[Gnso-epdp-team] Recommendation on Web Forms

Tue May 25 17:22:06 UTC 2021

Hi Alan,

you are correct: This should be addressed as part of the P1 IRT, not this
group.  We cannot willy-nilly expand the scope of a PDP. Or should we ask
to include some transfer issues relating to registration data next? Or
change the ICANN bylaws?
-- 
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 Tue, May 25, 2021 at 6:45 PM Alan Greenberg <alan.greenberg at mcgill.ca>
wrote:

> Volker et al,
>
> The Chair suggested that this issue should be addressed, but by the Phase
> 1 IRT.  I believe that he was correct in that the issue does need to be
> addressed but do not believe that is a real possibility, since the Phase 1
> policy did not imply and web form content requirements.
>
> So that leaves us with needing to take some other action to remedy the
> Phase 1 recommendation that is not working.
>
> Unless you are recommending starting a new PDP just to address this issue,
> this is a way to finesse it. We include it in our report and solicit input.
> And of course discuss it following the comment period.
>
> If indeed the instructions from the GNSO Council need to be changed (which
> I do not believe), that could happen after the public comment period.
>
> This Phase 2a DOES have the mandate to require some form of email address
> be used. So we ARE discussing a change to Recommendation 13. If we choose
> NOT to do that, we need to make sure the remaining policy is viable. So I
> believe this recommendation is indeed in scope!
>
> Alan
>
> At 2021-05-25 12:30 PM, Volker Greimann wrote:
>
> Hi Laureen,
>
> yes, we did discuss it and always returned to the point that it was out of
> scope for our group. While I understand the desire to have something on
> webforms included, discussion was rather one-sided due to the scope. I
> understand from other registrars that there are many issues with input
> fields as part of the webforms and they have chosen the format of their
> forms for a reason.
>
> 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
>
> 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
> recipient, any use, copying, transmission, distribution, or other forms of
> dissemination is strictly prohibited. If you have received this email in
> error, please notify the sender immediately and permanently delete this
> email with any files that may be attached.
>
>
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> On Tue, May 25, 2021 at 6:17 PM Kapin, Laureen <LKAPIN at ftc.gov> wrote:
>
> 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
>
> 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
> recipient, any use, copying, transmission, distribution, or other forms of
> dissemination is strictly prohibited. If you have received this email in
> error, please notify the sender immediately and permanently delete this
> email with any files that may be attached.
>
>
>
>
>
>
> <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> Virus-free.
> www.avast.com
> <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>
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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 > 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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