[Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Carlton Samuels
carlton.samuels at gmail.com
Tue Aug 7 16:10:58 UTC 2018
Seems to me this is a simple case of caveat emptor! The P/P provider
covenants that it has sold a service for which it is fully qualified to
sell and provide, so far as that is required.
The P/P customer accepts and covenants it has acquired the service in good
faith and credit.
P/P is not a baseline requirement pertaining stability and security of the
DNS but an add-on choice. If the P/P provider turns out to be a scofflaw
then the most that should happen is to *take due care* the P/P customer be
given *due notice* that they bought a bill of goods and what is coming at
them. And if they still need the conservation the service offers then they
ought to go find another P/P service provider in good standing.
-Carlton
==============================
*Carlton A Samuels*
*Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround*
=============================
On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins <amy.bivins at icann.org> wrote:
> Thanks, Sara and Theo for your feedback on this.
>
> I'm working on some proposed edits to this document based on your
> feedback--once I can discuss with Legal I'll have an updated draft for you.
> I hope to be able to send a draft to the list next week.
>
> To start, we're planning to change the word "transfer" to "transition" and
> to explicitly require coordination with the registrar as a necessary step
> for a bulk transition. We're also taking another look at notice
> requirements where a registrar is not involved in the facilitation of a
> bulk transfer, in which case a customer might need to transfer out if the
> customer wishes to transition to a new PP service provider.
>
> Theo, regarding your comments on the fees proposal, the activities listed
> as contributors to ongoing expected program costs (one of the 3 elements
> that fed into the proposed fees determination) were not itemized the way
> they were for the application phase (this would require a broader analysis).
>
> Thanks, all, and have a great weekend.
>
> Amy
>
>
>
> -----Original Message-----
> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces at icann.org]
> On Behalf Of Sara Bockey
> Sent: Tuesday, July 31, 2018 8:31 AM
> To: gdd-gnso-ppsai-impl at icann.org
> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation
> Procedure Document Attached for IRT review
>
> Again. Agree with Theo. Use of the word “transfer” is confusing and
> problematic. We need to be able to reassign the service, contract with a
> new provider. Actual transfers would seem to be a dead last option. We
> don’t want to penalize the customer just because the P/P service changes.
>
> Sara
>
> Sent from my iPhone. Apologies for typos and/or brevity.
>
> > On Jul 31, 2018, at 1:39 AM, gtheo <gtheo at xs4all.nl> wrote:
> >
> > I think the word transfer is somewhat confusing or does not meet the
> objective or can cause results that are not wanted.
> >
> > I can imagine a reseller using privacy provider X.
> > Privacy Provider X merges or hands over the business to Privacy Provider
> ABC.
> >
> > The most logical path is that the reseller updates the domain names to
> the details of Privacy Provider ABC.
> >
> > Transfering the domain names in bulk or through an inter-registrar
> transfer to the registrar of privacy provider ABC could be not wanted for
> various reasons.
> > Reseller has to implement a new API with the new registrar.
> > Billing issues.
> > The new registrar may lack features key critical to the reseller at the
> current registrar.
> > Etc the list is long.
> >
> > A bulk transfer at a registry level, poorly communicated could create
> chaos.
> >
> > Regarding the fees. The fee document seems to have two major components.
> > Program Startup and Application Processing Here are all the costs
> > listed.
> >
> > Then there is the; Ongoing Accreditation Program Maintenance Here are
> > no fees listed.
> > Are the fees of the ongoing program maintenance listed in the program
> startup and application processing?
> >
> > For example, Complaint processing is listed as ongoing. What are those
> costs? Or can I simply exclude them as those costs are not taken into
> account? How does that work?
> > I think it is relevant as I expect complaint processing cannot be
> compared to the current situation in case of a registrar.
> >
> > Thanks!
> > Theo
> >
> >
> > Sara Bockey schreef op 2018-07-30 10:31 PM:
> >> Apologies for weighing in late here, but I agree with Theo. I'm not
> >> understanding why the registrar would need to change per se. I also
> >> can imagine a scenario where a privacy provider (or registrar)
> >> reaches an agreement with another privacy provider to provide
> >> privacy. In fact, I think this would be the most likely option we
> >> would want - allow the registrar to contract with a new provider.
> >> Sara
> >> sara bockey
> >> sr. policy manager | GoDaddy™
> >> sbockey at godaddy.com 480-366-3616
> >> skype: sbockey
> >> This email message and any attachments hereto is intended for use
> >> only by the addressee(s) named herein and may contain confidential
> >> information. If you have received this email in error, please
> >> immediately notify the sender and permanently delete the original and
> >> any copy of this message and its attachments.
