com</a>><br>
> Cc: <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a> <<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><br>
> Subject: Re: [Rt4-whois] streamlined proxy recommendation language<br>
><br>
> mmm, didn't really want that kind of pressure.<br>
><br>
> Here's an attempt:<br>
><br>
> Data Access- Proxy Service<br>
><br>
> 1. The Review Team considers a Proxy Service as a relationship in which<br>
> the registrant is acting on behalf of another. The WHOIS data is that of the<br>
> agent/proxy service and the agent/proxy service alone obtains all rights and<br>
> assumes all responsibility for the domain name and its manner of use.<br>
> 2. ICANN should clarify that any registrant that may be acting as a<br>
> proxy service for another is in all respects still the registrant and, in<br>
> ICANN's view, should be held fully responsible for the use of the domain<br>
> name including for any and all harm that results from the use of the domain<br>
> name.<br>
> 2. Because of ICANN's position on proxy services to date, which<br>
> tolerates the proxy service industry that has arisen and which through RAA<br>
> provisions gives recognition and attempts to regulate that industry, has<br>
> been used by courts and others to allow proxy services to escape liability<br>
> for bad acts of the proxy service customers, ICANN should either delete or<br>
> amend those provisions of the RAA that can or have been used to allow proxy<br>
> services to escape liability.<br>
> 3. The Review Team acknowledges that there may be legitimate reasons<br>
> for the occasional use of a proxy service, as for example to protect a<br>
> valuable trade secret at product launch. At the same time proxy services<br>
> should not be viewed or used as a substitute for privacy services that are<br>
> designed to shield an individual's personal contact information. The<br>
> legitimate use a proxy service would be the exception and not widespread.<br>
> 4. A proxy service industry willing to accept full risks and liabilities<br>
> for the manner in which domain names through its service will be used will<br>
> take the necessary precautionary measures, in its relationship with its<br>
> customers, such that domain names so registered are unlikely to be misused<br>
> and, if misused, a remedy for those victimized will more likely be<br>
> available.<br>
><br>
> I suspect most of you are asleep by now anyway. If not, feel free to<br>
> comment or modify or supplement, or in the morning.<br>
><br>
> Seth<br>
><br>
><br>
> -----Original Message-----<br>
> From: Smith, Bill [mailto:<a href="mailto:bill.smith@paypal-inc.com">bill.smith@paypal-inc.com</a>]<br>
> Sent: Wednesday, November 30, 2011 4:34 PM<br>
> To: Seth M Reiss<br>
> Cc: Kathy Kleiman; <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>; Susan Kawaguchi<br>
> Subject: Re: [Rt4-whois] streamlined proxy recommendation language<br>
><br>
> Seth,<br>
><br>
> Any chance you cold take a crack at this? Your writing on the subject seems<br>
> on point and I suspect you could say it using fewer words than I.<br>
><br>
> Bill<br>
><br>
> On Nov 30, 2011, at 6:27 PM, "Susan Kawaguchi" <<a href="mailto:susank@fb.com">susank@fb.com</a>> wrote:<br>
><br>
>> Hi Bill,<br>
>><br>
>> This is a valuable (albeit frustrating) discussion and necessary to make<br>
> sure we get this right, I appreciate the argument. I think we all want the<br>
> end result but it is getting to that point that may be painful but we knew<br>
> this task could be painful when we signed on.<br>
>><br>
>> Is there a stronger recommendation that you and Seth could draft that<br>
> outlines your view point?<br>
>><br>
>> This is all that we said in the recommendations in Dakar<br>
>><br>
>> "Remove proxy services from the RAA since the proxy, as an agent, is the<br>
> registrant. Expand and ? affirmative sentence"<br>
>><br>
>> I cannot live with that what would you propose to strengthen the<br>
> recommendation?<br>
>><br>
>> At this point, I am not willing to walk away from the best practices<br>
> recommendation but I am very willing to continue the discussion and see if<br>
> there is a way forward on a recommendation we all agree to.<br>
>><br>
>> I am going to eat dinner and walk the dog so will be offline for an hour.<br>
>><br>
>> Susan<br>
>><br>
>> -----Original Message-----<br>
>> From: Smith, Bill [mailto:<a href="mailto:bill.smith@paypal-inc.com">bill.smith@paypal-inc.com</a>]<br>
>> Sent: Wednesday, November 30, 2011 5:19 PM<br>
>> To: Susan Kawaguchi<br>
