[CCWG-ACCT] [community-finance] IANA Stewardship Transition - Project Expenses - FY16 Q3 update

Fri Jul 22 20:06:42 UTC 2016

This is very useful discussion particularly on this very list. Any idea, how are the consultants/contractors hired by ICANN?. If this is through an RFP/competitive bid thn may be the RFP will have the detail/requirement what is required which in other words will mean what the consultants do. Not?

Zakir  

      From: Marilyn Cade <marilynscade at hotmail.com>
 To: Sam Lanfranco <sam at lanfranco.net>; Phil Corwin <psc at vlaw-dc.com>; Ken Stubbs <kstubbs at afilias.info>; Paul Rosenzweig <paul.rosenzweig at redbranchconsulting.com>; "'Schaefer, Brett'" <brett.schaefer at heritage.org>; 'Xavier J. Calvez' <xavier.calvez at icann.org> 
Cc: "cwg-stewardship at icann.org" <cwg-stewardship at icann.org>; 'CCWG-Accountability' <accountability-cross-community at icann.org>; "icann-board at icann.org" <icann-board at icann.org>; 'Executive Team' <executive-team at icann.org>; 'COMMS Team' <commsteam at icann.org>; "community-finance at icann.org" <community-finance at icann.org>; 'Finance Staff' <finance-staff at icann.org>
 Sent: Thursday, July 21, 2016 2:27 AM
 Subject: Re: [CCWG-ACCT] [community-finance] IANA Stewardship Transition - Project Expenses - FY16 Q3 update

I'd like to stick to the topic we are discussing which is disclosure about 'advisors', and lobbyists, and not venture until the gTLDs contracts.  I fear that would become a bog that is too unbounded, with some questioning the marketing plans of different gTLDs, like give aways, etc. 
So, I ask that as this is the CCWG-ACCT, and the topic is about the amounts paid for consultants specifically working on the IANA transition  -- and who they are -- and that they have only ICANN as a client, not also members of ICANN's community on directly related subjects -- we stick to that discussion. 
All law firms in the US 'clear' conflicts before accepting a new client, and all corporations 'clear' their consultants. While this may be confidential in both these cases, I do agree that a public interest NGO, which is what ICANN is, can best serve itself, and the interest of the broader ICANN community by as much transparency as possible. BUT let's keep it high level and civil in our request for facts and figures. 
As I like to say: Facts are our friends.
Of course, some issues have to be kept confidential. 
Who the consultants are has been published, what they were  paid would add to the transparency.  What they do, at a high level, should be published as well. I will say again that I think that the work is probably much needed. I spend a lot of time -- without being paid -- explaining ICANN as I do my other IG work and it is is a worthwhile task and an important one if we are to demystify ICANN to RoW [Rest of World].  
I am sure it is all above board, but it has now taken on a sort of taint of 'why not tell'.
Let's keep this high level and not make it a hunt for the details, but just get the high level facts, and make that a standard.
Will help us all. 
M
Subject: Re: [CCWG-ACCT] [community-finance] IANA Stewardship Transition - Project Expenses - FY16 Q3 update
To: psc at vlaw-dc.com; kstubbs at afilias.info; paul.rosenzweig at redbranchconsulting.com; marilynscade at hotmail.com; brett.schaefer at heritage.org; xavier.calvez at icann.org
CC: cwg-stewardship at icann.org; accountability-cross-community at icann.org; icann-board at icann.org; executive-team at icann.org; commsteam at icann.org; community-finance at icann.org; finance-staff at icann.org
From: sam at lanfranco.net
Date: Wed, 20 Jul 2016 12:23:12 -0400

 As the non-lawyer economist here I would like to observe that the discussion has honed in on a specific enough question, one that has an ICANN definitive answer, and that it should be put both to the Board and the new CEO for a an answer and clarification. I previously worried that the ICANN DNS contract with .sucks seemed to verge on ICANN exposing itself to the RICO act in the U.S., given the .sucks marketing plan. Maybe I am overly cautious but as a not-for-profit corporation operating in the public interest ICANN is more than obliged to provide clarity here. Silence won't do. 

