[gnso-rpm-wg] Action Items, Slides and Notes from the Working Group call held earlier today

Tue Apr 18 04:03:41 UTC 2017

Paul M.,

I agree wholeheartedly with your email.  One of the problems we're running
into in this group and others is "data poverty," which leads to "metrics
poverty," and "evidence poverty."  The CCT-RT has been calling for more
useful data that can be used in an analytical manner.  The constituencies
of the Commercial Stakeholder Group -- IPC, BC and ISPCP -- recently sent a
letter to the Board along the same lines, and we hope for an ongoing
dialogue on this topic.

I think it would be an excellent idea if this WG, as we go along,
identifies the type of data and metrics we wish we had in this review, and
then includes in our report recommendations for collection and analysis of
this data, as well as appropriate release of the raw data to allow analysis
by others besides the ICANN organization.

This "lack-of-data-point" could be the first of several identified by our
WG.  Hopefully, future reviews as well as other efforts will have the data
we lack.

Best regards,

Greg

*Greg Shatan *C: 917-816-6428
S: gsshatan
Phone-to-Skype: 646-845-9428
gregshatanipc at gmail.com

On Mon, Apr 17, 2017 at 11:15 AM, <policy at paulmcgrady.com> wrote:

>
> Hi Rebecca,
>
> It's not that there is no amount of evidence that would convince us there
> is a problem.  It's that there is no evidence.  Registrars did not collect
> the data when a customer abandoned the attempted registration.  We all know
> this and Deloitte admitted it on the call with us.  There is no such thing
> as a data-less empirical inquiry; nor will a survey of
> registrant/abandoners - months later - yield the same quality of data that
> an "at-abandonment" survey would have.
>
> Perhaps instead going around endlessly on this loop about trying to prove
> something without data (which started at our in-person meeting in Dublin),
> perhaps we "data collection types" should be working together to build a
> set of data to be collected by registrars in the next round that would
> actually measure the reasons for abandonment after claims notice in future
> rounds/procedures so that we can fine tune the Claims Notice to get to the
> perfect balance.  I would be very happy to collaborate with you in that
> effort if you wish it.  I suspect that Kathy K. would join us as well,
> given our storied history with the text of the Claims Notice.
>
> Best,
> Paul
>
> -------- Original Message --------
> Subject: Re: [gnso-rpm-wg] Action Items, Slides and Notes from the
> Working Group call held earlier today
> From: Rebecca Tushnet <Rebecca.Tushnet at law.georgetown.edu>
> Date: Mon, April 10, 2017 5:01 am
> To: Kiran Malancharuvil <Kiran.Malancharuvil at markmonitor.com>
> Cc: "gnso-rpm-wg at icann.org" <gnso-rpm-wg at icann.org>
>
> I believe you've just made my point. If there is no amount of evidence
> that would convince you there's a problem, then this is not an
> empirical inquiry. I do agree that looking at outcomes alone is not
> helpful, given the over 90% rate of abandonment in response to claims
> notices; better understanding what is going on requires more
> transparency in the TMCH, which could be done by auditing or other
> mechanisms not limited to throwing it open to everyone.
> Rebecca Tushnet
> Georgetown Law
> 703 593 6759 <(703)%20593-6759>
>
>
> On Mon, Apr 10, 2017 at 12:49 AM, Kiran Malancharuvil
> <Kiran.Malancharuvil at markmonitor.com> wrote:
> > There is no way to determine, when examining an unregistered domain name
> that matches an entry in the clearinghouse, whether a TMCH claims notice
> (which does NOT block registration) deterred a legitimate right from being
> expressed.
> >
> > K
> >
> > Kiran Malancharuvil
> > Policy Counselor
> > MarkMonitor
> > 415-419-9138 <(415)%20419-9138> (m)
> >
> > Sent from my mobile, please excuse any typos.
> >
> >> On Apr 9, 2017, at 9:08 PM, Rebecca Tushnet <Rebecca.Tushnet at law.
> georgetown.edu> wrote:
> >>
> >> That doesn't seem responsive to my point about the evidence we have
> >> right now, which is not speculative: ten common words that are not
> >> famous marks in some field are the top 10 TMCH matches.
> >>
> >> Although I do not agree that your suggestion would provide evidence
> >> anywhere as useful as evidence specific to the TMCH, if we could get a
> >> consensus on what kind of evidence would demonstrate a problem, I'm
> >> certainly willing to get an RA on it. If we did find, say, 50% of the
> >> words you've suggested were either registered during sunrise or
> >> unregistered (which would be some evidence that presence in the TMCH
> >> deterred registration when a match notice was produced, especially for
> >> our top 10) in a sampling of, say, 10 new gTLDs, would you agree that
> >> there was a problem? If we found that 80% of the words were in those
> >> categories, would that be enough? 100%?
