[Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3

Thu Apr 30 15:56:10 UTC 2015

I agree, very sensible, assuming this means you will withdraw the 
proposed ancillary questions which have kicked off this debate.
Kind regards
Stephanie

On 2015-05-01 0:42, James Gannon wrote:
>
> Steve,
>
> That seems like a logical compromise between both sides, it has my 
> full support.
>
> -James
>
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] *On Behalf Of *Metalitz, 
> Steven
> *Sent:* Thursday, April 30, 2015 4:36 PM
> *To:* 'Graeme Bunton'; gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3
>
> Graeme and I have asked staff to insert a footnote in this section, 
> providing links to the extensive discussions of the topic in WG 
> meetings (telephonic and face to face) and on the mailing list, as 
> background for the public.
>
> Steve
>
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org> 
> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] *On Behalf Of *Graeme Bunton
> *Sent:* Thursday, April 30, 2015 11:14 AM
> *To:* gnso-ppsai-pdp-wg at icann.org <mailto:gnso-ppsai-pdp-wg at icann.org>
> *Subject:* Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3
>
> Steve, myself and staff are discussing how to proceed while ensuring
> that balance is maintained.
> Thank you all for your contributions.
>
> Graeme
> On 2015-04-30 11:02 AM, Stephanie Perrin wrote:
> > So let me get this very very clear, as i am new to the process.
> > 1. The research report you offered was sent to the list.
> > 2. It has never been part of the record.
> > 3. You wish to see it added now, April 30th, 23:58 KST.
> > 4, You are telling me I could have done the same thing.
> > 5. I have Exactly how much time to submit a minority report in order
> > to comply with the deadline of April 30th?
> >
> > Thanks for the clarifications.
> > Stephanie
> >
> > On 2015-04-30 23:52, Kiran Malancharuvil wrote:
> >> Stephanie,
> >>
> >> You had ample opportunity to prepare and present a white paper of
> >> your own.
> >>
> >> It was not unsolicited, as at any time, members of the group are
> >> welcome and encouraged to present their views on the matter under
> >> discussion.
> >>
> >> Are you really saying that a well researched policy position and a
> >> presentation of that research is NOT meant to be a part of the PDP
> >> process? I really do not think that it the case.
> >>
> >> I know that you object to the position that the white paper explains,
> >> but unless there is a concrete prohibition on linking to it (staff?)
> >> it needs to be included, as we have every right to present the
> >> complex legal argument behind our position.
> >>
> >> Kiran Malancharuvil
> >> Internet Policy Counselor
> >> MarkMonitor
> >> 415-419-9138 (m)
> >>
> >> Sent from my mobile, please excuse any typos.
> >>
> >>> On Apr 30, 2015, at 7:45 AM, Stephanie Perrin
> >>> <stephanie.perrin at mail.utoronto.ca 
> <mailto:stephanie.perrin at mail.utoronto.ca>> wrote:
> >>>
> >>> With great respect to Kiran and to the law firm that compiled the
> >>> "white paper", I objected at the time and there was no indication
> >>> that we accepted the white paper in our discussions, other than to
> >>> say thanks. I would object strenuously to it being included. That
> >>> was a totally unsolicited contribution from parties wishing to
> >>> advance their case. You cannot attach that paper, without giving
> >>> those on the other side an opportunity to counter it with another
> >>> white paper. Frankly, the PDP process is not supposed to be about
> >>> dualling unsolicited white papers. IF we need to have research
> >>> done, we have to agree on what needs to be done if it is to be
> >>> attached to the official call for comments. I don't wish to be
> >>> ungracious, but the paper should not be added.
> >>> Stephanie Perrin
> >>>
> >>>> On 2015-04-30 23:34, Kiran Malancharuvil wrote:
> >>>> It is a recommendation for a policy/best practice from a portion of
> >>>> the group.
> >>>>
> >>>> K
> >>>>
> >>>> Kiran Malancharuvil
> >>>> Internet Policy Counselor
> >>>> MarkMonitor
> >>>> 415-419-9138 (m)
> >>>>
> >>>> Sent from my mobile, please excuse any typos.