 Sam Lanfranco, NPOC/CSIH

 On 7/20/2016 12:06 PM, Phil Corwin wrote:

If the contract non-disclosure clause indeed violates IRS disclosure requirements then how could ICANN legal agree to it?    Philip S. Corwin, Founding Principal Virtualaw LLC 1155 F Street, NW Suite 1050 Washington, DC 20004 202-559-8597/Direct 202-559-8750/Fax 202-255-6172/Cell   Twitter: @VlawDC   "Luck is the residue of design" -- Branch Rickey      From: Ken Stubbs [mailto:kstubbs at afilias.info] 
 Sent: Wednesday, July 20, 2016 11:37 AM
 To: Paul Rosenzweig; 'Marilyn Cade'; Phil Corwin; 'Schaefer, Brett'; 'Xavier J. Calvez'
 Cc: cwg-stewardship at icann.org; 'CCWG-Accountability'; icann-board at icann.org; 'Executive Team'; 'COMMS Team'; community-finance at icann.org; 'Finance Staff'
 Subject: Re: [community-finance] [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update     I believe Lori is correct here. IRS requirements on disclosures are
 usually quite specific here

 Ken Stubbs  On 7/20/16 10:32, Lori Schulman wrote:  
 I don’t believe that 501©3 orgs can consider any consulting fees confidential as the top fees are required to be reported on the 990.   Lori    Lori S. Schulman Senior Director, Internet Policy International Trademark Association (INTA) +1-202-704-0408, Skype: lsschulman      From: accountability-cross-community-bounces at icann.org [mailto:accountability-cross-community-bounces at icann.org] On Behalf Of Paul Rosenzweig
 Sent: Wednesday, July 20, 2016 10:16 AM
 To: 'Marilyn Cade' <marilynscade at hotmail.com>; 'Phil Corwin' <psc at vlaw-dc.com>; 'Schaefer, Brett'  <brett.schaefer at heritage.org>; 'Xavier J. Calvez'  <xavier.calvez at icann.org>
 Cc: cwg-stewardship at icann.org; 'CCWG-Accountability' <accountability-cross-community at icann.org>; icann-board at icann.org; 'Executive Team' <executive-team at icann.org>; 'COMMS Team' <commsteam at icann.org>;  community-finance at icann.org; 'Finance Staff'  <finance-staff at icann.org>
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update     I agree completely with Marilyn and Phil.  I have been on both sides of non-disclosure agreements – both ones requested by me and ones requested by my clients.  Typically, a client (in the position of ICANN) may request that a consultant sign an NDA so as to protect the confidentiality of its efforts or its intellectual property.  Sometimes a consultant might have a proprietary methodology or process that they are using on behalf of the client that they wish to protect.     Neither circumstance applies here that I can see.  And in no case that I am aware of has a client ever asked me to keep confidential my fee …  I don’t broadcast them, but I’m in the private sector.  For ICANN, which is an NGO acting in the global public interest, I cannot see any reason at all why ICANN would want or agree to a confidentiality  arrangement as to the size of the fee paid.   Xavier – can you tell us what the rationale is?  I may be missing something  …..   Thanks Paul    Paul Rosenzweig paul.rosenzweig at redbranchconsulting.com O: +1 (202) 547-0660 M: +1 (202) 329-9650 VOIP: +1 (202) 738-1739 www.redbranchconsulting.com My PGP Key: http://redbranchconsulting.com/who-we-are/public-pgp-key/       From: accountability-cross-community-bounces at icann.org [mailto:accountability-cross-community-bounces at icann.org] On Behalf Of Marilyn Cade
 Sent: Wednesday, July 20, 2016 9:05 AM
 To: Phil Corwin <psc at vlaw-dc.com>; Schaefer, Brett <brett.schaefer at heritage.org>; Xavier J. Calvez <xavier.calvez at icann.org>
 Cc: cwg-stewardship at icann.org; CCWG-Accountability <accountability-cross-community at icann.org>; icann-board at icann.org; Executive Team <executive-team at icann.org>; COMMS Team <commsteam at icann.org>; community-finance at icann.org; Finance Staff <finance-staff at icann.org>