> >>
> >> If there is no level of evidence that would satisfy the people arguing
> >> that we shouldn't look for evidence of a problem because there isn't
> >> enough evidence of a problem, then I won't bother.
> >> Rebecca Tushnet
> >> Georgetown Law
> >> 703 593 6759 <(703)%20593-6759>
> >>
> >>
> >> On Sun, Apr 9, 2017 at 11:11 PM, Nahitchevansky, Georges
> >> <ghn at kilpatricktownsend.com> wrote:
> >>> Make a list of 50 common words that have real value, then do the
> research as I suggest. If you need help on value, you might start with
> common words that generated large amounts of money (business, sex, travel,
> music etc.) in the. Com world. If you want to add these other words, be my
> guest (make it 60 then or even a 100). The point is simply that we
> shouldn't be spending time arguing over something that is nothing more than
> speculation.
> >>> ‎
> >>> Original Message
> >>> From: Rebecca Tushnet
> >>> Sent: Sunday, April 9, 2017 9:33 PM
> >>> To: Nahitchevansky, Georges
> >>> Cc: Paul Keating; gnso-rpm-wg at icann.org
> >>> Subject: Re: [gnso-rpm-wg] Action Items, Slides and Notes from the
> Working Group call held earlier today
> >>>
> >>> So your argument is that the top ten matches in the audit report such
> >>> as hotel, cloud, and smart are not common words? If that is not
> >>> evidence worth investigating, you need to explain why. And even if
> >>> other common words like zebra, dog, and fight remain unregistered,
> >>> that doesn't really help someone who wants to talk about hotels,
> >>> clouds, or something smart.
> >>> Rebecca Tushnet
> >>> Georgetown Law
> >>> 703 593 6759 <(703)%20593-6759>
> >>>
> >>>
> >>> On Sun, Apr 9, 2017 at 6:57 PM, Nahitchevansky, Georges
> >>> <ghn at kilpatricktownsend.com> wrote:
> >>>> It would help fairly easily. First, registration in the TMCH does not
> mean in and of itself there is an abuse. Second, the whole straw man
> argument with no evidence is that brand owners are somehow overreaching and
> grabbing all common word domain names in the new extensions. Clearly, if
> brand owners are not the majority owners of common word domain names in the
> new extensions, then the whole house of cards argument that brand owners
> are taking advantage of the system falls apart. Third, you could easily
> tell in many instances whether a sunrise registration occurred. We know all
> of the sunrise dates, and whois for the most part show a date of creation.
> So if you wanted to cross reference you could easily see if a name was
> registered during a sunrise period. Fourth, what you will likely find from
> all this is that most common word domain in the new extensions are not
> registered to brand owners. If it turns out a majority are registered by
> domainers or speculators would we then go down the path of figuring out how
> that happened.
> >>>>
> >>>> Original Message
> >>>> ‎
> >>>> From: Rebecca Tushnet
> >>>> Sent: Sunday, April 9, 2017 4:38 PM
> >>>> To: Nahitchevansky, Georges
> >>>> Cc: Paul Keating; Rebecca Tushnet; gnso-rpm-wg at icann.org
> >>>> Subject: Re: [gnso-rpm-wg] Action Items, Slides and Notes from the
> Working Group call held earlier today
> >>>>
> >>>>
> >>>> How would this exercise indicate whether such registrations occurred
> with a TMCH claim or in spite of one, or neither? And aren't the top ten in
> the audit report also valuable?
> >>>>
> >>>> Sent from my phone. Apologies for terseness/typos.
> >>>>
> >>>>> On Apr 9, 2017, at 4:03 PM, Nahitchevansky, Georges <
> ghn at kilpatricktownsend.com> wrote:
> >>>>>
> >>>>> Again, I have to ask where is the evidence of widespread abuse. It
> seems like the whole argument is on the basis of some strawman argument
> that brand owners are using the TMCH to take common words out of
> circulation. I have yet to see anything that even remotely proves or
> suggests this in fact has occurred. Moreover, the idea that you have to see
> the TMCH data is a bit of a fishing expedition and will not establish that
> widespread abuse occurred (e.g., if Delta was registered by Delta Airlines
> in the TMCH it does in and of itself suggest an abuse of the system). What
> seems to be happening is that folks are positing a position with little to
> no evidence, then saying they need the data and making everybody spends
> gobs of time on issues that have previously been debated, esoteric concepts
> of human rights, natural justice, free speech and god knows what else.