> >>>>
> >>>>> On Apr 30, 2015, at 7:33 AM, James Gannon
> >>>>> <james at cyberinvasion.net <mailto:james at cyberinvasion.net>> wrote:
> >>>>>
> >>>>> Unless we are suggesting that the whitepaper is consensus policy
> >>>>> or best practice it does not fall under that category. We are
> >>>>> presenting our policy recommendation already, which is the work
> >>>>> product of the group
> >>>>>
> >>>>> -James
> >>>>>
> >>>>> -----Original Message-----
> >>>>> From: Kiran Malancharuvil
> >>>>> [mailto:Kiran.Malancharuvil at markmonitor.com]
> >>>>> Sent: Thursday, April 30, 2015 3:31 PM
> >>>>> To: James Gannon
> >>>>> Cc: Mary Wong; PPSAI
> >>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section
> >>>>> 1.3.3
> >>>>>
> >>>>> Recommendations for policies, guidelines, best practices.
> >>>>>
> >>>>> Kiran Malancharuvil
> >>>>> Internet Policy Counselor
> >>>>> MarkMonitor
> >>>>> 415-419-9138 (m)
> >>>>>
> >>>>> Sent from my mobile, please excuse any typos.
> >>>>>
> >>>>>> On Apr 30, 2015, at 7:29 AM, James Gannon
> >>>>>> <james at cyberinvasion.net <mailto:james at cyberinvasion.net>> wrote:
> >>>>>>
> >>>>>> Quoting from the PDP Manual, there seems to be strong guidelines
> >>>>>> of what goes out with the Initial Report:
> >>>>>>
> >>>>>>> After collection and review of information, the PDP Team and
> >>>>>>> Staff are responsible for producing an Initial Report. The
> >>>>>>> Initial Report should include the following elements:
> >>>>>>> * Compilation of Stakeholder Group and Constituency Statements
> >>>>>>> * Compilation of any statements received from any ICANN
> >>>>>>> Supporting Organization or Advisory Committee
> >>>>>>> * Recommendations for policies, guidelines, best practices or
> >>>>>>> other proposals to address the issue
> >>>>>>> * Statement of level of consensus for the recommendations
> >>>>>>> presented in the Initial Report
> >>>>>>> * Information regarding the members of the PDP Team, such as the
> >>>>>>> attendance records, Statements of Interest, etc.
> >>>>>>> * A statement on the WG discussion concerning impact of the
> >>>>>>> proposed recommendations, could consider areas such as economic,
> >>>>>>> competition, operations, privacy and other rights, scalability
> >>>>>>> and feasibility
> >>>>>> I don't see where in that framework the whitepaper would sit. I
> >>>>>> would welcome others thoughts on this.
> >>>>>>
> >>>>>> -James
> >>>>>>
> >>>>>> -----Original Message-----
> >>>>>> From: gnso-ppsai-pdp-wg-bounces at icann.org 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>
> >>>>>> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Kiran
> >>>>>> Malancharuvil
> >>>>>> Sent: Thursday, April 30, 2015 3:09 PM
> >>>>>> To: Mary Wong
> >>>>>> Cc: PPSAI
> >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section
> >>>>>> 1.3.3
> >>>>>>
> >>>>>> Mary,
> >>>>>>
> >>>>>> Since one side of this issue prepared a lengthy legal review to
> >>>>>> address this question, I would request that that white paper be
> >>>>>> included in the reference materials for the public comment. Since
> >>>>>> public comment is meant to "resolve" this issue, commenters need
> >>>>>> all of the information.
> >>>>>>
> >>>>>> It's not just down to feasibility of self-declaration at
> >>>>>> registration (which frankly, many of us see as a cop out since
> >>>>>> it's already done in some TLDs), but also legality.
> >>>>>> Not trying to re-open the debate, but please, let's make sure the
> >>>>>> community understands the various points and the background.
> >>>>>>
> >>>>>> K
> >>>>>>
> >>>>>>
> >>>>>> Kiran Malancharuvil
> >>>>>> Internet Policy Counselor
> >>>>>> MarkMonitor
> >>>>>> 415-419-9138 (m)
> >>>>>>
> >>>>>> Sent from my mobile, please excuse any typos.
