[Gnso-ppsai-pdp-wg] For your review - updated template Cat B - question 2
John Horton
john.horton at legitscript.com
Tue Mar 18 03:33:46 UTC 2014
Question, with respect to the "suspension rates being catastrophic"
concerns: if, for the sake of argument, we're talking about requiring
additional verification for P/P beyond what the 2013 RAA requires, a
failure -- especially one based solely on non-response -- wouldn't
necessarily lead to domain name suspension, would it? (Unless the failure
reasonably indicates that the Whois data is actually false.) I assume that
failure of any supplemental verification required by a P/P service would
result in merely terminating the P/P service itself, unless the failure
actually indicates that the information is falsified.
In other words:
- If the verification already required under the 2013 RAA fails, the
Registrar may have to suspend the domain name anyway.
- If any verification required for P/P providers *in addition to* the
2013 RAA requirements fails solely due to non-response, it doesn't seem to
me that the remedy would have to be (or should be) domain name suspension;
rather, it would likely only be terminating the P/P service itself,
revealing the domain name registration data but leaving the domain name
active and pointing to content.
- However, if any verification required for P/P providers *in addition
to* the 2013 RAA requirements fails as a result of the underlying
information actually being falsified, then suspension may be appropriate
anyway, in addition to the P/P service being withdrawn.
My apologies if I'm missing something there, but I'm not sure that it
follows that there would have to be any domain name suspensions for
failures to verify the *supplemental* information not originally required
to be verified by the 2013 RAA, as described in the Whois Accuracy Program
Specification.
John Horton
President, LegitScript
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On Mon, Mar 17, 2014 at 7:50 PM, Stephanie Perrin <
stephanie.perrin at mail.utoronto.ca> wrote:
> I agree with what James and Michele have said, and I view this as
> extremely discriminatory and therefore highly problematic from a
> competition policy perspective.
> Stephanie Perrin
>
> On Mar 17, 2014, at 10:41 PM, Graeme Bunton <gbunton at tucows.com> wrote:
>
> Agreeing with what James and Michele have stated here.
> The suspension rates would be catastrophic, with no real gain over what
> the 2013 RAA ensures.
>
> Graeme
>
> On 3/17/2014 6:24 PM, James M. Bladel wrote:
>
> Everyone, this part of Michele's post is key:
>
> If there's a bounce or any other indication that the contact details are
> invalid then let the 2013 RAA standards apply - if any.
>
>
>
> The 2013 RAA requires registrar to re-verify the contact information if
> the information is known to be invalid. A bounced or undeliverable
> reminder email certainly qualifies.
>
> But to take this further, and claim that non-response = invalid contact
> information is speculation and could have catastrophic implications. As
> Michele notes, registrars work our tails off to drive these response rates
> in to the high single digits or low teens.
>
> Suspending upwards of 80% of domain names would be prohibitively
> disruptive and I've seen nothing in this thread/PDP to justify such a
> radical proposal.
>
> Thanks--
>
> J.
>
> Sent from my iPad
>
> On Mar 17, 2014, at 15:13, "Michele Neylon - Blacknight" <
> michele at blacknight.com> wrote:
>
> I cannot agree with this.
>
> Just because somebody does not reply to an annual email does not mean
> anything and expecting registrars or proxy / privacy providers to do
> anything extra based on a lack of response is completely unreasonable.
>
> If there's a bounce or any other indication that the contact details are
> invalid then let the 2013 RAA standards apply - if any.
>
> But expecting registrars or privacy / proxy providers to do extra
> validation simply because a customer hasn't responded to an annual whois
> data reminder simply will not fly.
>
> We send out thousands of these reminders every year. Only a tiny
> percentage of our clients ever reply to them - and if their details haven't
> changed why on earth would they have to?
>
> Regards
>
> Michele
>
> --
> Mr Michele Neylon
> Blacknight Solutions
> Hosting & Colocation, Domains
> http://www.blacknight.co/
> http://blog.blacknight.com/
> http://www.technology.ie
> Intl. +353 (0) 59 9183072
> Locall: 1850 929 929
> Direct Dial: +353 (0)59 9183090
> Fax. +353 (0) 1 4811 763
> Twitter: http://twitter.com/mneylon
> -------------------------------
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
> Road,Graiguecullen,Carlow,Ireland Company No.: 370845
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> mailto:gnso-ppsai-pdp-wg-bounces at icann.org<gnso-ppsai-pdp-wg-bounces at icann.org>
> ] *On Behalf Of *Valeriya Sherman
> *Sent:* Monday, March 17, 2014 8:09 PM
> *To:* Metalitz, Steven; 'Williams, Todd'; Marika Konings;
> gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat
> B - question 2
>
> I, Jim Bikoff, David Heasley, and Griffin Barnett agree with Todd's
> assessment:
>
> Contact information that is ultimately revealed is valuable only if it is
> accurate.
>
> The validation/verification requirements should be consistent with the
> 2013 RAA requirements, but should go above and beyond those requirements to
> ensure the accuracy of contact information.
>
> Registrars already send an annual Whois Data Reminder Policy
> notification to registrants, reminding them to provide accurate and
> up-to-date information.
>
> Similarly, the privacy/proxy customer's contact information should be
> verified upon initial registration of the domain name (either by the
> registrar or the Privacy/Proxy Service Provider) and periodically
> thereafter by automated annual email re-verification notifications that
> require an affirmative response by the P/P customer. Absence of a response
> would trigger a follow-up, reminding the privacy/proxy customer to provide
> accurate and up-to-date information.
>
> Regards,
>
> Valeriya Sherman
> Silverberg, Goldman & Bikoff, L.L.P.
