[Gnso-newgtld-wg] Follow up on Consensus Topic

Aikman-Scalese, Anne AAikman at lrrc.com
Tue Aug 28 19:49:26 UTC 2018


Thanks Jeff.  Discussion is always good.  Perhaps we both agree on the following guideline re determining Consensus levels:

[cid:image005.png at 01D43ECD.8B8C42F0]

Anne E. Aikman-Scalese

Of Counsel

520.629.4428 office


520.879.4725 fax

AAikman at lrrc.com<mailto:AAikman at lrrc.com>

_____________________________

[cid:image001.png at 01D43ECD.8C1940B0]

Lewis Roca Rothgerber Christie LLP

One South Church Avenue, Suite 2000

Tucson, Arizona 85701-1611

lrrc.com<http://lrrc.com/>




From: Jeff Neuman [mailto:jeff.neuman at comlaude.com]
Sent: Tuesday, August 28, 2018 12:32 PM
To: Aikman-Scalese, Anne; 'Annebeth Lange'; 'lists at christopherwilkinson.eu Wilkinson'; gnso-newgtld-wg at icann.org; Jim Prendergast
Cc: Brian Winterfeldt (Brian at Winterfeldt.law); Vicky Sheckler; Drazek, Keith
Subject: RE: [Gnso-newgtld-wg] Follow up on Consensus Topic

Anne,

Thanks for this note.  I guess clarity is in the eye of the beholder.   The section you quote requires the Co-Chairs to “make an evaluation of the designation [of the level of Consensus] and publish it to the group for review.”

That leaves open a lot of latitude for the co-chairs to come up with its evaluation methodology (which of course is reviewable by the Working Group), so long the co-chairs publish it for review.  What may be clear to some, is not as clear to others.

I do not see how a proposal by the Co-Chairs to appoint liaisons (or even empowered designees) deviates from the Working Group Guidelines.  Please note that the Co-Chairs have not stated that we will only look to the designees to determine Consensus.  We have just stated that knowing whether the positions that are being taken are by an individual or a group will “help” the Co-Chairs in our evaluation.    You may not like this method and that is ok and that may be the opinion of the full group, I don’t know.  But not liking the fact that the Co-Chairs are seeking help to evaluate the designation in this manner is VERY different than an accusation that the Co-Chairs are looking to deviate from the Working Group Guidelines.

As we stated on the call, Cheryl and I will review this with the Council Liaisons this week in our Leadership meeting and communicate back to the group.

Thanks.



Jeffrey J. Neuman
Senior Vice President | Valideus USA | Com Laude USA
1751 Pinnacle Drive, Suite 600
Mclean, VA 22102, United States
E: jeff.neuman at valideus.com<mailto:jeff.neuman at valideus.com> or jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>
T: +1.703.635.7514
M: +1.202.549.5079
@Jintlaw

From: Aikman-Scalese, Anne <AAikman at lrrc.com<mailto:AAikman at lrrc.com>>
Sent: Tuesday, August 28, 2018 2:30 PM
To: 'Annebeth Lange' <annebeth.lange at norid.no<mailto:annebeth.lange at norid.no>>; Jeff Neuman <jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>>; 'lists at christopherwilkinson.eu Wilkinson' <lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu>>; gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast <jim at GALWAYSG.COM<mailto:jim at GALWAYSG.COM>>
Cc: Brian Winterfeldt (Brian at Winterfeldt.law<mailto:Brian at Winterfeldt.law>) <Brian at Winterfeldt.law<mailto:Brian at Winterfeldt.law>>; Vicky Sheckler <victoria.sheckler at riaa.com<mailto:victoria.sheckler at riaa.com>>; Drazek, Keith <kdrazek at verisign.com<mailto:kdrazek at verisign.com>>
Subject: RE: [Gnso-newgtld-wg] Follow up on Consensus Topic

Dear all,
As this discussion continues, I have corrected Brian Winterfeldt’s address (which was wrong the first time I copied him.)