> ‎Perhaps, instead of throwing out arguments there should be an effort to
> gather some real evidence for discussion. If we all decide to continue down
> this path then perhaps one simple idea would be to take a list of common
> words that could be perceived as being valuable such as business, music,
> car, travel, sex, money, ski, football, food, boat, truck, website, online
> etc and cross reference these words with the new gTld registrations to get
> some sense of who owns these domain names. Once there is some real data,
> then we can evaluate who owns most of these ( domainers, brand owners,
> speculators, industry groups etc.). This would not be a difficult exercise
> to do. Instead of multiple email chains, folks could take on one or two
> words from a compiled list and conduct this investigation using whois.
> >>>>>
> >>>>>
> >>>>>
> >>>>> Original Message
> >>>>> From: Paul Keating
> >>>>> Sent: Sunday, April 9, 2017 3:31 PM
> >>>>> To: Rebecca Tushnet
> >>>>> Cc: gnso-rpm-wg at icann.org
> >>>>> Subject: Re: [gnso-rpm-wg] Action Items, Slides and Notes from the
> Working Group call held earlier today
> >>>>>
> >>>>>
> >>>>> I see clear speech issues as well. It is not possible to formulate a
> position that no domain name represents an expression of speech.
> >>>>>
> >>>>> Nor is it sufficient to ignore this issue because there are other
> forums available to channel the desired expression.
> >>>>>
> >>>>> The goal here is not to protect the obvious but rather to protect
> the speech that is possible but not yet obvious.
> >>>>>
> >>>>> So this is not a rabbit hole.
> >>>>> The TMCH was developed based upon an assumption that it would not be
> abused and would not unreasonably infringe upon speech.
> >>>>> We must determine if abuse has occurred.
> >>>>> The contents of the TMCH database is very much relevant.
> >>>>> If we are to be denied information relevant to the database we must
> assume the worst.
> >>>>> For if the IP crowd wants us to believe - there is no problem, - it
> is encumbrance upon then to prove it,
> >>>>> Freedoms of speech is simply too important to ignore.
> >>>>>
> >>>>> For if you take away all of my rights save the freedom of speech I
> will quickly recover those rights lost......Jefferson.
> >>>>>
> >>>>> Sent from my iPad
> >>>>>
> >>>>>> On 9 Apr 2017, at 19:08, Rebecca Tushnet <Rebecca.Tushnet at law.
> georgetown.edu> wrote:
> >>>>>>
> >>>>>> Following up on my post from yesterday, let's make this more
> specific:
> >>>>>> I see clear free speech issues that can arise from an attempt to
> >>>>>> register cloud.X (where X is a new gTLD), smart.X, love.X, luxury.X,
> >>>>>> nyc.x and the like. Those along with forex, hotel, one, london, and
> >>>>>> abc, are the top ten downloads from the TMCH. Of course, as Michael
> >>>>>> K. indicates, we'd know more about how many dictionary terms are
> beingdom
> >>>>>> blocked if there were more transparency, but what we do know right
> now
> >>>>>> should be concerning.
> >>>>>> Rebecca Tushnet
> >>>>>> Georgetown Law
> >>>>>> 703 593 6759 <(703)%20593-6759>
> >>>>>>
> >>>>>>
> >>>>>>> On Sun, Apr 9, 2017 at 12:51 PM, Greg Shatan <
> gregshatanipc at gmail.com> wrote:
> >>>>>>> My responses are in-line.
> >>>>>>>
> >>>>>>> G
> >>>>>>> reg
> >>>>>>>
> >>>>>>>
> >>>>>>> On Sat, Apr 8, 2017 at 1:39 PM, Michael Karanicolas <
> mkaranicolas at gmail.com>
> >>>>>>> wrote:
> >>>>>>>>
> >>>>>>>> Hi,
> >>>>>>>>
> >>>>>>>> I think that Michael Graham brings up a salient point in terms of
> falling
> >>>>>>>> too far down the rabbit hole on background matters, but I should
> address a
> >>>>>>>> few issues in response to questions that were directly asked of
> me.
> >>>>>>>>
> >>>>>>>> First off, while Greg is correct to point out that the UDHR is not
> >>>>>>>> formally legally binding as a UNGA resolution, it is (quite
> literally) the
> >>>>>>>> textbook example of customary international law. I realize that
> can be a
> >>>>>>>> fuzzy concept to rely on, but luckily I don't have to rely on it
> because the
> >>>>>>>> freedom of expression protections in the UDHR are substantially
> identical to
> >>>>>>>> those found in the ICCPR, which IS a formally binding treaty.