> >>>>>>
> >>>>>> On Apr 30, 2015, at 6:58 AM, Mary Wong
> >>>>>> <mary.wong at icann.org<mailto:mary.wong at icann.org 
> <mailto:mary.wong at icann.org%3cmailto:mary.wong at icann.org>>> wrote:
> >>>>>>
> >>>>>> To add to Stephanie's note that this specific issue - whether
> >>>>>> registrants of domain names actively used for commercial
> >>>>>> transactions ought to be disallowed from using P/P services - had
> >>>>>> been discussed at some length by the WG:
> >>>>>>
> >>>>>> Please note that this part of the Initial Report draws heavily on
> >>>>>> the detailed WG template for Charter Category C that was the
> >>>>>> basis for the WG's deliberations on this topic. That template
> >>>>>> contains lengthy descriptions of what had previously been termed
> >>>>>> the majority and minority positions on the WG's answer to this
> >>>>>> specific issue. As part of the WG's deliberations - which took
> >>>>>> place primarily between April and June 2014 - the more specific
> >>>>>> formulation of "transactional" to describe the sort of commercial
> >>>>>> (i.e. Involving financial transactions) activities that were
> >>>>>> being discussed was included in the language. All the templates
> >>>>>> and suggested formulations discussed by the WG are recorded and
> >>>>>> published on the WG wiki.
> >>>>>>
> >>>>>> The WG ultimately agreed to retain the two positions in the
> >>>>>> Initial Report and to revisit the question during its review of
> >>>>>> the public comments received. As noted previously, the WG's views
> >>>>>> were presented to the community in London in June 2014 and again
> >>>>>> in Los Angeles in October 2014.
> >>>>>>
> >>>>>> Therefore, the three questions in Section 1.3.3 of the Executive
> >>>>>> Summary only go toward soliciting community input on this single
> >>>>>> issue. They were not intended to represent a view of any "side"
> >>>>>> in the WG with regard to this matter. If the WG prefers, we can
> >>>>>> add a sentence to clarify and specify the reason for the
> >>>>>> questions in Section 1.3.3. Fundamentally, the idea is that
> >>>>>> public comments will facilitate the WG's eventual resolution of
> >>>>>> this issue as part of its preparation of the Final Report.
> >>>>>>
> >>>>>> We hope this reminder of the background is of assistance.
> >>>>>>
> >>>>>> Cheers
> >>>>>> Mary
> >>>>>>
> >>>>>> Mary Wong
> >>>>>> Senior Policy Director
> >>>>>> Internet Corporation for Assigned Names & Numbers (ICANN)
> >>>>>> Telephone: +1 603 574 4892
> >>>>>> Email: mary.wong at icann.org<mailto:mary.wong at icann.org 
> <mailto:mary.wong at icann.org%3cmailto:mary.wong at icann.org>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>> From: Stephanie Perrin
> >>>>>> 
> <stephanie.perrin at mail.utoronto.ca<mailto:stephanie.perrin at mail.utoronto.ca 
> <mailto:stephanie.perrin at mail.utoronto.ca%3cmailto:stephanie.perrin at mail.utoronto.ca>>>
> >>>>>> Date: Thursday, April 30, 2015 at 09:20
> >>>>>> To:
> >>>>>> 
> "gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org> 
> <mailto:gnso-ppsai-pdp-wg at icann.org%3cmailto:gnso-ppsai-pdp-wg at icann.org%3e>" 
>
> >>>>>> <gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org 
> <mailto:gnso-ppsai-pdp-wg at icann.org%3cmailto:gnso-ppsai-pdp-wg at icann.org>>>, 
> James
> >>>>>> Gannon <james at cyberinvasion.net<mailto:james at cyberinvasion.net 
> <mailto:james at cyberinvasion.net%3cmailto:james at cyberinvasion.net>>>,
> >>>>>> Michele Blacknight
> >>>>>> <michele at blacknight.com<mailto:michele at blacknight.com 
> <mailto:michele at blacknight.com%3cmailto:michele at blacknight.com>>>
> >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section
> >>>>>> 1.3.3
> >>>>>>
> >>>>>> James, prior to you joining the group, we had discussed this at
> >>>>>> some length. IN fact, I really thought that the many reasons why
> >>>>>> sorting out the purpose of a registration is problematic had
> >>>>>> buried this debate, but apparently not. Some of the issues
> >>>>>> raised, according to my recollection were the following:
> >>>>>>
> >>>>>> * names are registered prior to decisions about content
> >>>>>> * content changes over time
> >>>>>> * most countries regulate e-commerce in some fashion, so that
> >>>>>> website commercial activity does not have to be regulated by ICANN
> >>>>>> * ICANN should not be in the business of regulating content in
> >>>>>> the first place (and sorting out who is extracting a material
> >>>>>> consideration from a website in order to deny them the ability to
> >>>>>> use a proxy registration is certainly a form of regulation)
> >>>>>> * definitions of commercial activity vary widely around the world
> >>>>>> * bad actors will not declare, registrars cannot police this
> >>>>>> matter
> >>>>>> * criminal prosecution is not dependent on WHOIS information
> >>>>>> * if this is really about the ability to detect market
> >>>>>> information, ICANN should not be in the business of making
> >>>>>> registrant information available for market purposes, it does it
> >>>>>> for security and stability.