I really do appreciate how difficult it is going to be for Jeff and Cheryl to measure Consensus in such a large Working Group.  And it will be even more difficult in connection with Work Track 5.  That being said, “somebody’s got to do it.”  Given the many choices for the type of consensus listed in the WG Guidelines, there should be plenty of room to categorize the level of consensus achieved in the various views expressed in the WG.  In this regard, looking forward, it is difficult to see how Leadership of Sub Pro can avoid “polling” when measuring consensus.   (And the WG has not yet even presented the recommendations to the full WG for this purpose or addressed coordination among the Work Tracks.)

It seems to me that the Working Group guidelines on measuring consensus are quite clear on how Consensus should be measured.  https://gnso.icann.org/sites/default/files/file/field-file-attach/2016-12/annex-1-gnso-wg-guidelines-01sep16-en.pdf   (See the applicable excerpt on developing consensus below.)

The Guidelines  further state that if there is a desire to “deviate” from the specified method of measuring Consensus, this has to be “affirmatively stated in the Charter”.   Assuming Version 3.2 of the WG guidelines (Annex 1 to the GNSO Operating Procedures)  is the correct version, please see page 9 at the link above which provides:

[cid:image008.png at 01D43ECD.8B8C42F0]

Anne

Anne E. Aikman-Scalese

Of Counsel

520.629.4428 office


520.879.4725 fax

AAikman at lrrc.com<mailto:AAikman at lrrc.com>

_____________________________

[cid:image009.png at 01D43ECD.8B8C42F0]

Lewis Roca Rothgerber Christie LLP

One South Church Avenue, Suite 2000

Tucson, Arizona 85701-1611

lrrc.com<http://lrrc.com/>




From: Annebeth Lange [mailto:annebeth.lange at norid.no]
Sent: Tuesday, August 28, 2018 12:13 AM
To: Jeff Neuman; Aikman-Scalese, Anne; 'lists at christopherwilkinson.eu Wilkinson'; gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast
Cc: Vicky Sheckler; Winterfeldt, Brian J.; Drazek, Keith
Subject: Re: [Gnso-newgtld-wg] Follow up on Consensus Topic

All,

just a few words on this from a ccTLD point of view. We all know that it takes a lot of time and energy to be play an active part in the work of the working groups and PDPs. In our world, there are a lot of small ccTLDs spread over the world that not at all have resources to attend and participate at this level. Therefore, I as a co-lead in Worktrack 5, try to update all the regional organisations within ccNSO and send reports to the ccNSO council on the development in the working groups.

The 4 regional organisations (ROs) of the ccTLDs – CENTR, AFTLD, LACTLD and APTLD have all treated the issues of interest for them and have had extensive discussions. I don’t feel that it is inappropriate that these ROs representing the ccNSO find their spokesman based on the discussions they have had. That said, we as ccTLDs, are not very familiar with the concept of consensus in the GNSO-world, and I am certainly not an expert here.

But if you are interested in hearing the views of as many ccTLDs as possible – especially relevant for Worktrack 5 – this is a method that will work for us.

Best regards,
Annebeth


Kind regards,
Annebeth B. Lange
Special Adviser International Policy
UNINETT Norid AS

annebeth.lange at norid.no<mailto:annebeth.lange at norid.no>

Mobile: +47 959 11 559






From: Julie Hedlund <gnso-newgtld-wg-bounces at icann.org<mailto:gnso-newgtld-wg-bounces at icann.org>> on behalf of Jeff Neuman <jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>>
Date: Monday, 27 August 2018 at 20:50
To: "Aikman-Scalese, Anne" <AAikman at lrrc.com<mailto:AAikman at lrrc.com>>, "'lists at christopherwilkinson.eu Wilkinson'" <lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu>>, "gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>" <gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>>, Jim Prendergast <jim at GALWAYSG.COM<mailto:jim at GALWAYSG.COM>>
Cc: Vicky Sheckler <victoria.sheckler at riaa.com<mailto:victoria.sheckler at riaa.com>>, "Winterfeldt, Brian J." <BWinterfeldt at mayerbrown.com<mailto:BWinterfeldt at mayerbrown.com>>, Keith Drazek <kdrazek at verisign.com<mailto:kdrazek at verisign.com>>
Subject: Re: [Gnso-newgtld-wg] Follow up on Consensus Topic

Anne,

I cannot answer your question on the CCWG-Accountability group since I was not intimately involved in that group and only contributed to the work in a few matters.  There is no good answer for me on that question because of my lack of knowledge, so that is a rabbit hole I will not go down.