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update      I support Phil's clarifying explanation.      I also think that anyone who is in this category, should have to declare if they re also representing  companies in a SO/AC.       Or advising governments.        In the BC, we do not allow an ICANN consultant to be a BC member, regardless of the amount, but if someone is a backdoor advisor to ICANN and also a group of entities, in a SO/AC, that would not be so obvious, but I think that for integrity sake, of course, any  such entity would recuse themselves from advising companies, while also advising ICANN.        And I would expect ICANN to disqualify such entities as their consultants.        Thanks, Phil, for this useful clarification.       M             From: psc at vlaw-dc.com
 To: Brett.Schaefer at heritage.org; xavier.calvez at icann.org
 Date: Wed, 20 Jul 2016 00:48:08 +0000
 CC: cwg-stewardship at icann.org;  accountability-cross-community at icann.org;  icann-board at icann.org; executive-team at icann.org; commsteam at icann.org;  community-finance at icann.org; finance-staff at icann.org
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update  In the U.S. much of what used to be done by registered lobbyists is now performed by “strategic advisors” who walk right up to the line of what constitutes lobbying (and maybe a few inches over), and nonetheless facilitate door opening to key members of Congress and the Executive branch, and who “educate” rather than “lobby” members of both branches of government. So while the seven firms may not be engaged in what is considered lobbying under current U.S. law, they are still likely engaged in helping to assure officials outcomes desired by ICANN corporate.   It is for that reason – as well as for the exercise of effective oversight over ICANN budgeting and expenditures – that the community should have more data on this. If ICANN is prohibited by its contracts with these firms from disclosing its  expenditures that is unfortunate – and in the future I would hope that ICANN would tell any firms being considered for such duties that its own transparency obligations to the community preclude it from agreeing to such restrictions (I’d wager that the majority of the firms would waive confidentiality rather than lose the contract).    At a minimum, ICANN should disclose the aggregate amounts spent with these seven firms since they were engaged – surely their contracts don’t bar such aggregate reporting.    Philip S. Corwin, Founding Principal Virtualaw LLC 1155 F Street, NW Suite 1050 Washington, DC 20004 202-559-8597/Direct 202-559-8750/Fax 202-255-6172/Cell   Twitter: @VlawDC   "Luck is the residue of design" -- Branch Rickey      From: accountability-cross-community-bounces at icann.org [mailto:accountability-cross-community-bounces at icann.org] On Behalf Of Schaefer, Brett
 Sent: Tuesday, July 19, 2016 1:04 PM
 To: Xavier J. Calvez
 Cc: cwg-stewardship at icann.org; CCWG-Accountability; icann-board at icann.org; Executive Team; COMMS Team; community-finance at icann.org; Finance Staff
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update     Xavier,   Are you saying that ICANN’s contracts for Education/Engagement/Advice with (1) Albright Stonebridge Group LLC, (2) Edelman, (3) Interface Media, (4) Rice Hadley Gates LLC, (5) Summit Strategies International LLC, (6) WBC Global, and  (7) Wiley Rein LLP each contain confidentiality provisions that prohibit ICANN from disclosing the specific amount paid to each of these individual vendors?    Does this only apply to the CCWG and the public or does it also apply to other parts of the ICANN community, specifically the Supporting Organizations and Advisory Committees?   Thank you for the link on lobbying disclosures. For those who are interested, here are ICANN’s lobbying expenditures based on the disclosure website of the U.S. Congress.       I do have a couple of additional questions. Would this source capture lobbying exclusively directed toward the US Executive Branch? Has ICANN spent any funds during this period lobbying governments other than the US?    Thank you,   Brett             Brett Schaefer
