[Gnso-epdp-team] Contact Relays

Sarah Wyld swyld at tucows.com
Mon Jan 18 13:38:47 UTC 2021


Hello all,

This goes back to the question of what exactly is in scope for this phase 2a, and what problem we’re trying to solve.

We already have Recommendation #13 from Phase 1 stating that (among other things) “the Registrar MUST provide an email address or a web form to facilitate email communication with the relevant contact,” so the requirement to provide a contact method, which may be an email address, has already been decided. 

Specifics related to the web form around things like character limits and CAPTCHA are not in scope for 2a as they are unrelated to our instructions, as James pointed out. 

Our duty here is not to determine if a relay email is required, or under what circumstances. Instead, we’re here to review the legal guidance and any specific proposals which offer methods to implement that email while addressing the issues raised in that guidance and of course adhering to relevant data protection obligations. 

Is it feasible for unique contacts to have a uniform anonymized email address? If so, should that be required when implementing an email address contact relay? That’s what we’re doing here, and we shouldn’t mix that up with questions around if a relay email is itself required or not, which are already determined. 

-- 
Sarah Wyld, CIPP/E

Policy & Privacy Manager
Tucows
swyld at tucows.com 
+1.416 535 0123 Ext. 1392



From: Volker Greimann
Sent: January 18, 2021 8:21 AM
To: King, Brian
Cc: gnso-epdp-team at icann.org
Subject: Re: [Gnso-epdp-team] Contact Relays

I think the main issue is not whether it is desirable, but whether it is feasible at all, in a way that _fully safeguards_ all affected parties.

-- 
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

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.

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On Sun, Jan 17, 2021 at 11:28 PM King, Brian via Gnso-epdp-team <gnso-epdp-team at icann.org> wrote:
Hi James,
 
I’d like to understand your request a bit better. 
 
For many IP purposes, having a reliable email address is necessary to facilitate communication with the RNH, especially since web forms have proven insufficient for many of us. To the IP folks, contactability is an important reason for our work on “the feasibility of requiring unique contacts to have a uniform anonymized email address” (Temp Spec, emphasis added). I was concerned (or hopefully confused) to hear the RrSG assert that email contact was not necessary for IP purposes – I’d think we could either take the IPC’s word on that, or attempt to understand each other better. 
 
If we agree that some form of email address is needed, or that we need to understand each other better, let’s proceed accordingly. If not, I’d ask candidly whether we should expect the RrSG to join consensus on a (lawful) requirement to provide an email contact, if the RrSG position is that email is not necessary and the RrSG is unwilling to discuss it further. 
 
Brian J. King​
He/Him/His
Head of Policy and Advocacy, Intellectual Property Group

T +1 443 761 3726​
clarivate.com​
Accelerating innovation
 
From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> On Behalf Of James M. Bladel
Sent: Sunday, January 17, 2021 3:32 PM
To: gnso-epdp-team at icann.org
Subject: [Gnso-epdp-team] Contact Relays
 
Hi folks –
 
On last Thursday’s call, we spent a chunk of time discussing the merits/efficacy of various Registrar implementations of the Contact Relay requirement. 
 
In my view, this is one of htose topics that our group can’t resist debating, and yet it is not within scope for our work in Phase 2A.  Our calendar is extremely tight, and I would ask everyone (myself included) to try and avoid these “catnip” topics that burn a lot of call time, but ultimately don’t end up anywhere.

Thanks—

J.
 
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