I have already explained why we are doing this.  If/when the IPC (or any other group submits comments), if the Working Group has questions about the IPC statement, we would like a person that we could go to within the PDP that could either answer those questions or if they do not know a person we can hold accountable to go back to the group to find out the answers.  In addition, in the Statements of Interest that are filed, there are many people listed as being part of each of the groups.  Cheryl and I would like a way to understand that when a person that happens to be in one of the groups is speaking on behalf of that group or on behalf of themselves or their employer.  And, in accordance with the Working Group Guidelines, we are also responsible for ensuring that we have the views of each of the groups.  If we don’t have the view of a C/SG/SO/AC, etc., on a recommendation, Cheryl and I can go to the point person from that group to ask them their position (if they have one).  Finally, when we measure the level of consensus, though not dispositive, the views of the different Cs, SGs, ACs, etc. are instructive.

I guess we can go around and around on this issue, but it is clear that will not convince you.  So, let me ask this question to try and get at this a different way.  What are you concerned about?  When we move ahead with this plan, what are the pitfalls that you see and what can we do to address them?




Jeffrey J. Neuman
Senior Vice President | Valideus USA | Com Laude USA
1751 Pinnacle Drive, Suite 600
Mclean, VA 22102, United States
E: jeff.neuman at valideus.com<mailto:jeff.neuman at valideus.com> or jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>
T: +1.703.635.7514
M: +1.202.549.5079
@Jintlaw

From: Aikman-Scalese, Anne <AAikman at lrrc.com<mailto:AAikman at lrrc.com>>
Sent: Monday, August 27, 2018 2:03 PM
To: Jeff Neuman <jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>>; 'lists at christopherwilkinson.eu Wilkinson' <lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu>>; gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast <jim at GALWAYSG.COM<mailto:jim at GALWAYSG.COM>>
Cc: Drazek, Keith <kdrazek at verisign.com<mailto:kdrazek at verisign.com>>; Austin, Donna <Donna.Austin at team.neustar<mailto:Donna.Austin at team.neustar>>; Winterfeldt, Brian J. <BWinterfeldt at mayerbrown.com<mailto:BWinterfeldt at mayerbrown.com>>; Vicky Sheckler <victoria.sheckler at riaa.com<mailto:victoria.sheckler at riaa.com>>
Subject: RE: [Gnso-newgtld-wg] Follow up on Consensus Topic

Jeff,
I would have to leave it up to IPC Leadership, after discussion within the IPC, as to whether they agree with this interpretation of the WG Guidelines.  It’s unquestionably a new one as far as I know – more reflective of steps taken in CCWG – Accountability , but in that case, the “representation” was explicit.

I think the notion that the GAC is going to appoint one rep to the Sub Pro group is pretty extreme.  Not sure as to ALAC or SSAC.  Are you looking for appointments that mirror what occurred in CCWG- Accountability?
Anne

Anne E. Aikman-Scalese

Of Counsel

520.629.4428 office


520.879.4725 fax

AAikman at lrrc.com<mailto:AAikman at lrrc.com>

_____________________________

[cid:image010.png at 01D43ECD.8B8C42F0]

Lewis Roca Rothgerber Christie LLP

One South Church Avenue, Suite 2000

Tucson, Arizona 85701-1611

lrrc.com<http://lrrc.com/>




From: Jeff Neuman [mailto:jeff.neuman at comlaude.com]
Sent: Monday, August 27, 2018 7:35 AM
To: Aikman-Scalese, Anne; 'lists at christopherwilkinson.eu Wilkinson'; gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast
Cc: Drazek, Keith; Austin, Donna
Subject: RE: [Gnso-newgtld-wg] Follow up on Consensus Topic

All,

We will discuss this further on the call today, but to be clear, we are asking for a spokesperson/alternate from each Constituency or Stakeholder Group (In the case of the GNSO), Supporting Organization (in the case of the ccNSO), and Advisory Committee (in the case of the GAC, ALAC, SSAC).   If an Advisory Committee wants to further break down into regional organization that is fine as well.  Cheryl and I are looking to understand that when positions are taken on issues, recommendations, comments, etc., are those positions held by just the individuals taking those positions, or are they the positions of a Constituency, Stakeholder Group, Supporting Organization, Advisory Committee, etc.

