[Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March

Wed Mar 28 15:39:42 UTC 2018

Hi Jenn, 

"Cost recovery" - sorry but this is what we are trying to gather - what costs are ICANN coming up with ? Lets be blunt - how many months have you had this on the table ? 

Clearly Jenn, this is really sounding like : 

1. Lets pick a number - oh for a registrar its 4k a year - lets start there 
2. Lets now *try* and justify it 

Its been in the document for **months**, we have requested those workings for **months** therefore please explain how you came up with 1 above then ? That should be a 5 minute reply :) 

I am open to answers of : 

i) Made it up 
ii) Based it on what we charge a registrar 
iii) Finance worked out the deficiency of the reserve kitty and we thought of the best way of plugging it - this being one of them 

Also as staff in compliance seem not to be expanding, this will be using existing resources, thats great, I like that, so please confirm in balance how much less you will be charging for yearly ICANN fees to registrars ? 
As clearly paying the same team to do the same job that they have already confirmed takes little to no time, means there is a saving somewhere. 

Kind regards, 

Chris 

From: "Jennifer Gore" <jennifer.gore at icann.org> 
To: gdd-gnso-ppsai-impl at icann.org 
Sent: Wednesday, 28 March, 2018 16:28:23 
Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 

Hello All, 

Amy and I are currently working with our finance department to provide a detailed response regarding costs that support the proposed fee structure. Please keep in mind, this is a cost recovery effort. We anticipate the materials to be completed within the coming weeks. In the meantime, thank you in advance for your patience. 

Jennifer 

On Mar 28, 2018, at 10:49 AM, theo geurts < gtheo at xs4all.nl > wrote: 

Indeed 

We need to make sure the real costs are in line with the proposed fees. 
https://domainnamewire.com/2018/03/27/icanns-budget-crunch-how-we-got-here/ 

Theo 

On 28-3-2018 16:03, Sara Bockey wrote: 

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Agree. I have yet to see a real justification for the proposed fees, which as currently stated are unacceptable. 

Sara 

sara bockey 

sr. policy manager | Go Daddy ™ 

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. 

From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Michele Neylon <michele at blacknight.com> 
Reply-To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org> 
Date: Wednesday, March 28, 2018 at 6:13 AM 
To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org> 
Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 

Amy 

During a registrar specific meeting with Compliance in PR we asked specifically about their overall expected spend and the volume of complaints they currently handle related to privacy / proxy. 

Three things came out of this: 

1 – Compliance does not see a large volume of complaints related to privacy / proxy 

2 – Compliance has more staff budgeted for than they currently have 

3 – they have no plans to increase their headcount 

Considering that the bulk of engagement from ICANN staff in relation to proxy / privacy is going to be around contractual enforcement I am really curious to see how ICANN intends to rationalise the proposed fees. 

Regards 

Michele 

-- 

Mr Michele Neylon 

Blacknight Solutions 

Hosting, Colocation & Domains 

https://www.blacknight.com/ 

http://blacknight.blog/ 

Intl. +353 (0) 59 9183072 

Direct Dial: +353 (0)59 9183090 

Personal blog: https://michele.blog/ 

Some thoughts: https://ceo.hosting/ 

------------------------------- 

Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty 

Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 

From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Amy Bivins <amy.bivins at icann.org> 
Reply-To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org> 
Date: Wednesday 28 March 2018 at 13:40 
To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org> 
Subject: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March 

Dear Colleagues, 

This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. 

The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: 

(1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 

2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 

2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 

2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. 

We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. 

(2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1. 

(3) Moving section 6.3 up to the notification section as 4.3.3. 

The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. 

If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. 

Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call. 

The fees information will not be ready for next week, but we will get it to you as soon as possible. 

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 

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