[Gnso-epdp-team] Recommendation on Web Forms

Alan Greenberg alan.greenberg at mcgill.ca
Tue May 25 17:55:13 UTC 2021


Volker, if you and the other registrars agree to be bound by 
contractual limitations of what a web form should contain as set by 
the Phase 1 IRT (presuming it agrees to take this on), I would 
consider it. I have not heard such agreements.

Phase 2a is discussing email contact to registrants. That is Phase 1 
Recommendation 13. This is not expanding the scope of this PDP phase.

Alan


At 2021-05-25 01:22 PM, Volker Greimann wrote:
>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: <http://www.key-systems.net/>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.
>
>
>Virus-free. 
><https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>www.avast.com 
>
>
>On Tue, May 25, 2021 at 6:45 PM Alan Greenberg 
><<mailto:alan.greenberg at mcgill.ca>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: <http://www.key-systems.net/>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.
>>
>>
>>Virus-free. 
>><https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>www.avast.com 
>>
>>
>>On Tue, May 25, 2021 at 6:17 PM Kapin, Laureen 
>><<mailto:LKAPIN at ftc.gov>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 <<mailto:gnso-epdp-team-bounces at icann.org> 
>>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 
>><<mailto:alan.greenberg at mcgill.ca>alan.greenberg at mcgill.ca >
>>Cc: EPDP <<mailto:gnso-epdp-team at icann.org>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: <http://www.key-systems.net/>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. 
>><https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail>www.avast.com 
>>
>>
>>On Tue, May 25, 2021 at 2:45 AM Alan Greenberg via Gnso-epdp-team 
>><<mailto:gnso-epdp-team at icann.org>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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