> >> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts"
> >> <gdd-gnso-ppsai-impl-bounces at icann.org on behalf of gtheo at xs4all.nl>
> >> wrote:
> >> Hi Amy,
> >> If it is supposed to address both situations, isn't it somewhat odd a
> >> privacy provider can order a bulk transfer to another privacy
> provider
> >> at another registrar?
> >> I can imagine a scenario where a privacy provider reaches an
> agreement
> >> with another privacy provider to update all the domain names to one
> >> privacy provider. But to transfer domain names in bulk in the above
> >> scenario, does that benefit the registrant? I think it could create
> >> total chaos and disruption of services. Or is the above scenario
> >> unthinkable and am I chasing ghosts here?
> >> Thanks,
> >> Theo
> >> On 26-7-2018 15:03, Amy Bivins wrote:
> >> > Hi Theo,
> >> >
> >> > Thanks for your feedback.
> >> >
> >> > This was drafted to try to accommodate both types of situations,
> >> though, practically speaking, it seems probable that in most cases
> >> this would often involve an inter-registrar transfer.
> >> >
> >> > There's nothing explicit in the document that would require
> >> obtaining consent from the registrar to a provider-provider bulk
> >> transfer under the same registrar. Do you (and others) think this
> >> should be an explicit requirement?
> >> >
> >> > Best,
> >> > Amy
> >> >
> >> > -----Original Message-----
> >> > From: gtheo [mailto:gtheo at xs4all.nl]
> >> > Sent: Thursday, July 26, 2018 4:54 AM
> >> > To: gdd-gnso-ppsai-impl at icann.org
> >> > Cc: Amy Bivins <amy.bivins at icann.org>
> >> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP
> >> De-Accreditation Procedure Document Attached for IRT review
> >> >
> >> > Hi Any, et al,
> >> >
> >> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from
> >> one privacy provider to another, or can a privacy provider request a
> >> transfer of all the domain names that are being used by a privacy
> >> provider at a registrar to another privacy provider at another
> >> registrar?
> >> > I am somewhat struggling here with what we want to achieve and
> >> what a privacy provider can do here.
> >> >
> >> > I think in all cases when a privacy provider requests a bulk
> >> transfer the sponsoring registrar has to agree also?
> >> >
> >> > Thanks,
> >> >
> >> > Theo
> >> >
> >> >
> >> >
> >> > Amy Bivins schreef op 2018-07-25 03:37 PM:
> >> >> Dear Colleagues,
> >> >>
> >> >> Attached you will find a new draft of the PP De-accreditation and
> >> >> transition procedure, updated based on IRT feedback and our final
> >> >> (prior to public comment) internal review. If you have any further
> >> >> questions or comments on this document, please send them to the
> list.
> >> >>
> >> >> We're nearly finished with the final editing/review process for
> the
> >> >> applicant guide and fees document, as well (there will be copy
> edits
> >> >> but no significant substantive changes). I'll send those to the
> list
> >> >> as soon as they are complete, likely before the end of this week.
> >> >>
> >> >> Best,
> >> >>
> >> >> Amy
> >> >>
> >> >> AMY E. BIVINS
> >> >>
> >> >> Registrar Services and Engagement Senior Manager
> >> >>
> >> >> Registrar Services and Industry Relations
> >> >>
> >> >> Internet Corporation for Assigned Names and Numbers (ICANN)
> >> >>
> >> >> Direct: +1 (202) 249-7551
> >> >>
> >> >> Fax: +1 (202) 789-0104
> >> >>
> >> >> Email: amy.bivins at icann.org
> >> >>
> >> >> www.icann.org [1]
> >> >>
> >> >>
> >> >>
> >> >> Links:
> >> >> ------
> >> >> [1]
> >> >>
> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
> >> >>
> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
> >> >>
> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
> >> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e=
> >> >> _______________________________________________
> >> >> Gdd-gnso-ppsai-impl mailing list
> >> >> Gdd-gnso-ppsai-impl at icann.org
> >> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
> >> _______________________________________________
> >> Gdd-gnso-ppsai-impl mailing list
> >> Gdd-gnso-ppsai-impl at icann.org
> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
> >> _______________________________________________
> >> Gdd-gnso-ppsai-impl mailing list
> >> Gdd-gnso-ppsai-impl at icann.org
> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
> > _______________________________________________
> > Gdd-gnso-ppsai-impl mailing list
> > Gdd-gnso-ppsai-impl at icann.org
> > https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
> _______________________________________________
> Gdd-gnso-ppsai-impl mailing list
> Gdd-gnso-ppsai-impl at icann.org
> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
> _______________________________________________
> Gdd-gnso-ppsai-impl mailing list
> Gdd-gnso-ppsai-impl at icann.org
> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/gdd-gnso-ppsai-impl/attachments/20180807/86b51213/attachment-0001.html>
More information about the Gdd-gnso-ppsai-impl
mailing list