>> Cc: Seth M Reiss; Kathy Kleiman; <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a><br>
>> Subject: Re: [Rt4-whois] streamlined proxy recommendation language<br>
>><br>
>> Susan,<br>
>><br>
>> It may not seem like it but I am supportive, very supportive of your<br>
> position of to not rely on litigation to solve these types of problems.<br>
> Where we disagree is the best approach to avoid the litigation.<br>
>><br>
>> I am not suggesting that cigarette-style litigation is the way forward.<br>
> Rather, I am concerned that proposal for retail proxy indemnification (if<br>
> I've read it right) will result in exactly that situation, some time far in<br>
> the future when society and the courts finally realize that allowing<br>
> unfettered criminal activity on the Internet is a bad idea. Retail proxies<br>
> will happily sell a service to people they don't know as long as they have<br>
> no liability.<br>
>><br>
>> If instead of no liability, we insist that they have the liability of the<br>
> Registrant, since that's what they are, I strongly suspect that counsel for<br>
> these services will understand that they now carry at least some risk in<br>
> these transactions. Consequently, they will either recommend against them or<br>
> insist on some mechanism to mitigate the risk, through insurance or other<br>
> mechanisms - perhaps even actually knowing something about their customers.<br>
> Any or all of these would involve higher costs hence higher prices making<br>
> these services less attractive to criminals, etc.<br>
>><br>
>> By the addition of SLAs into contracts, and mandatory consequences, we<br>
> provide a means for ICANN to ensure that valid queries, information<br>
> requests, corrections, etc. are made in a timely manner. A registrant could<br>
> ignore a request knowing that the specific penalty for failing to comply<br>
> with such request. With mandatory revocation the consequence of last resort,<br>
> we give the community and ICANN the ability to revoke a name (the only thing<br>
> of value under our control).<br>
>><br>
>> If a proxy is a party to any of these transactions, they act as the<br>
> Registrant and must respond either directly or with guidance from the<br>
> licensee per the agreement SLAs. Failure to do so results in the same<br>
> consequences.<br>
>><br>
>> By setting SLAs and consequences appropriately, ICANN can influence the<br>
> behavior of Registrants and those that act as proxies for them.<br>
>><br>
>> Even if we go with language you an James worked on, and I realize that you<br>
> put in a great deal of effort on that, we'll still need something like what<br>
> I have outlined because as we discussed in Dakar, anyone can act as a proxy<br>
> for a Registrant no matter what ICANN tries to do to prevent it. If the<br>
> "best practices" ICANN develops for the retail trade prove too onerous,<br>
> proxy providers will simply step outside of the ICANN tent and provide their<br>
> services likely failing to adhere to the best practices.<br>
>><br>
>> I hope this makes sense.<br>
>><br>
>> Bill<br>
>><br>
>><br>
>> On Nov 30, 2011, at 4:38 PM, Susan Kawaguchi wrote:<br>
>><br>
>> HI Bill,<br>
>><br>
>> Thank you for your thoughts I think your statement below is my biggest<br>
> pain point.<br>
>><br>
>> "I think they are inherently contradictory. How a service is *sold* should<br>
> not determine liability. If this were the case and we applied the proposed<br>
> definitions to consumer products, untold numbers of tort cases would be<br>
> summarily thrown out. Cigarette, toy, and asbestos manufacturers could<br>
> properly claim, "I don't know the buyer therefor I have no liability"."<br>
>><br>
>> All of the cases you mention above relied on litigation to clarify the<br>
> existence of liability and impose that liability on the manufacturer. It<br>
> would be overwhelming and burdensome to rely on litigation to fix this<br>
> problem especially when it involves global entities as proxy service<br>
> providers. I think we have the opportunity to incentivize the registrars to<br>
> help with the problem.<br>
>><br>
>> If I or LE are forced to rely on litigation of any sort of court order to<br>
> get information on the licensee of a domain name to pursue a provider of<br>
> counterfeit drugs, for example, this would take years for each domain name<br>
> involved.<br>
>><br>
>> If we take a very extreme step and recommend that proxy services are not<br>
> allowed in the gTlds (as .US has done) how would that ever be enforced?<br>
> Proxy registrations provide a vital service for many in the domain name<br>