> >>>>>>>
> >>>>>>>
> >>>>>>> Binding on states. Of course, ICANN is not a state. Luckily, we
> have the
> >>>>>>> new human rights Core Value in the ICANN Bylaws, Section
> 1.2(b)(viii), which
> >>>>>>> states that one of ICANN's eight Core Values (which must be
> subject to a
> >>>>>>> balancing analysis involving all Core Values). is "within the
> scope of its
> >>>>>>> Mission and other Core Values, respecting internationally
> recognized human
> >>>>>>> rights as required by applicable law." The Bylaw specifically
> notes that
> >>>>>>> "This Core Value does not create, and shall not be interpreted to
> create,
> >>>>>>> any obligation on ICANN outside its Mission, or beyond obligations
> found in
> >>>>>>> applicable law." As such, ICANN's obligations do not go beyond
> what would
> >>>>>>> otherwise be required by applicable law. There's been a great deal
> of
> >>>>>>> discussion of this in CCWG-Accountability WS1 and in the Human
> Rights
> >>>>>>> Subgroup of WS2, so I won't go further into the concepts here,
> which would
> >>>>>>> be a rabbit hole down a rabbit hole from the viewpoint of this
> group.
> >>>>>>>>
> >>>>>>>>
> >>>>>>>> Also, while I appreciate Greg's caution against "cherrypicking"
> by viewing
> >>>>>>>> Article 19 in isolation, in this context that argument is just a
> >>>>>>>> smokescreen.
> >>>>>>>
> >>>>>>>
> >>>>>>> Concerns about cherrypicking are in no way a "smokescreen" --
> unless the
> >>>>>>> reference is to the saying "where there's smoke, there's fire."
> John
> >>>>>>> Levine's blog nicely expressed a number of concerns about such
> >>>>>>> cherrypicking, especially for what he calls the "fashionable human
> rights,"
> >>>>>>> so I won't repeat them here. It is important to keep in mind, as
> Michael
> >>>>>>> notes, that "human rights are fundamentally about balance," so
> perhaps we
> >>>>>>> are not so far apart, as "balance" and "cherrypicking" are mutually
> >>>>>>> exclusive concepts.
> >>>>>>>
> >>>>>>> Of course the UDHR and ICCPR need to be viewed holistically - that
> >>>>>>> understanding in no way supports an argument that domains are not
> speech.
> >>>>>>>
> >>>>>>> I'm puzzled by the second part of this sentence. I think this
> point is
> >>>>>>> unrelated to the issue of whether or not domain names are speech,
> so it
> >>>>>>> neither supports nor negates any argument on that topic.
> >>>>>>>
> >>>>>>> There's no conflict between believing in personal privacy as
> protected by
> >>>>>>> the ICCPR (as I do), and believing in the need to combat hate
> speech as
> >>>>>>> spelled out in the ICCPR (as I do), and believing in freedom of
> expression.
> >>>>>>> Human rights are fundamentally about balance (more on that in a
> second).
> >>>>>>>
> >>>>>>> There are certainly conflicts (e.g., between combating hate speech
> and
> >>>>>>> supporting free speech); the issue is how to balance these
> countervailing
> >>>>>>> issues to resolve these conflicts.
> >>>>>>>>
> >>>>>>>>
> >>>>>>>> With regard to Ballantyne, Davidson & McIntyre, I probably should
> have
> >>>>>>>> been more specific in my original post. Of course, as Greg notes,
> the case
> >>>>>>>> is not specifically about domain names - which would be a pretty
> niche area
> >>>>>>>> for the Human Rights Committee to dig into. But the decision
> contains the
> >>>>>>>> clearest statement of the extent of what constitutes "speech"
> under the
> >>>>>>>> ICCPR, namely that Article 19: "must be interpreted as
> encompassing every
> >>>>>>>> form of subjective ideas and opinions capable of transmission to
> others".
> >>>>>>>> It's an incredibly broad formulation - to cover virtually
> anything that
> >>>>>>>> conveys meaning. I, personally, can't see an interpretation of
> that that
> >>>>>>>> doesn't include domain names.
> >>>>>>>
> >>>>>>>
> >>>>>>> This is not really that broad a formulation -- it dovetails nicely
> with the
> >>>>>>> concept of "expressive speech" under US law (as in the excerpt
> from Gibson).
> >>>>>>> Furthermore, there is a considerable difference between the speech
> >>>>>>> constituting "subjective ideas and opinions" protected in
> Ballantyne and the
> >>>>>>> "incredibly broad formulation" that would elevate "virtually
> anything that
> >>>>>>> conveys meaning." "Subjective ideas and opinions" in no way
> embraces domain
> >>>>>>> names per se; whether and to what extent it embraces domain names
> is
> >>>>>>> certainly not a question answered in Ballantyne.