> 1101 30th Street, N.W.
> Suite 120
> Washington, D.C. 20007
> Tel 202.944.2330
> Cell 303.589.7477
> vsherman at sgbdc.com <vsherman at law.gwu.edu>
> ------------------------------
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> gnso-ppsai-pdp-wg-bounces at icann.org] on behalf of Metalitz, Steven [
> met at msk.com]
> *Sent:* Monday, March 17, 2014 6:13 AM
> *To:* 'Williams, Todd'; Marika Konings; gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat
> B - question 2
> I agree with Todd's characterization of the status of this discussion, and
> that the questions he highlights are still open.
>
> Another aspect of the second question below is how the p/p service
> provider should handle situations in which the contact information supplied
> by the customer cannot be verified. In the parallel situation involving
> non-proxy registrations, the RAA specification calls either for suspension
> of the registration, or "manual verification," which is not defined. How
> should this apply in the p/p service scenario?
>
> Steve Metalitz
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> mailto:gnso-ppsai-pdp-wg-bounces at icann.org<gnso-ppsai-pdp-wg-bounces at icann.org>
> ] *On Behalf Of *Williams, Todd
> *Sent:* Friday, March 14, 2014 4:53 PM
> *To:* Marika Konings; gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat
> B - question 2
>
> Thanks Marika. I missed part of the call on Tuesday where this may have
> been discussed, but I don't see how the draft preliminary recommendation
> follows from the attached Word document, insofar as it concludes that p/p
> customer data should be validated and verified in a manner consistent with
> the requirements outlined in the 2013 RAA. I thought the current posture
> was that the WG has basically agreed to the 2013 RAA requirements as a
> floor, but that there was not yet agreement on: 1) whether
> validation/verification requirements should go beyond the 2013 RAA; and 2)
> if so, how.
>
> On the first question (2013 RAA vs. "more"), it appears that more of the
> responses in the attached argue for "more" than not. That also seems to
> have been an open topic in our email threads (see attached). Just to
> reiterate from that thread, the basic argument on the "more" side (which I
> agree with) is that in order to partially offset the delay that will
> inevitably occur when accessing p/p data, the "more" should consist of
> whatever reasonable validation/verification steps can be taken to increase
> the likelihood that the information ultimately obtained will be accurate
> enough to facilitate contact. I suppose that if we ultimately settle on a
> "reveal" procedure that is essentially instantaneous in certain cases (once
> we get to discussing "reveal" procedures), that may mitigate this concern.
> But absent assurances on that point, I would think we need to address it.
>
> On the second question: the attached appears to include multiple proposals
> as to what may or may not ultimately comprise the "more" (*e.g.*, email
> *and* phone vs. or; periodic/annual re-verification vs. re-verification
> with information suggesting the contact information is incorrect; etc.).
> Have we debated the relative merits of those? Are some more likely to be
> effective than others? I have my thoughts, but I'm curious to hear what
> everybody else thinks.
>
> Thanks all.
>
> Todd.
>
> *From:* gnso-ppsai-pdp-wg-bounces at icann.org [
> mailto:gnso-ppsai-pdp-wg-bounces at icann.org<gnso-ppsai-pdp-wg-bounces at icann.org>
> ] *On Behalf Of *Marika Konings
> *Sent:* Thursday, March 13, 2014 7:04 AM
> *To:* gnso-ppsai-pdp-wg at icann.org
> *Subject:* [Gnso-ppsai-pdp-wg] For your review - updated template Cat B -
> question 2
>
> Dear All,
>
> Following our call earlier this week, please find attached the updated
> template for Category B - question 2. To facilitate your review, I've
> posted below the draft preliminary recommendation in which we've aimed to
> capture the conversation to date taking into account the language of the
> Whois Accuracy Specification Program of the 2013 RAA. If you are of the
> view that this does not accurately capture the WG's view to date and/or
> have specific suggestions for changes / edits, please share those with the
> mailing list. Also, if there are any other issues that need to be addressed
> in relation to this question and/or the preliminary recommendation, please
> share those as well.
>
> Best regards,
>
> Marika
>
> *Draft Preliminary Recommendation - Category B - question 2 (Should
> ICANN-accredited privacy/proxy service providers be required to conduct
> periodic checks to ensure accuracy of customer contact information; and if
> so, how?)*
>
> The WG recommends that proxy and privacy customer data be validated and
> verified in a manner consistent with the requirements outlined in Whois
> Accuracy Specification Program of the 2013 RAA. The WG furthermore agrees
> that in the cases where validation and verification of the P/P customer
> data was carried out by the registrar, reverification by the P/P service of
> the same, identical, information should not be required.
>
> Similar to ICANN's Whois Data Reminder Policy (
> http://www.icann.org/en/resources/registrars/consensus-policies/wdrp),
> the P/P provider should be required to inform the P/P customer annually of
> his/her requirement to provide accurate and up to date contact information
> to the P/P provider. If the P/P provider has any information suggesting
> that the P/P customer information is incorrect (such as P/P service
> receiving a bounced email notification or non-delivery notification message
> in connection with compliance with data reminder notices or otherwise) for
> any P/P customer, the P/P provider must verify or re-verify, as applicable,
> the email address(es). If, within fifteen (15) calendar days after
> receiving any such information, P/P service does not receive an affirmative
> response from the P/P customer providing the required verification, the P/P
> service shall verify the applicable contact information manually.
>
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>
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>
>
> --
> _________________________
> Graeme Bunton
> Information Specialist
> Tucows Inc.
> PH: 416 535 0123 ext 1634
>
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