The Working Group Guidelines can be found here<https://gnso.icann.org/sites/default/files/file/field-file-attach/annex-1-gnso-wg-guidelines-18jun18-en.pdf>.  Based on Cheryl and I’s read of the Guidelines, it is our job as Co-Chairs to assess the level of Consensus of the Working Group (Section 3.6) .   Although it talks about the taking of Polls (and how care should be taken if doing those), there is little or no guidance on how the Co-Chairs make those calls and certainly nothing prohibiting us as Co-Chairs from trying to assess whether positions being taken are by a particular Constituency, Stakeholder Group, Supporting Organization, Advisory Committee, etc.   Section 2.2.1 of the Working Group Guidelines (as well as 3.2) also require the Chair (in our case Co-Chairs) to ensure that the Working Group is representative and in fact, Section 3.2 states “Ideally, a Working Group should mirror the diversity and representativeness of the community by having representatives from most, if not all, CO Stakeholder Groups and/or Constituencies.” [Emphasis Added]

Anne - Cheryl and I disagree with your view that merely asking for representatives from each group to help us ensure that we are capturing the views of each group in any way run contrary to the Working Group Guidelines.  In fact, we believe quite the opposite.  Not only will it help us comply with 2.2.1 and 3.2 of the Guidelines, but it will also help us to understand the context in which certain statements or positions are taken.  In a month or so when we start reviewing the comments from the Initial Report, we are likely to have questions on the comments that are submitted.  They may be clarification questions, or substantive questions.  Some of the comments are likely to come from the IPC, CBUC, ISPCP, CSG, RySG, RrSG, ALAC, GAC, ccNSO, SSAC, NCUC, NCSG, etc.  Having a person that we can all turn to as a representative of that group to direct these questions will help us tremendously.   If they don’t know an answer, we can look to them to get the answer from the represented group as an action item.  This is not “cutting corners” at all and makes good logical sense.

Of course, you are free to continue to disagree with this approach, but this is how we would like to move forward.  I look forward to discussing further in a few hours on our call. I have cc’d our GNSO Council Liaisons on this email.  Although Cheryl and I have weekly meetings with them and we have kept them in the loop, they should weigh in if they disagree.

Best regards,

Jeffrey J. Neuman
Senior Vice President | Valideus USA | Com Laude USA
1751 Pinnacle Drive, Suite 600
Mclean, VA 22102, United States
E: jeff.neuman at valideus.com<mailto:jeff.neuman at valideus.com> or jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>
T: +1.703.635.7514
M: +1.202.549.5079
@Jintlaw

From: Aikman-Scalese, Anne <AAikman at lrrc.com<mailto:AAikman at lrrc.com>>
Sent: Friday, August 24, 2018 5:16 PM
To: 'lists at christopherwilkinson.eu Wilkinson' <lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu>>; gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast <jim at GALWAYSG.COM<mailto:jim at GALWAYSG.COM>>; Jeff Neuman <jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>>
Subject: RE: [Gnso-newgtld-wg] Follow up on Consensus Topic

Christopher,
Jeff is not asking for one GNSO designee.   However, as a reminder, the PDP is  a GNSO process.    (My reference to “Constituencies” was merely shorthand.)
Anne

Anne E. Aikman-Scalese

Of Counsel

520.629.4428 office


520.879.4725 fax

AAikman at lrrc.com<mailto:AAikman at lrrc.com>

_____________________________

[cid:image011.png at 01D43ECD.8B8C42F0]

Lewis Roca Rothgerber Christie LLP

One South Church Avenue, Suite 2000

Tucson, Arizona 85701-1611

lrrc.com<http://lrrc.com/>




From: lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu> Wilkinson [mailto:lists at christopherwilkinson.eu]
Sent: Friday, August 24, 2018 1:57 PM
To: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Aikman-Scalese, Anne; Jim Prendergast; Jeff Neuman
Subject: RE: [Gnso-newgtld-wg] Follow up on Consensus Topic


Well, Jeff speaks of SO/ACs; Anne speaks of Constituencies! But  - as proposed - GNSO would have one empowered somebody, who BTW could not be IPC, who are by far the more divisive of all the PDP participants.