> >>>>>>>>
> >>>>>>>>
> >>>>>>>> With regard to Gibson v. Texas - I don't want to dig too deeply
> into this
> >>>>>>>> because, honestly, US law is not my specialisation. But I think
> that part of
> >>>>>>>> the disconnect between our positions is due to a particular
> aspect of the
> >>>>>>>> American understanding of free speech, that's sort of different
> to how it's
> >>>>>>>> understood virtually everywhere else. Under most systems,
> including the
> >>>>>>>> international example I just cited, virtually everything is
> classed as
> >>>>>>>> "speech", and then there's a balancing as to whether particular
> restrictions
> >>>>>>>> are justified. But because of the absolutist way the US
> Constitution is
> >>>>>>>> phrased ("Congress shall make no law"), the Courts have had to go
> through
> >>>>>>>> some unusual legal gymnastics to find that speech that they feel
> justified
> >>>>>>>> restricting isn't actually speech.
> >>>>>>>
> >>>>>>>
> >>>>>>> Simply reading the excerpt from Gibson v. Texas in my prior email
> shows that
> >>>>>>> this "speech/not speech" analysis is incorrect. Gibson, and the
> cases cited
> >>>>>>> in it, distinguish between protected speech and speech that that
> is "not to
> >>>>>>> be protected." Specifically, Gibson mentions that "courts have
> held that
> >>>>>>> domain names that use trademarks to misidentify the source of a
> product are
> >>>>>>> outside the reach of the First Amendment" and also cites a line of
> cases
> >>>>>>> where "the domain name was actually held not to be protected
> speech because
> >>>>>>> it was not expressive, not because it was misleading." More
> broadly, the
> >>>>>>> idea that the US approach to free speech is anomalous is
> incorrect. Of
> >>>>>>> course, free speech regimes vary broadly throughout the world --
> so there's
> >>>>>>> no such thing as a single "understanding of free speech...
> virtually
> >>>>>>> everywhere else" aside from the US. Unfortunately, there are many
> places in
> >>>>>>> the world where there is no understanding of free speech at all.)
> If the US
> >>>>>>> approach to free speech tends to be different, it is in a greater
> tolerance
> >>>>>>> for controversial and offensive speech (what John Levine calls "the
> >>>>>>> absolutist U.S. first amendment approach"). This is why US law
> doesn't find
> >>>>>>> it so easy to restrict alleged "hate speech" as "virtually
> everywhere else",
> >>>>>>> and also why I can't be so comfortable in finding "no conflict"
> between free
> >>>>>>> speech and restricting hate speech. (And I say this as a member of
> a group
> >>>>>>> that is finding itself increasingly on the wrong end of both
> offensive
> >>>>>>> speech and hate speech.)
> >>>>>>>>
> >>>>>>>>
> >>>>>>>> So, without trying to belabour these issues, my point in the
> above is not
> >>>>>>>> to try and invalidate the trademark protection system - indeed,
> Greg's quite
> >>>>>>>> right to point out that trademarks are also speech. My point here
> is simply
> >>>>>>>> to try and demonstrate that there are free speech issues at play.
> >>>>>>>
> >>>>>>>
> >>>>>>> It's clear that this is false as a general statement, unless this
> is meant
> >>>>>>> as a statement that could possibly true in a large enough sample,
> like
> >>>>>>> "people are 7 feet tall". Whether one looks at Ballantyne or
> Gibson, one
> >>>>>>> sees clear distinctions being drawn being "subjective ideas and
> opinions"
> >>>>>>> and speech that is "not expressive" or "inherently misleading."
> This is
> >>>>>>> probably a good time to note that the UDHR and the ICCPR both
> refer to
> >>>>>>> "freedom of expression" and not to "free speech." So, it would be
> more
> >>>>>>> proper to discuss whether "expressive speech" is at issue, not
> whether the
> >>>>>>> over-broad "virtually anything that conveys meaning" is at issue,
> before we
> >>>>>>> even get to the question of whether free speech issues are at
> play, to what
> >>>>>>> extent, and how that might affect any discussion that is relevant
> to this
> >>>>>>> Working Group.
> >>>>>>>
> >>>>>>>>
> >>>>>>>> To me, that's not a controversial point - and if we can agree on
> that,
> >>>>>>>
> >>>>>>>
> >>>>>>> I don't think we can agree on that, and certainly not as an assumed
> >>>>>>> agreement from which one can proceed blithely on. Rather, I think
> that is
> >>>>>>> an elemental aspect of the discussion, and as noted above, at best
> >>>>>>> "controversial" and possibly sometimes true, and at worst false
> (at least as
> >>>>>>> a general statement).