 Jay Kingham Senior Research Fellow in International Regulatory Affairs
 Margaret Thatcher Center for Freedom Davis Institute for National Security and Foreign Policy
 The Heritage Foundation
 214 Massachusetts Avenue, NE
 Washington, DC 20002
 202-608-6097
 heritage.org   From: Xavier J. Calvez [mailto:xavier.calvez at icann.org] 
 Sent: Monday, July 18, 2016 6:30 PM
 To: Schaefer, Brett
 Cc: community-finance at icann.org; cwg-stewardship at icann.org; CCWG-Accountability; Executive Team; COMMS Team; icann-board at icann.org; Finance Staff
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update     Brett, Yes, the information I provided in my latest email had been included in some previous communication. I just wanted to make sure you had a clear visibility on this information, which provides for (i) categories of expenses, (ii) the individual names  of the vendors grouped for each category, and (iii) the total value of the expenses for each category. With respect to the contractual obligations of confidentiality in commercial contracts, ICANN is subject to them, like all business organizations. That said, we disclose what we can consistent with standard business confidentiality provisions in  vendor contracts. We cannot disclose the specific amount of spend with each vendor but we were able to disclose the names of the service providers engaged. Regarding the lobbying expenses, as you are aware, both organizations that hire lobbyists and firms that lobby on behalf of organizations are required under U.S. federal law to file lobbying disclosure reports. In addition to ICANN’s quarterly lobbying disclosures posted on our website, you can find the amounts ICANN has paid to individual outside lobbying firms at http://disclosures.house.gov/ld/ldsearch.aspx. I hope this helps and clarifies.      Thank you.       Best,   Xavier       Xavier Calvez   ICANN   CFO   12025 Waterfront Drive, Suite 300   Los Angeles, CA 90094   Office     : +1 (310) 301 5838   Mobile   : +1 (805) 312 0052   Fax                          : +1 (310) 957-2348         From:  "Schaefer, Brett" <Brett.Schaefer at heritage.org>
 Date: Thursday, July 14, 2016 at 7:07 AM
 To: Xavier Calvez <xavier.calvez at icann.org>
 Cc: "community-finance at icann.org" <community-finance at icann.org>, "cwg-stewardship at icann.org" <cwg-stewardship at icann.org>, CCWG-Accountability <accountability-cross-community at icann.org>, Executive Team <executive-team at icann.org>, COMMS Team <commsteam at icann.org>, "icann-board at icann.org" <icann-board at icann.org>, Finance Staff <finance-staff at icann.org>
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update          Xavier,       This is pretty much the same information that was provided before. I am asking for a breakdown of how much was paid to each vender in the lobbying category (Akin Gump, etc.) and the  education/engagement/advice category (Albright Stoneridge, etc.).        Thank you,        Brett    
 On Jul 13, 2016, at 8:13 PM, Xavier J. Calvez <xavier.calvez at icann.org> wrote:  
  Dear Brett, 
In response to your question listed below on 22 June: the detailed information provided on Other professional fees (other than legal fees, detailed in a separate section of the “Transition project cost” expense webpage, on the IANA Stewardship Transition webpage) can be found in the section called “Professional Services – Expenses Breakdown”. Within this section, you will find a link to a document that provides the list of Professional Services (other than legal fees) incurred, by category, with the names of the vendors, and the total amount  of expenditures for the category.

