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

[DiBiase, Gregory]

Hi Jen,

ICANN's calculations assumed that each accreditation would cost ICANN the same amount of money (i.e., they would be creating the process anew each time).  A more realistic projection would show the cost to set up the system/process, then the minimal cost of processing each application once the system is in place.

Thanks,
Greg

From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Jennifer Gore
Sent: Wednesday, March 28, 2018 8:28 AM
To: 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

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<mailto: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:
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 | GoDaddy(tm)
sbockey at godaddy.com<mailto: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><mailto:gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Michele Neylon <michele at blacknight.com><mailto:michele at blacknight.com>
Reply-To: "gdd-gnso-ppsai-impl at icann.org"<mailto:gdd-gnso-ppsai-impl at icann.org> <gdd-gnso-ppsai-impl at icann.org><mailto:gdd-gnso-ppsai-impl at icann.org>
Date: Wednesday, March 28, 2018 at 6:13 AM
To: "gdd-gnso-ppsai-impl at icann.org"<mailto:gdd-gnso-ppsai-impl at icann.org> <gdd-gnso-ppsai-impl at icann.org><mailto: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/
-------------------------------
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Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces at icann.org><mailto:gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Amy Bivins <amy.bivins at icann.org><mailto:amy.bivins at icann.org>
Reply-To: "gdd-gnso-ppsai-impl at icann.org"<mailto:gdd-gnso-ppsai-impl at icann.org> <gdd-gnso-ppsai-impl at icann.org><mailto:gdd-gnso-ppsai-impl at icann.org>
Date: Wednesday 28 March 2018 at 13:40
To: "gdd-gnso-ppsai-impl at icann.org"<mailto:gdd-gnso-ppsai-impl at icann.org> <gdd-gnso-ppsai-impl at icann.org><mailto: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<mailto:amy.bivins at icann.org>
www.icann.org<http://www.icann.org>





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