> space.<br>
>><br>
>> Susan<br>
>><br>
>> -----Original Message-----<br>
>> From: Smith, Bill [mailto:<a href="mailto:bill.smith@paypal-inc.com">bill.smith@paypal-inc.com</a>]<br>
>> Sent: Wednesday, November 30, 2011 4:20 PM<br>
>> To: Seth M Reiss<br>
>> Cc: Susan Kawaguchi; Kathy Kleiman;<br>
> <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><br>
>> Subject: Re: [Rt4-whois] streamlined proxy recommendation language<br>
>><br>
>> See below:<br>
>><br>
>> On Nov 30, 2011, at 4:03 PM, "Seth M Reiss"<br>
> <<a href="mailto:seth.reiss@lex-ip.com">seth.reiss@lex-ip.com</a><mailto:<a href="mailto:seth.reiss@lex-ip.com">seth.reiss@lex-ip.com</a>><mailto:<a href="mailto:seth.reiss@lex-i">seth.reiss@lex-i</a><br>
> <a href="http://p.com" target="_blank">p.com</a>>> wrote:<br>
>><br>
>> I am not advocating ignoring proxy services simply clarifying their role<br>
> and liability as registrant. I suspect we are very closely aligned<br>
> regarding outcome, just not how to reach there.<br>
>><br>
>> I guess I'm advocating that we get as close to ignoring them as we can.<br>
> Recognizing them, even in the limited way the current RAA does gave the<br>
> Ninth Circuit everything it need to make its liability absolving decision.<br>
>><br>
>> While the community may not be inclined to receive a proposal to "ignore<br>
> proxy services" with open arms, I hope they would consider it if we present<br>
> it as in the public interest.<br>
>><br>
>><br>
>> I think we disagree regarding whether we need to tolerate an industry<br>
> simply because it exists and has for a time. ICANN did not tolerate domain<br>
> name tasting, although it acted relatively quickly there and has not here.<br>
>><br>
>> I believe it to be a dangerous proposition to say that we need to<br>
> accommodate existing practices simply because ICANN has allowed them to<br>
> exist for a period of time, although I think it's an unfortunately<br>
> circumstance. If you apply this line of reasoning broadly, you effectively<br>
> allow the industry to restrict what ICANN can and cannot do.<br>
>><br>
>> If we make this assumption generally, our report would be very short. Yes<br>
> there are problems with WHOIS. However, it has existed in this manner for<br>
> too long and therefor it cannot be changed.<br>
>><br>
>><br>
>> I would like to find a middle ground. I am not one for asking people to<br>
> think differently. I just don't see how holding stating a proxy should be<br>
> held fully responsible, and then at the same time having retail proxy<br>
> services definitions and a voluntary best practices policy, will not be<br>
> viewed as inherently contradictory.<br>
>><br>
>> I think they are inherently contradictory. How a service is *sold* should<br>
> not determine liability. If this were the case and we applied the proposed<br>
> definitions to consumer products, untold numbers of tort cases would be<br>
> summarily thrown out. Cigarette, toy, and asbestos manufacturers could<br>
> properly claim, "I don't know the buyer therefor I have no liability".<br>
>><br>
>> Other than to satisfy, the current purveyors of these fine services, I<br>
> can't see any reason to develop a complex set of definitions and liability<br>
> flows. Together these give attorneys and courts ample room to for truck<br>
> driving.<br>
>><br>
>><br>
>> Seth<br>
>><br>
>><br>
>> From: Susan Kawaguchi [mailto:<a href="mailto:susank@fb.com">susank@fb.com</a>]<br>
>> Sent: Wednesday, November 30, 2011 1:29 PM<br>
>> To: Kathy Kleiman; Seth M Reiss<br>
>> Cc:<br>
> <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><br>
>> Subject: RE: [Rt4-whois] streamlined proxy recommendation language<br>
>><br>
>> HI Seth,<br>
>><br>
>> I am going to respond to you out of order<br>
>> In all our discussions, I have still not heard a persuasive argument why a<br>
> proxy service industry that can shield itself from liability is necessary or<br>
> good or appropriate. I agree with you but it is what is. The situation<br>
> arose over 10 years ago and I do not think that advocating to do away with<br>
> proxy services is going to be well received by the ICANN community. Also<br>
> to date, there has been very few examples of a proxy service being held<br>
> liable.<br>
>><br>
>> We need proxy services but we need responsive proxy services many of the<br>
> providers are acting responsibly it is the bad actors that I would like to<br>
> change their behavior.<br>
>><br>
>> Once you introduce definitions concerning affiliates, retail services and<br>