> >>>>>>>
> >>>>>>> As an aside, it's worth noting what Article 19 of the ICCPR
> actually
> >>>>>>> protects: "the right to hold opinions without interference" and
> "the right
> >>>>>>> to freedom of expression; this right shall include freedom to
> seek, receive
> >>>>>>> and impart information and ideas of all kinds, regardless of
> frontiers,
> >>>>>>> either orally, in writing or in print, in the form of art, or
> through any
> >>>>>>> other media of his choice." I admit to struggling to find
> instances where
> >>>>>>> the right to hold opinions or to express oneself freely is truly
> being
> >>>>>>> violated in this context -- especially in a world where holding or
> >>>>>>> expressing an opinion can come under threat of oppression,
> suppression,
> >>>>>>> violence, imprisonment or worse. As someone who strongly supports
> First
> >>>>>>> Amendment rights and who has worked on litigation defending First
> Amendment
> >>>>>>> freedoms, I wonder whether this discussion trivializes free speech
> concerns
> >>>>>>> rather than promoting them. That is not to dismiss the possibility
> of free
> >>>>>>> speech concerns here, but just to say that, to the extent there is
> a viable
> >>>>>>> point here, it pales in comparison to the significant freedom of
> expression
> >>>>>>> concerns elsewhere (including elsewhere on the Internet, where
> access to
> >>>>>>> websites with undesirable opinions or expression, or even to the
> Internet as
> >>>>>>> a whole, is under escalating attack).
> >>>>>>>
> >>>>>>>
> >>>>>>>>
> >>>>>>>> then that is relevant to the transparency question, since in my
> mind it
> >>>>>>>> bolsters arguments for why openness in the system is important.
> >>>>>>>
> >>>>>>>
> >>>>>>> I don't get the logical leaps here, from the possibility of a free
> speech
> >>>>>>> issue, to the claimed relevance to the transparency question, to
> the even
> >>>>>>> more attenuated idea that this bolsters arguments regarding
> changing access
> >>>>>>> rules for the TMCH. In other words, I don't really think that any
> of this
> >>>>>>> changes the discussion on TMCH database access, nor do I really
> think it is
> >>>>>>> relevant to any of the work we are undertaking right now. That is
> not to
> >>>>>>> say that this is an uninteresting discussion (or else I would not
> have
> >>>>>>> engaged in it), just that it is a rabbit hole in relation to our
> work.
> >>>>>>>>
> >>>>>>>>
> >>>>>>>> Best,
> >>>>>>>>
> >>>>>>>> Michael
> >>>>>>>>
> >>>>>>>> On Fri, Apr 7, 2017 at 2:19 AM, Greg Shatan <
> gregshatanipc at gmail.com>
> >>>>>>>> wrote:
> >>>>>>>>>
> >>>>>>>>> It's important to keep in mind that the rights set forth in the
> UDHR are
> >>>>>>>>> interrelated and interdependent, so understanding the
> applicability of any
> >>>>>>>>> one Article also requires understanding the applicability of the
> other
> >>>>>>>>> rights in the UDHR, including some which may be countervailing
> to others.
> >>>>>>>>> Looking at Article 19 in isolation is "cherrypicking." A recent
> CircleID
> >>>>>>>>> article by John Levine is quite enlightening on this very point:
> >>>>>>>>>
> >>>>>>>>> http://www.circleid.com/posts/20170401_human_rights_and_
> regular_internet_users/
> >>>>>>>>>
> >>>>>>>>> The article is short, but for those who don't get there, this
> quote goes
> >>>>>>>>> to the heart of the matter: "it devalues the whole topic of
> human rights to
> >>>>>>>>> pay attention only to a few fashionable rights, while ignoring
> ones that are
> >>>>>>>>> at least as important in people's daily lives."
> >>>>>>>>>
> >>>>>>>>> (It should also be noted that the UDHR, while adopted by the
> United
> >>>>>>>>> Nations and widely used, does not constitute some form of
> "universal law"
> >>>>>>>>> nor is it universally accepted.)
> >>>>>>>>>
> >>>>>>>>> The case mentioned, Gibson v. Texas, has portions that are
> directly
> >>>>>>>>> applicable to the discussion at hand. However, the Gibson
> decision actually
> >>>>>>>>> distinguishes cases involving trademarks from the situation in
> that case.
> >>>>>>>>> As a matter of fact, the Gibson case tells us that there are at
> least two
> >>>>>>>>> types of domain names that do not constitute speech protected by
> the First
> >>>>>>>>> Amendment: domain names that infringe trademarks, and domain
> names that do
> >>>>>>>>> not constitute "expressive speech."
> >>>>>>>>>
> >>>>>>>>> (In other words, there can be no "freedom of expression" issue
> when the
> >>>>>>>>> speech is not expressive.)