> >>>>>> * contactability remains, regardless of which registrant info
> >>>>>> appears in WHOIS
> >>>>>>
> >>>>>> I am planning to reformulate these into questions to match the
> >>>>>> questions on the other side, suggestions welcome.
> >>>>>>
> >>>>>> Stephanie Perrin
> >>>>>> On 2015-04-30 16:24, James Gannon wrote:
> >>>>>> I don't see this as asking providers to enforce anything similar
> >>>>>> to other questions when registering a domain, it's a
> >>>>>> self-reported assessment. All it does is add an additional branch
> >>>>>> to the decision tree for eligibility, which will already be there
> >>>>>> to determine eligibility due to the other reasons listed below.
> >>>>>> The registrant is asked will you be processing financial
> >>>>>> transactions.
> >>>>>>
> >>>>>>
> >>>>>> * Yes-->Will you be using a 3rd party>No>Not eligible for
> >>>>>> P/P.
> >>>>>>
> >>>>>> * Yes-->Will you be using a 3rd party>Yes>Eligible for P/P.
> >>>>>>
> >>>>>>
> >>>>>> I'm not asking registrars to enforce law but to see if a more
> >>>>>> finely grained eligibility process can be enacted. Or at least is
> >>>>>> there is public support for more granularity.
> >>>>>>
> >>>>>> -James
> >>>>>> From: Michele Neylon - Blacknight [mailto:michele at blacknight.com]
> >>>>>> Sent: Thursday, April 30, 2015 8:17 AM
> >>>>>> To: James Gannon; Graeme Bunton; PPSAI
> >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section
> >>>>>> 1.3.3
> >>>>>>
> >>>>>> James
> >>>>>>
> >>>>>> As a registrar or PP service provider how am I meant to assess 
> this?
> >>>>>>
> >>>>>> It doesn't scale
> >>>>>>
> >>>>>> Seriously.
> >>>>>>
> >>>>>> If, for example, there is an Irish operated website that is not
> >>>>>> complying with Irish law then it would be up to the ODCE
> >>>>>> (http://www.odce.ie/ 
> <https://protect-us.mimecast.com/r/IqfLPS2xhmx-5GDCPCM4mLmlw-jOPQHGmhpzAjWDKActStEmX7ndjfqnEIgUMkdhXCAGe_aALVo69T0irIiCOftGW0RRkFeeJXP_SQ_bxxN5c9ZWrJzjnfSpDUeI4UjuT2dsrtgXox-JsiUyGsBvbDhSHcf2gH3gqSI2YwvUnORJuOhanPP2uCSQp3bey2BqQKbirhovyP6hDiunUi2Ilg>) 
> to enforce whatever needs enforcing, as it
> >>>>>> would be up to the DPA to enforce any issues around data privacy
> >>>>>> etc., etc.,
> >>>>>>
> >>>>>> Attempting to force registrars and PP providers to make these
> >>>>>> kind of evaluations is not going to work.
> >>>>>>
> >>>>>> Issues like PCI-DSS compliance are matters that should be dealt
> >>>>>> with by the DPA and the banks.
