[Gnso-epdp-team] Recommendation on Web Forms

[Kapin, Laureen]

To be fair, this issue has been discussed many times during our meetings.  This recommendation merely captures what has already been proposed by certain SGs. Hence I suggest that it be included for the purpose of soliciting public comments.


Laureen Kapin

Acting Assistant Director
Division of Consumer Response and Operations
Bureau of Consumer Protection
Federal Trade Commission

From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> On Behalf Of Volker Greimann via Gnso-epdp-team
Sent: Tuesday, May 25, 2021 11:56 AM
To: Alan Greenberg <alan.greenberg at mcgill.ca>
Cc: EPDP <gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Recommendation on Web Forms

Hi,

I think it is not appropriate to introduce a new recommendation at the last minute that has not been deliberated and seems to me to be out of scope of this WG. While I have no objection to the content of this recommendation, and KS has already implemented its webforms in a similar manner, I think the process concern must prevail here.

Best,

--
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<http://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

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On Tue, May 25, 2021 at 2:45 AM Alan Greenberg via Gnso-epdp-team <gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org>> wrote:
Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report.

Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation.

As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose).

It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules.

Accordingly, the Initial Report must include a new Recommendation:

Recommendation

The Phase 1 Recommendation 13 should be amended to include:  Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant.

Alan & Mark
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