> different flavors of proxy services, the cheap ones with flimsy<br>
> relationships, and the expensive ones with fiduciary type relationships, it<br>
> will appear to the court that you do not really mean what you saying in<br>
> bullet number 6. This will confuse the courts (and the public) and the<br>
> registrant proxy services is more likely to be able to weasel out of being<br>
> held liable.<br>
>><br>
>> I am not sure that these definitions would be accepted outside of ICANN<br>
> and at least we would have a clearer picture of who we are dealing with.<br>
>><br>
>> I am not convinced at all that just removing the language from the RAA<br>
> would impact the practices of the current proxy services. If you have<br>
> another argument let me know I am open to rethinking this but I am not open<br>
> to ignoring proxy service providers.<br>
>><br>
>> Susan<br>
>><br>
>> From:<br>
> <a href="mailto:rt4-whois-bounces@icann.org">rt4-whois-bounces@icann.org</a><mailto:<a href="mailto:rt4-whois-bounces@icann.org">rt4-whois-bounces@icann.org</a>><mailto:<a href="mailto:rt4-w">rt4-w</a><br>
> <a href="mailto:hois-bounces@icann.org">hois-bounces@icann.org</a>> [mailto:<a href="mailto:rt4-whois-bounces@icann.org">rt4-whois-bounces@icann.org</a>] On Behalf Of<br>
> Kathy Kleiman<br>
>> Sent: Wednesday, November 30, 2011 3:15 PM<br>
>> To: Seth M Reiss<br>
>> Cc:<br>
> <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><br>
>> Subject: Re: [Rt4-whois] streamlined proxy recommendation language<br>
>><br>
>> Great comments, Seth. I defer to Susan and James, as the experts on this<br>
> material.<br>
>> Best,<br>
>> Kathy<br>
>><br>
>> :<br>
>> Thank you Kathy for breaking this out. I have not been good about<br>
> reviewing the entire document.<br>
>><br>
>> To respond to Peter's question about what would be legally enforceable, I<br>
> think if you look at bullet number 6, if this bullet was implemented in a<br>
> very clear and unambiguous way, by itself and without some of the other<br>
> material being proposal, then I think there would be reasonable expectation<br>
> that national courts would hold the registrant proxy service fully<br>
> responsible for harm caused by a website hosted at the domain name at issue.<br>
> In other words, the Ninth Circuit decision that Susan highlighted would have<br>
> been decided differently.<br>
>><br>
>> Once you introduce definitions concerning affiliates, retail services and<br>
> different flavors of proxy services, the cheap ones with flimsy<br>
> relationships, and the expensive ones with fiduciary type relationships, it<br>
> will appear to the court that you do not really mean what you saying in<br>
> bullet number 6. This will confuse the courts (and the public) and the<br>
> registrant proxy services is more likely to be able to weasel out of being<br>
> held liable.<br>
>><br>
>> The current proposal on the table suggests to me a somewhat more<br>
> complicated model whereby the registrant proxy service is fully liable for<br>
> the use of the domain name but can shield that liability by adopted and<br>
> fully complying the a specific set of reveal and relay processes etc. I<br>
> voluntary set of best practices would not do this, but a mandatory set of<br>
> provisions to qualify a proxy service for a "safe harbor" would. Such a<br>
> safe hard model would in my view be more difficult to implement and is<br>
> likely to give rise to a certain amount of uncertainty and inconsistent<br>
> outcomes even if prudently implemented. But this also assumes that we need<br>
> to have a proxy service in which proxies may shield themselves from<br>
> liability. In all our discussions, I have still not heard a persuasive<br>
> argument why a proxy service industry that can shield itself from liability<br>
> is necessary or good or appropriate.<br>
>><br>
>> Seth<br>
>><br>
>><br>
>> From:<br>
> <a href="mailto:rt4-whois-bounces@icann.org">rt4-whois-bounces@icann.org</a><mailto:<a href="mailto:rt4-whois-bounces@icann.org">rt4-whois-bounces@icann.org</a>><mailto:<a href="mailto:rt4-w">rt4-w</a><br>
> <a href="mailto:hois-bounces@icann.org">hois-bounces@icann.org</a>> [mailto:<a href="mailto:rt4-whois-bounces@icann.org">rt4-whois-bounces@icann.org</a>] On Behalf Of<br>
> Kathy Kleiman<br>
>> Sent: Wednesday, November 30, 2011 12:24 PM<br>
>> To:<br>
> <a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><mailto:<a href="mailto:rt4-whois@icann.org">rt4-whois@icann.org</a>><br>
>> Subject: [Rt4-whois] streamlined proxy recommendation language<br>
>><br>
>> Hi All,<br>