> >>>>>>>>>
> >>>>>>>>> Before getting to an excerpt from the case, it's important to
> note that
> >>>>>>>>> the court did not find that domain names are speech, much less
> find that
> >>>>>>>>> domain names are speech protected by the First Amendment. The
> court made no
> >>>>>>>>> findings about all domain names. Rather, the court assumed, for
> the purpose
> >>>>>>>>> of considering a motion to dismiss, that the domain name in
> question
> >>>>>>>>> (texasworkerscomplaw.com) constituted commercial speech. It's
> also
> >>>>>>>>> important to note that the case involved the Constitutionality
> of a law that
> >>>>>>>>> broadly prohibited the use of the terms "Texas" and "workers
> comp," and not
> >>>>>>>>> a trademark infringement matter.
> >>>>>>>>>
> >>>>>>>>> The excerpt is quite instructive:
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> In order for speech to fall outside of the First Amendment’s
> protection,
> >>>>>>>>> the speech must either be “inherently likely to deceive,” or
> “the record
> >>>>>>>>> [must] indicate[] that a particular form or method of
> advertising has in
> >>>>>>>>> fact been deceptive.” R.M.J., 455 U.S. at 202.
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> Appellees primarily argue that the Texas statute is
> constitutional
> >>>>>>>>> because Gibson’s domain name amounts to inherently misleading
> speech. In
> >>>>>>>>> support of this proposition, they cite to a series of cases in
> which courts
> >>>>>>>>> have held that domain names that use trademarks to misidentify
> the source of
> >>>>>>>>> a product are outside the reach of the First Amendment. The case
> law cited
> >>>>>>>>> by Appellees, however, is unique to the field of trademark
> infringement,
> >>>>>>>>> see, e.g., Coca-Cola Co. v. Purdy, 382 F.3d 774 (8th Cir. 2004),
> and does
> >>>>>>>>> not necessarily extend to a case such as this one, where Texas is
> >>>>>>>>> prohibiting Gibson from using words that are otherwise in the
> public
> >>>>>>>>> domain.[1] Cases involving trademark infringement involve
> inherently
> >>>>>>>>> deceptive speech because they contain a significant risk that an
> infringing
> >>>>>>>>> party will freeload on the goodwill that has been created by the
> original
> >>>>>>>>> trademark. See Friedman, 440 U.S. at 11-16. No such risk is
> present here.
> >>>>>>>>> Texas has made no showing that its own talents and energy
> contributed to the
> >>>>>>>>> creation of any goodwill in the name “texasworkerscomplaw.com.”
> See San
> >>>>>>>>> Francisco Arts & Athletics, Inc. v. U.S. Olympic Comm., 483 U.S.
> 522, 533-34
> >>>>>>>>> (1987). Instead the regulation at issue is forward-thinking;
> intended to
> >>>>>>>>> prohibit confusion for individuals seeking information from the
> government
> >>>>>>>>> agency. It is not retrospective in the same way as most trademark
> >>>>>>>>> litigation, which is generally intended to preserve the
> reputation that has
> >>>>>>>>> been built upon a trade name. See Friedman, 440 U.S. at 11-16.
> Accordingly,
> >>>>>>>>> the case law cited by Appellees is inapposite.
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> ________________________________
> >>>>>>>>>
> >>>>>>>>> [1] In most of the cases cited by Appellees the domain name was
> actually
> >>>>>>>>> held not to be protected speech because it was not expressive,
> not because
> >>>>>>>>> it was misleading. See, e.g., Planned Parenthood Fed’n of Am. v.
> Bucci, No.
> >>>>>>>>> 97-cv-0629, 1997 WL 133313, at *10-11 (S.D.N.Y. Mar. 24, 1997);
> Morrison &
> >>>>>>>>> Foerster, LLP v. Wick, 94 F.Supp. 2d 1125, 1135 (D. Colo. 2000);
> Jews for
> >>>>>>>>> Jesus v. Brodsky, 993 F.Supp. 282, 286 n.1 (D.N.J. 1998). Here,
> in contrast,
> >>>>>>>>> Gibson’s domain name is expressive because it does more than
> simply mimic
> >>>>>>>>> the state agency’s website or identify a source of Texas Workers’
> >>>>>>>>> Compensation Law. See Planned Parenthood, 1997 WL 133313, at
> *11. The domain
> >>>>>>>>> name is intended to direct visitors to a forum for discussing
> workers’
> >>>>>>>>> compensation laws and their potential reform, as well as to
> convey to
> >>>>>>>>> visitors the message of Gibson’s website as a whole.
> Accordingly, in the
> >>>>>>>>> context of this case, the domain name is “‘sufficiently imbued
> with the
> >>>>>>>>> elements of communication’” to place it in the realm of
> expressive speech.
> >>>>>>>>> Name.Space, Inc. v. Network Solutions, Inc., 202 F.3d 573, 585
> (2d Cir.