> >>>>>>
> >>>>>> Forcing registrars and PP providers to start getting involved in
> >>>>>> that kind of assessment isn't viable
> >>>>>>
> >>>>>> Regards
> >>>>>>
> >>>>>> Michele
> >>>>>>
> >>>>>> --
> >>>>>> Mr Michele Neylon
> >>>>>> Blacknight Solutions
> >>>>>> Hosting, Colocation & Domains
> >>>>>> http://www.blacknight.host/ 
> <https://protect-us.mimecast.com/r/r0QiXaZk72F7OmWKc9_pO3HAiIAvI3h06-RcgETJh-J4kMLvQtMGZn5lKnoQO8ikZnQiTNL6FLbYD67s4dF-tWj2IbgtPVbZIrmLhFiT8cZvRoXUKLem6cyG8n3JE6-tis8tEkBPwKkOuqFU7azbPzFSZPBE0XjNt1o6W5MAy5yWOEr-3QLGcTYMC5oDDDwuftYuz9pHDOyvEieReE36N1UxTeWXBI__3g1_xmHN4S0>
> >>>>>> http://blog.blacknight.com/ 
> <https://protect-us.mimecast.com/r/wl1MfvJ8aWTxnqz6FCsjG4QE5Lt8k3OKgMWheA8wVhCgpAj6NRi9Y8zMxa9MvTN2vhD-EWNpvAhObo3t9Jl-Kh7ki557bXwOMPGhz-Up4X8e1Q8UR-DF0d4jYhrGpb0LrotD50UduC3QQRYUJ24nEnbyayh-GPs3hk77LhEpDwYrSf4v_RqmohacWFuO-pMc6Ap8I9JulleUf0h9FbW-MHMc1xlq8F7WXPVnekaa_Tg>
> >>>>>> http://www.blacknight.press 
> <https://protect-us.mimecast.com/r/-MRGGedz53TF8UWq3rKo8GI39ai_ismqN0UYggzFnhsCzIT83jwX24BSxN_VMtJYpUgkSGF-Qst71LuBVQLY87bs-vewJiEDX8p5ABHKofJc69pmthPRFaowH9cz7b4wBdr45nD9yW3n5wmmAGAorNORPO2oD8fx1b7Ch4UucRtocG7TVoD8q8xePkXjqmELFjL3powas7Q8SOSYQE947lLpZzCcGrOwqu7wogrVuvk> 
> - get our latest news & media
> >>>>>> coverage http://www.technology.ie 
> <https://protect-us.mimecast.com/r/suwZNIiJfrdSpqE4iC56mMY3x3S91aHmdyA2bCRS-Fmr9Q1_uNxFISl4UXNQGJAa4ABDSoMKKJoH4LBI6dPDpw1IcPIW2UD6KmY-khZffkUgGyGTLPU0VW-nWld8z7P0H2Ru_lA2gyfCIuoaN7WmFU6IRQ9AVVBKNMpsRsxQkxp27qp4b1vr0Nu7xAxlXjinmqCYcWDyv6BlIGk1JID86YB5QMhEW98wyZ5sollRXTc> 
> Intl. +353 (0) 59 9183072
> >>>>>> Direct Dial: +353 (0)59 9183090
> >>>>>> Social: http://mneylon.social 
> <https://protect-us.mimecast.com/r/c9ciyb99CMvSHLw2MJX2WYjWAGojFAv6abNbJNSbdh-ZFyKYiMOesCOSW0IbP_Hk74wcQMPR4LFdtPIo3qwpdVxkGjxnPEF73YlWOioKWfm0ASY6v7enF3zKmqddqH2G4dXIbPg_PVqGwzzZzhWQxKSK2MKPyc4QXazyYJjS7H_X2JdIq2B8eAZeCDmgPBWH09Ix-VujUi5pHJeE_GXWIlFrE4TTH0hP08WIPWYQvhY>
> >>>>>> -------------------------------
> >>>>>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business
> >>>>>> Park,Sleaty Road,Graiguecullen,Carlow,Ireland Company No.: 370845
> >>>>>>
> >>>>>> From: James Gannon
> >>>>>> Date: Thursday 30 April 2015 07:45
> >>>>>> To: Graeme Bunton,
> >>>>>> 
> "gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org> 
> <mailto:gnso-ppsai-pdp-wg at icann.org%3cmailto:gnso-ppsai-pdp-wg at icann.org%3e>"
> >>>>>> Subject: Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section
> >>>>>> 1.3.3
> >>>>>>
> >>>>>> I would personally like to see if there is public traction for
> >>>>>> distinguishing between sites directly processing financial
> >>>>>> truncations and sites who use 3rd parties for processing
> >>>>>> financial transactions as this is a very important distinction. A
> >>>>>> simple and I hope non-controversial additional question to the
> >>>>>> ones below:
> >>>>>> If so, should domains which use a third party to process
> >>>>>> financial transactions (i.e Paypal, Stripe), and thus do not
> >>>>>> directly process financial information, be subject to the same
> >>>>>> restrictions?