Good night

CW




El 24 de agosto de 2018 a las 22:43 "Aikman-Scalese, Anne" <AAikman at lrrc.com<mailto:AAikman at lrrc.com>> escribió:

I would have to agree with those who have observed that this is not an appropriate method for determining Consensus under Working Group guidelines.  Those guidelines don’t provide that consensus is measured via designation of an individual representative from each Constituency.  A version of that model was used (with voting attached) in the Accountability CCWG.  I don’t think it should be imported into the PDP process “on the fly” without policy work on the PDP process. If the Co-Chairs believe that measuring Consensus under current WG Guidelines is unwieldy, that is a subject for PDP 3.0.



Corners were already cut relative to measuring “Consensus” in the name of expediency when the Initial Report was issued.   Existing PDP procedures provide for Consensus to be measured among members of the full WG and these should be followed.

Anne



Anne E. Aikman-Scalese


Of Counsel


520.629.4428 office




520.879.4725 fax


AAikman at lrrc.com<mailto:AAikman at lrrc.com>


_____________________________


[cid:image010.png at 01D43ECD.8B8C42F0]


Lewis Roca Rothgerber Christie LLP


One South Church Avenue, Suite 2000


Tucson, Arizona 85701-1611


lrrc.com<http://lrrc.com/>








From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces at icann.org] On Behalf Of Jeff Neuman
Sent: Friday, August 24, 2018 11:53 AM
To: lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu> Wilkinson; gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast
Subject: Re: [Gnso-newgtld-wg] Follow up on Consensus Topic



Christopher,



We are not saying that all SGs, Cs, ACs, etc have unified positions.  That said, sometimes they do come out with statements that do have unified positions.  When a comment is filed on behalf an SG, C, etc., we do attribute that comment to the entire SG, C, etc. unless it explicitly states in the comment that it is not made on behalf of the SG,C, etc.



Asking for the name of a person who can be empowered to discuss issues on behalf of an SG, C, etc. to be sent to us with a months notice should be enough time.  After all, for the ePDP, I believe all of the representatives were identified within a week or two.  But we do have some additional time since we just extended the comment period.



If we can have the name representative(s) by September 28th (an extra two weeks), this will still be enough time before we start analysis of the comments to have an understanding of who is empowered to speak on behalf of the groups if/when we have questions or need to measure level of consensus.

Thanks.



Jeffrey J. Neuman

Senior Vice President | Valideus USA | Com Laude USA

1751 Pinnacle Drive, Suite 600

Mclean, VA 22102, United States

E: jeff.neuman at valideus.com<mailto:jeff.neuman at valideus.com> or jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>

T: +1.703.635.7514

M: +1.202.549.5079

@Jintlaw



From: lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu> Wilkinson <lists at christopherwilkinson.eu<mailto:lists at christopherwilkinson.eu>>
Sent: Friday, August 24, 2018 2:09 PM
To: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>; Jim Prendergast <jim at GALWAYSG.COM<mailto:jim at GALWAYSG.COM>>; Jeff Neuman <jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>>
Subject: Re: [Gnso-newgtld-wg] Follow up on Consensus Topic



Good evening:  I have also been perplexed, and thinking along very similar lines to Jim Prendergast's post.

I do not need to detail explicitly the diversity, even heterogeneity, of nearly all the SO/ACs, to suggest that the proposal would impose an impossible political burden on their leaderships, for which the SO/ACs  have neither the time, the resources nor the infrastructure to resolve at such short notice.