This link is copied below and was provided in my first answer to your question. I have also attached the file to which this link refers in case the link would not work for you.

https://www.icann.org/en/system/files/files/iana-stewardship-expenses-professional-vendor-01jun16-en.pdf
 If this not addressing your question, please let me know.      Thank you.       Best,   Xavier       Xavier Calvez   ICANN   CFO   12025 Waterfront Drive, Suite 300   Los Angeles, CA 90094   Office     : +1 (310) 301 5838   Mobile   : +1 (805) 312 0052   Fax                          : +1 (310) 957-2348         
              Brett Schaefer
 Jay Kingham Senior Research Fellow in International Regulatory Affairs
 Margaret Thatcher Center for Freedom Davis Institute for National Security and Foreign Policy
 The Heritage Foundation
 214 Massachusetts Avenue, NE
 Washington, DC 20002
 202-608-6097
 heritage.org 
   From:  Xavier Calvez <xavier.calvez at icann.org>
 Date: Tuesday, July 12, 2016 at 9:45 AM
 To: "Schaefer, Brett" <Brett.Schaefer at heritage.org>, "community-finance at icann.org" <community-finance at icann.org>, "cwg-stewardship at icann.org" <cwg-stewardship at icann.org>, CCWG-Accountability <accountability-cross-community at icann.org>
 Cc: Executive Team <executive-team at icann.org>, COMMS Team <commsteam at icann.org>, "icann-board at icann.org" <icann-board at icann.org>, Finance Staff <finance-staff at icann.org>
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update        Brett, Thank you for following up. I will make sure to respond no later than the end of this week.      Thank you.       Best,   Xavier       Xavier Calvez   ICANN   CFO   12025 Waterfront Drive, Suite 300   Los Angeles, CA 90094   Office     : +1 (310) 301 5838   Mobile   : +1 (805) 312 0052   Fax                          : +1 (310) 957-2348         From:  "Schaefer, Brett" <Brett.Schaefer at heritage.org>
 Date: Tuesday, July 12, 2016 at 11:38 AM
 To: Xavier Calvez <xavier.calvez at icann.org>, "community-finance at icann.org" <community-finance at icann.org>, "cwg-stewardship at icann.org" <cwg-stewardship at icann.org>, CCWG-Accountability <accountability-cross-community at icann.org>
 Cc: Executive Team <executive-team at icann.org>, COMMS Team <commsteam at icann.org>, "icann-board at icann.org" <icann-board at icann.org>, Finance Staff <finance-staff at icann.org>
 Subject: RE: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3 update        Xavier,   Thanks for promising to get this information to me in Helsinki. Do  you have an estimate for when it will be provided?    Thanks, 
 Brett                     Brett Schaefer
 Jay Kingham Senior Research Fellow in International Regulatory Affairs
 Margaret Thatcher Center for Freedom Davis Institute for National Security and Foreign Policy
 The Heritage Foundation
 214 Massachusetts Avenue, NE
 Washington, DC 20002
 202-608-6097
 heritage.org   From: Schaefer, Brett 
 Sent: Wednesday, June 22, 2016 2:39 PM
 To: 'Xavier J. Calvez'; community-finance at icann.org; cwg-stewardship at icann.org; CCWG-Accountability
 Cc: Executive Team; COMMS Team; icann-board at icann.org; Finance Staff
 Subject: RE: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses  - FY16 Q3 update     Xavier,   I appreciate the detailed breakdown on the legal fees That is indeed  what I was looking for though I would think it useful to have the totals provided in the summary  document.    However, I did not see similar information for lobbying or education/  engagement/advice in the links provided. In fact, the only specific information that I saw  listed is for Jamie Hedlund at $200,000. No information on other individual firms or vendors is listed at all – only the top line budget expenditure in the summary  document link originally sent around.    Could you provide that information?    Thanks,   Brett      From: Xavier J. Calvez [mailto:xavier.calvez at icann.org] 
 Sent: Wednesday, June 22, 2016 10:43 AM
 To: Schaefer, Brett; community-finance at icann.org; cwg-stewardship at icann.org; CCWG-Accountability
 Cc: Executive Team; COMMS Team; icann-board at icann.org; Finance Staff
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses  - FY16 Q3 update     Dear all, It appears that the first link in my email further below (detail of  legal fees by firm) does not resolve correctly. Please use the below instead. https://www.icann.org/en/system/files/files/iana-stewardship-expenses-legal-firm-fy16-01jun16-en.pdf        Thank you.       Best,   Xavier       Xavier Calvez   ICANN   CFO   12025 Waterfront Drive, Suite 300   Los Angeles, CA 90094   Office     : +1 (310) 301 5838   Mobile   : +1 (805) 312 0052   Fax                          : +1 (310) 957-2348         From:  Xavier Calvez <xavier.calvez at icann.org>
 Date: Wednesday, June 22, 2016 at 1:01 PM
