[Gnso-epdp-team] On the proposed guidance

Thu Apr 22 13:23:41 UTC 2021

Brian,

in all openness, the only ones standing in the way of SSAD right now are
IPC, BC and maybe parts of ALAC. Consensus in the meaning of "consensus
policy" does not mean full consensus, it means a qualified majority on the
GNSO policy, and SSAD had and has that.
Ultimately, we will not need your agreement. We may decide to build it this
way to satisfy our legal requirement under NIS2. But now you still have an
opportunity to influence how this is going to look. Wear your registrar hat
for a while and you will see this is the only other way besides the status
quo that has any chance of success.
If you have specific concerns with what I proposed as a way out of this
conundrum, by all means, put them on the table, but if all you are going to
do is total opposition, your points are moot as you are then clearly not
interested in finding a workable solution.

Live a little and say yes to reason...

-- 
Volker A. Greimann
General Counsel and Policy Manager
*KEY-SYSTEMS GMBH*

T: +49 6894 9396901
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On Thu, Apr 22, 2021 at 3:15 PM King, Brian <Brian.King at markmonitor.com>
wrote:

> I like it too (which is why I proposed it in Phase 2).
>
> However, what we developed in Phase 2 is clearly not acceptable to most
> groups, plus, we may never have an SSAD. Historically we’ve been let down
> by ICANN’s inability or unwillingness to implement policies like PPSAI
> which actually have consensus (unlike SSAD) and which have progressed to
> implementation, so I don’t see the IPC agreeing to the dubious proposition
> of SSAD as the solution here.
>
> Furthermore, the European Commission has already advised that mere
> availability of legal entity data in SSAD will not meet the publication
> requirements in NIS2. So let’s stay focused.
>
> *Brian J. King*
> Head of Policy and Advocacy, Intellectual Property Group
>
>
> T +1 443 761 3726
>
> *clarivate.com <http://clarivate.com>*
>
> On Apr 22, 2021, at 8:18 AM, Thomas Rickert via Gnso-epdp-team <
> gnso-epdp-team at icann.org> wrote:
>
>  Let me go on the record that I also like the idea.
>
> I addition to the points mentioned by others, making it a one-stop-shop
> for all data would make it more user friendly, add safeguards against
> undesirable correlation of data and allows for kicking-out bad actors even
> at that level.
>
> Best,
> Thomas
>
> Am 20.04.2021 um 23:49 schrieb Volker Greimann via Gnso-epdp-team <
> gnso-epdp-team at icann.org>:
>
> Hi Milton,
>
> essentially, yes, although it would be non-personal data.
>
> And it takes care of a huge chunk of DNS abuse (the abuse originating from
> the RDS harvesters, that is).
> --
> Volker A. Greimann
> General Counsel and Policy Manager
> *KEY-SYSTEMS GMBH*
>
> T: +49 6894 9396901
> M: +49 6894 9396851
> F: +49 6894 9396851
> W: www.key-systems.net
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.key-2Dsystems.net_&d=DwMFaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=X6pN0o-2i1MmkNU25SuEeN8oV8d98i2CNKj3g-jjirE&s=K7tLs1J7TcFvBLJUXYLBeicrxT4Hve5SygGGTY4GwHU&e=>
>
> Key-Systems GmbH is a company registered at the local court of
> Saarbruecken, Germany with the registration no. HR B 18835
> CEO: Oliver Fries and Robert Birkner
>
> Part of the CentralNic Group PLC (LON: CNIC) a company registered in
> England and Wales with company number 8576358.
>
> This email and any files transmitted are confidential and intended only
> for the person(s) directly addressed. If you are not the intended
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>
> On Tue, Apr 20, 2021 at 8:47 PM Mueller, Milton L via Gnso-epdp-team <
> gnso-epdp-team at icann.org> wrote:
>
>> > Obviously I can’t speak for Volker, but I want to try and respond with
>> why I find Volker’s
>>
>> > proposal intriguing.
>>
>>
>>
>> I too am intrigued by this suggestion. Volker as I understand it proposed
>> that instead of publishing the data as we used to do with “ye olde Whois”
>> (love that term), we would make the data of those who flag themselves as
>> legal persons available automatically to any registered SSAD user who
>> requests it. Other requests would be available based on the review for
>> legitimate purpose as originally envisioned.
>>
>>
>>
>> As Marc suggests, going through SSAD eliminates a lot of abusers/bad
>> actors or at least gives us some recourse against them, but still gives all
>> the legitimate users easy access to data that does not need to be private.
>> I would hope this option would be acceptable to the stakeholders who are
>> arguing for a legal/natural distinction.
>>
>>
>>
>> Dr. Milton L Mueller
>>
>> Georgia Institute of Technology
>>
>> School of Public Policy
>>
>>
>>
>>
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