Regards

Christopher Wilkinson

El 24 de agosto de 2018 a las 18:57 Jim Prendergast <jim at GALWAYSG.COM<mailto:jim at GALWAYSG.COM>> escribió:

Cheryl and Jeff – Thanks for sending the note.  Since this is the first PDP for many, including me, I have a few questions about this approach.



Has this concept of designating representatives for SO/AC/SG/Cs been done in previous PDPs?



I looked at the charter for this PDP and did not see any reference to it so I presumed that I was always participating in my own capacity and not behalf of any SO/AC/SG/Cs.  Now it seems like a new class of PDP participant is being created. One that holds more sway than everyone else who has been participating for the last two years or so.  Is that the intent?  It would seem to me if this was the process that was going to be used, it should have been called out in the charter.  It certainly would have influenced how SO/AC/SG/Cs looked at this PDP from the start.



How do you envision these new “empowered” participants to effectively represent SO/AC/SG/C positions in such a fluid environment?  It’s not difficult to imagine a lot of “I need to consult my SO/AC/SG/C” responses to questions and that process, depending on the SO/AC/SG/C, could take weeks.



I’m still trying to get my head around measuring consensus qualitatively and not quantitively – what is the methodology?  It may have been discussed on a previous call so if that’s the case, could you or Steve circulate the link to the recordings so I and others can review this?  I know were pretty far off from this process kicking in but it’s important for all PDP participants have a solid grasp of the methodology being used before we get there.



Thanks





From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:gnso-newgtld-wg-bounces at icann.org>> On Behalf Of Jeff Neuman
Sent: Monday, August 20, 2018 2:28 PM
To: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
Subject: [Gnso-newgtld-wg] Follow up on Consensus Topic



All,



On the full Working Group call, one of the items we discussed was the difficult task that Cheryl and I, as Overall Working Group Co-Chairs, will have in ultimately determining the level of “Consensus” on each recommendation and for the overall final report (which I know is a number of months away).



In preparation for our group evaluating the public comments to the Initial Report next month, we would like to request that by September 14th, each Constituency, Stakeholder Group, Advisory Committee, etc. designate one person (and an alternate) that is empowered to speak for that particular Constituency, Stakeholder Group, Advisory Committee, etc.    This is not in any way an attempt to discourage individuals from participating, giving their opinions, helping to analyze comments, drafting, etc., but rather just an attempt for Cheryl and I to understand that when a position is being taken by someone, it is as an individual contributor, an organization or on behalf of a Stakeholder Group, Constituency, Advisory Committee, etc.



As we have repeatedly stated, Consensus is measured qualitatively and not quantitively.   Therefore, understanding the context in which position statements are made would be very helpful in moving forward.  Once we receive all of this information, we will then include that in the list of members of the Working Group.



Thanks in advance.



Best regards,



Jeffrey J. Neuman

Senior Vice President |Valideus USA | Com Laude USA

1751 Pinnacle Drive, Suite 600

Mclean, VA 22102, United States

E: jeff.neuman at valideus.com<mailto:jeff.neuman at valideus.com> or jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>

T: +1.703.635.7514

M: +1.202.549.5079

@Jintlaw





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This message and any attachments are intended only for the use of the individual or entity to which they are addressed. If the reader of this message or an attachment is not the intended recipient or the employee or agent responsible for delivering the message or attachment to the intended recipient you are hereby notified that any dissemination, distribution or copying of this message or any attachment is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the sender. The information transmitted in this message and any attachments may be privileged, is intended only for the personal and confidential use of the intended recipients, and is covered by the Electronic Communications Privacy Act, 18 U.S.C. §2510-2521.

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This message and any attachments are intended only for the use of the individual or entity to which they are addressed. If the reader of this message or an attachment is not the intended recipient or the employee or agent responsible for delivering the message or attachment to the intended recipient you are hereby notified that any dissemination, distribution or copying of this message or any attachment is strictly prohibited. If you have received this communication in error, please notify us immediately by replying to the sender. The information transmitted in this message and any attachments may be privileged, is intended only for the personal and confidential use of the intended recipients, and is covered by the Electronic Communications Privacy Act, 18 U.S.C. §2510-2521.
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