> >>>>>> There are strong existing distinctions both in national laws and
> >>>>>> in regulations such as PCI-DSS between these two forms.
> >>>>>>
> >>>>>> -James Gannon
> >>>>>> 
> From:gnso-ppsai-pdp-wg-bounces at icann.org<mailto:gnso-ppsai-pdp-wg-bounces at icann.org> 
>
> >>>>>> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Graeme
> >>>>>> Bunton
> >>>>>> Sent: Tuesday, April 28, 2015 10:17 PM
> >>>>>> To: PPSAI
> >>>>>> Subject: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3
> >>>>>>
> >>>>>> Thanks to all WG members for a very productive call earlier
> >>>>>> today(and to Steve for his chairing acumen). The co-chairs and
> >>>>>> staff met this afternoon to tie down two loose ends from the call.
> >>>>>>
> >>>>>> Regarding the deadline for public comments on the Initial Report,
> >>>>>> we recognize there is considerable support for extending the
> >>>>>> public comment period to 60 days instead of the standard 40 days
> >>>>>> on which we have all been planning. We are prepared to agree to
> >>>>>> this, but with the caveat that this will have repercussions on
> >>>>>> the pace and intensity of our work once public comments have been
> >>>>>> received. Specifically, if the public comment deadline is
> >>>>>> extended until July 3 (60 days after our publication date of May
> >>>>>> 4), we will need to plan on at least weekly calls throughout July
> >>>>>> and August, some of which may need to be more than an hour in
> >>>>>> length, to review these comments and move toward a Final Report.
> >>>>>> Otherwise, we jeopardize the prospects for getting the Final
> >>>>>> Report in front of the GNSO council no later than the Dublin
> >>>>>> ICANN meeting. As was noted on the call today, many additional
> >>>>>> steps need to take place even after this WG issues its Final
> >>>>>> Report before any new accreditati
> > on
> >>>> system can be implemented, so the time pressure imposed by the
> >>>> expiration of the Interim Specification at the end of next year is
> >>>> already real.
> >>>>>> Also, as previously announced over the past few weeks, if any WG
> >>>>>> members (or group of members) wish to submit a brief separate or
> >>>>>> additional statement for inclusion in the package posted for
> >>>>>> public comment next Monday, such statements need to be received
> >>>>>> by staff no later than Thursday, April 30.
> >>>>>>
> >>>>>> Lastly, the other loose end involves proposed revisions to
> >>>>>> section 1.3.3 of the Initial Report, which were presented on the
> >>>>>> call earlier today but which we did not have time to discuss
> >>>>>> fully. We agree that this section could benefit from some
> >>>>>> revision, but believe it should take the form of greater
> >>>>>> concision, not additional presentation of arguments for the
> >>>>>> divergent positions. Thus we suggest that section 1.3.3 be
> >>>>>> revised to read as follows:
> >>>>>>
> >>>>>> ---
> >>>>>> Although the WG agreed that the mere fact that a domain name is
> >>>>>> registered by a commercial entity or by anyone conducting
> >>>>>> commercial activity should not preclude the use of P/P services ,
> >>>>>> there was disagreement over whether domain names that are
> >>>>>> actively used for commercial transactions (e.g. the sale or
> >>>>>> exchange of goods or services) should be prohibited from using
> >>>>>> P/P services. While most WG members did not believe such a
> >>>>>> prohibition is necessary or practical, some members believed that
> >>>>>> registrants of such domain names should not be able to use or
> >>>>>> continue using proxy or privacy services.