 To: "Schaefer, Brett" <Brett.Schaefer at heritage.org>, "community-finance at icann.org" <community-finance at icann.org>, "cwg-stewardship at icann.org" <cwg-stewardship at icann.org>, CCWG-Accountability <accountability-cross-community at icann.org>
 Cc: Executive Team <executive-team at icann.org>, COMMS Team <commsteam at icann.org>, "icann-board at icann.org" <icann-board at icann.org>, Finance Staff <finance-staff at icann.org>
 Subject: Re: [CCWG-ACCT] IANA Stewardship Transition - Project Expenses - FY16 Q3  update        Dear Brett, Thank you for your interest and question. We currently publish the list of all vendors from whom ICANN  obtain services in relation to the IANA Stewardship transition. The $$ value of  the services received is aggregated by category of expenses, which you mention below (US Government affairs,Education/engagement/advice,…). This presentation is driven by 2  factors: providing clarity as to the type of services received, and abiding by the contractual obligation of confidentiality in force with  each of the vendors (resulting from standard business sensitive information). We do publish however the detail of the legal advice, by firm  and by working group, on this same page (see for example the link to the report of fees by firm: https://www.icann.org/en/system/files/files/iana-stewardship-expenses-legal-firm-fy16-01jun16-en.pdf). You will also find more information relative to ICANN’s lobbying in the following blog published a few months ago. In this blog, you  will also find links to the disclosure reports that ICANN makes on lobbying activities. https://www.icann.org/resources/pages/lobbying-disclosures-contributions-2015-11-18-en. Lastly, further information on lobbying appears in ICANN’s  form 990 (Schedule C, Part II-B. On page 33/73 of the FY15 form 990 published at the  following link): https://www.icann.org/en/system/files/files/fy-2015-form-990-10may16-en.pdf  I hope this helps. Please let me know if you have further  questions.      Thank you.       Best,   Xavier       Xavier Calvez   ICANN   CFO   12025 Waterfront Drive, Suite 300   Los Angeles, CA 90094   Office     : +1 (310) 301 5838   Mobile   : +1 (805) 312 0052   Fax                          : +1 (310) 957-2348         From:  "Schaefer, Brett" <Brett.Schaefer at heritage.org>
 Date: Tuesday, June 21, 2016 at 9:54 PM
 To: Xavier Calvez <xavier.calvez at icann.org>, "community-finance at icann.org" <community-finance at icann.org>, "cwg-stewardship at icann.org" <cwg-stewardship at icann.org>, CCWG-Accountability <accountability-cross-community at icann.org>
 Cc: Executive Team <executive-team at icann.org>, COMMS Team <commsteam at icann.org>, "icann-board at icann.org" <icann-board at icann.org>, Finance Staff <finance-staff at icann.org>
 Subject: RE: [CCWG-ACCT] IANA Stewardship Transition - Project  Expenses - FY16 Q3 update        Xavier,    Thank you. Could you please provide a more detailed  breakdown of legal advice, US government affairs, andeducations/engagement/advice? In each category, there are multiple  firms/vendors listed (https://www.icann.org/en/system/files/files/iana-stewardship-expenses-professional-vendor-01jun16-en.pdf). I would appreciate the amount provided to each  individual vendor. If it is provided somewhere, I would appreciate you  letting me know where to find it.    Much appreciated,   Brett                             Brett Schaefer
 Jay Kingham Senior Research Fellow in  International Regulatory Affairs
 Margaret Thatcher Center for Freedom Davis  Institute for National Security and Foreign Policy
 The Heritage Foundation
 214 Massachusetts Avenue, NE
 Washington, DC 20002
 202-608-6097
 heritage.org   From: accountability-cross-community-bounces at icann.org [mailto:accountability-cross-community-bounces at icann.org] On Behalf Of Xavier J. Calvez
 Sent: Saturday, June 18, 2016 12:10 AM
 To: community-finance at icann.org; cwg-stewardship at icann.org; CCWG-Accountability
 Cc: Executive Team; COMMS Team; icann-board at icann.org; Finance Staff
 Subject: [CCWG-ACCT] IANA Stewardship Transition  - Project Expenses - FY16 Q3 update     Dear all, You find at the link below the updated project’s expenses  as of FY16 Q3 (from July 2014 to March 2016). As indicated a few months ago, we have added new detailed information on  the staff support with the individual positions, names and percentages of  effort over the period.   https://www.icann.org/resources/pages/iana-stewardship-project-costs       Thank you.       Best,   Xavier       Xavier Calvez   ICANN   CFO   12025 Waterfront Drive, Suite 300   Los Angeles, CA 90094   Office     : +1 (310) 301 5838   Mobile   : +1 (805) 312 0052   Fax          : +1 (310) 957-2348              

  <iana-stewardship-expenses-professional-vendor-01jun16-en.pdf>  

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