>> I feel like I am sending altogether too many emails today. Sorry :-)!<br>
> Anyway, here's one more. I worked with James, a little, and Susan, more, on<br>
> streamlining the Proxy recommendations to look, sound and flow like the<br>
> Privacy recommendations. Of course, proxy is voluntary, and privacy is a<br>
> requirement, but the rest is fairly close.<br>
>><br>
>> They are below and attached. If you like them, we'll send them on to Alice<br>
> for inclusion. Note: the definitions went into a footnote which should be<br>
> easy to see as it will be quite extensive.<br>
>><br>
>> here's the text:<br>
>><br>
>> Data Access- Proxy Service<br>
>><br>
>> 1. ICANN should facilitate the review of existing practices by<br>
> reaching out to proxy providers to create a discussion which sets out<br>
> current processes followed by proxy service providers.<br>
>><br>
>> 2. Registrars should be required to disclosure their relationship<br>
> with any Affiliated Retail proxy service provider to ICANN.<br>
>><br>
>> 3. ICANN should develop and manage a set of voluntary best practice<br>
> guidelines for appropriate proxy services [footnote 1] consistent with<br>
> national laws. These voluntary guidelines should strike an appropriate<br>
> balance between stakeholders with competing but legitimate interests. At a<br>
> minimum this would include privacy, law enforcement and the industry around<br>
> law enforcement.<br>
>><br>
>> Such voluntary guidelines may include:<br>
>><br>
>> + Proxy services provide full contact details as required by the Whois<br>
>><br>
>> + Publication by the proxy service of its process for revealing and<br>
> relaying information<br>
>><br>
>> + Standardization of reveal and relay processes and timeframes, consistent<br>
> with national laws<br>
>><br>
>> + Maintenance of a dedicated abuse point of contact for the proxy service<br>
> provider<br>
>><br>
>> + Due diligence checks on licensee contact information.<br>
>><br>
>> 5. ICANN should encourage and incentivize registrars to interact with the<br>
> retail service providers that adopt the best practices.<br>
>><br>
>> 6. For the avoidance of doubt, the WHOIS Policy, referred to in<br>
> Recommendation 1 above, should include an affirmative statement that<br>
> clarifies that a proxy means a relationship in which the Registrant is<br>
> acting on behalf of another. The WHOIS data is that of the agent, and the<br>
> agent alone obtains all rights and assumes all responsibility for the domain<br>
> name and its manner of use.<br>
>><br>
>> Footnote 1 (all the remaining text)<br>
>> As guidance to the Community and as useful background for the Proxy<br>
> Service Recommendations, the Review Team provides its working definitions of<br>
> proxy service and different types of proxy service providers:<br>
>><br>
>> - Proxy Service - a relationship in which the registrant is acting on<br>
> behalf of another The WHOIS data is that of the agent and the agent alone<br>
> obtains all rights and assumes all responsibility for the domain name and<br>
> its manner of use. [KK: is this the definition we are using in other places<br>
> in the Report?]<br>
>><br>
>> - Affiliated Registrar - another ICANN accredited registrar that operates<br>
> under a common controlling interest (2009 Registrar Accreditation Agreement,<br>
> Section 1.20)<br>
>><br>
>> - Affiliate retail proxy service provider - entity operating under a<br>
> common controlling interest of a registrar.<br>
>><br>
>> - Retail proxy service provider - proxy service with little or no<br>
> knowledge of the entity or individual requesting the service beyond their<br>
> ability to pay and their agreement to the general terms and conditions.<br>
>><br>
>> - Limited proxy service provider - proxy service for an entity or<br>
> individual in which there is an ongoing business relationship bound by a<br>
> contract that is specific to the relationship.<br>
>><br>
>><br>
>> --- end<br>
>> same text attached<br>
>> Kathy<br>
>><br>
>><br>
>> --<br>
>><br>
>><br>
>><br>
>><br>
>><br>
>><br>
>><br>
>> --<br>
>><br>
>><br>
>><br>
>><br>
>><br>
>> _______________________________________________<br>
>> Rt4-whois mailing list<br>
>><br>
> <a href="mailto:Rt4-whois@icann.org">Rt4-whois@icann.org</a><mailto:<a href="mailto:Rt4-whois@icann.org">Rt4-whois@icann.org</a>><mailto:<a href="mailto:Rt4-whois@icann.org">Rt4-whois@icann.org</a>><br>
>> <a href="https://mm.icann.org/mailman/listinfo/rt4-whois" target="_blank">https://mm.icann.org/mailman/listinfo/rt4-whois</a><br>
>><br>
><br>
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