> >>>>>>
> >>>>>> For those that argued that it is necessary and practical to limit
> >>>>>> access to P/P services to exclude commercial entities, the
> >>>>>> following text was proposed to clarify and define their position:
> >>>>>> "domains used for online financial transactions for commercial
> >>>>>> purpose should be ineligible for privacy and proxy registrations."
> >>>>>>
> >>>>>> Public comment is therefore specifically invited on the following
> >>>>>> questions:
> >>>>>>
> >>>>>> * Should registrants of domain names associated with commercial
> >>>>>> activities and which are used for online financial transactions
> >>>>>> be prohibited from using, or continuing to use, privacy and proxy
> >>>>>> services?
> >>>>>> * If so, will it be useful to adopt a definition of
> >>>>>> "commercial" or "transactional" to define those domains for which
> >>>>>> P/P service registrations should be disallowed? And if so, what
> >>>>>> should the definition(s) be?"
> >>>>>> * Will it be necessary to make a distinction in the WHOIS data
> >>>>>> fields to be displayed as a result?
> >>>>>> ---
> >>>>>> Thanks,
> >>>>>>
> >>>>>> Graeme Bunton & Steve Metalitz
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>> --
> >>>>>>
> >>>>>> _________________________
> >>>>>>
> >>>>>> Graeme Bunton
> >>>>>>
> >>>>>> Manager, Management Information Systems
> >>>>>>
> >>>>>> Manager, Public Policy
> >>>>>>
> >>>>>> Tucows Inc.
> >>>>>>
> >>>>>> PH: 416 535 0123 ext 1634
> >>>>>>
> >>>>>>
> >>>>>>
> >>>>>> _______________________________________________
> >>>>>> Gnso-ppsai-pdp-wg mailing list
> >>>>>> 
> Gnso-ppsai-pdp-wg at icann.org<mailto:Gnso-ppsai-pdp-wg at icann.org>https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg> 
>
> >>>>>>
> >>>>>>
> >>>>>> _______________________________________________
> >>>>>> Gnso-ppsai-pdp-wg mailing list
> >>>>>> Gnso-ppsai-pdp-wg at icann.org<mailto:Gnso-ppsai-pdp-wg at icann.org 
> <mailto:Gnso-ppsai-pdp-wg at icann.org%3cmailto:Gnso-ppsai-pdp-wg at icann.org>>
> >>>>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg>
> >>>>>> _______________________________________________
> >>>>>> Gnso-ppsai-pdp-wg mailing list
> >>>>>> Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>
> >>>>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg>
> >>>> _______________________________________________
> >>>> Gnso-ppsai-pdp-wg mailing list
> >>>> Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>
> >>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg>
> >>>
> >>> _______________________________________________
> >>> Gnso-ppsai-pdp-wg mailing list
> >>> Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>
> >>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg>
> >
> >
> > _______________________________________________
> > Gnso-ppsai-pdp-wg mailing list
> > Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>
> > https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg>
>
> -- 
> _________________________
> Graeme Bunton
> Manager, Management Information Systems
> Manager, Public Policy
> Tucows Inc.
> PH: 416 535 0123 ext 1634
>
> _______________________________________________
> Gnso-ppsai-pdp-wg mailing list
> Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>
> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg 
> <https://protect-us.mimecast.com/r/w4cOGJpN8aqiFBeZDDCfM61L9zSPPQ8yJTOsuokgr0uUoFWQcH4C1vKnhAJR8I5CDUGd3f75FQZ0RrGQoOiumi5fkuGEeAdPoDjA3DGFVt5fCde0OuGcKsc4syb-86Vd3ZsMEWNubiso-WCMGJKqofC67xfNJVO1oqFPAmL7abae98k88hH_BDY04YcHIhprEG-vGcToOzkceYzCw4sYw77Sj8DHh1iwNuJPKagRVm5XkaPrKRnvsIqURxFUU964UWsThNMfSE_TxYg9ZhC-Fg>
>
>
>
> _______________________________________________
> Gnso-ppsai-pdp-wg mailing list
> Gnso-ppsai-pdp-wg at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg

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