> >>>>>>>>> 2000) (quoting Spence v. Washington, 418 U.S. 405, 409-10
> (1974)).
> >>>>>>>>>
> >>>>>>>>> Greg Shatan
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> Greg Shatan
> >>>>>>>>> C: 917-816-6428 <(917)%20816-6428>
> >>>>>>>>> S: gsshatan
> >>>>>>>>> Phone-to-Skype: 646-845-9428 <(646)%20845-9428>
> >>>>>>>>> gregshatanipc at gmail.com
> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>> On Thu, Apr 6, 2017 at 10:58 PM, Michael Karanicolas
> >>>>>>>>> <mkaranicolas at gmail.com> wrote:
> >>>>>>>>>>
> >>>>>>>>>> It's an interesting question. Different national courts have
> handled
> >>>>>>>>>> the issue in different ways. In the US, for example, the Fifth
> Circuit
> >>>>>>>>>> Court of Appeals found in Gibson v. Texas that domain names are
> >>>>>>>>>> protected as speech under the 1st amendment. But freedom of
> expression
> >>>>>>>>>> in the US context tends to be understood differently than
> elsewhere,
> >>>>>>>>>> since the way it's protected under the US constitution is a bit
> >>>>>>>>>> different from how most constitutions frame their equivalent
> >>>>>>>>>> protections.
> >>>>>>>>>>
> >>>>>>>>>> That said - when you're asking about Article 19, the discussion
> comes
> >>>>>>>>>> at the international level where, as far as I know, there's no
> single
> >>>>>>>>>> authoritative treatment to point to. Generally, discussions of
> Article
> >>>>>>>>>> 19 by standard setting bodies tend to focus on the sharper and
> more
> >>>>>>>>>> controversial issues: hate speech, defamation, national security
> >>>>>>>>>> restrictions, etc.
> >>>>>>>>>>
> >>>>>>>>>> However - there's a clear and well developed test for
> restrictions on
> >>>>>>>>>> freedom of expression that's built right into the ICCPR, and
> which
> >>>>>>>>>> applies equally to all restrictions, namely that they should
> be: (1)
> >>>>>>>>>> provided by Law (which includes a requirement for clarity and
> >>>>>>>>>> transparency), (2) fulfill a legitimate purpose, and (3) be
> necessary
> >>>>>>>>>> and proportionate to the achievement of that goal. If we
> establish
> >>>>>>>>>> that domain names qualify as speech under Article 19 (which,
> according
> >>>>>>>>>> to UN Human Rights Committee in Ballantyne, Davidson & McIntyre
> v.
> >>>>>>>>>> Canada, is a fairly sure interpretation), then understanding the
> >>>>>>>>>> applicability of Article 19 just means understanding that three
> part
> >>>>>>>>>> test.
> >>>>>>>>>>
> >>>>>>>>>> If you want more info, I'd recommend this briefing note as a
> useful
> >>>>>>>>>> (and concise!) introduction to restrictions on freedom of
> expression
> >>>>>>>>>> under Article 19:
> >>>>>>>>>>
> >>>>>>>>>> http://www.law-democracy.org/live/wp-content/uploads/2015/
> 02/foe-briefingnotes-2.pdf
> >>>>>>>>>>
> >>>>>>>>>> Or if you want to go into a little more depth, you can check
> out this
> >>>>>>>>>> one:
> >>>>>>>>>> http://www.law-democracy.org/live/wp-content/uploads/2012/
> 08/Paper-on-Restrictions.10.03.22.rev_.pdf
> >>>>>>>>>>
> >>>>>>>>>> Unfortunately - neither is specifically about domain names, but
> the
> >>>>>>>>>> discussion is basically analogous to how we understand other
> kinds of
> >>>>>>>>>> restrictions and protections.
> >>>>>>>>>>
> >>>>>>>>>> On Thu, Apr 6, 2017 at 6:50 PM, Michael Graham (ELCA)
> >>>>>>>>>> <migraham at expedia.com> wrote:
> >>>>>>>>>>> Michael:
> >>>>>>>>>>>
> >>>>>>>>>>> Where can I find a discussion how Article 19 and similar
> "Freedom of
> >>>>>>>>>>> Expression" requirements relate to or impact the registration
> of domain
> >>>>>>>>>>> names?
> >>>>>>>>>>>
> >>>>>>>>>>>
> >>>>>>>>>>> Michael R.
> >>>>>>>>>>>
> >>>>>>>>>>> Article 19.
> >>>>>>>>>>> Everyone has the right to freedom of opinion and expression;
> this
> >>>>>>>>>>> right includes freedom to hold opinions without interference
> and to seek,
> >>>>>>>>>>> receive and impart information and ideas through any media and
> regardless of
> >>>>>>>>>>> frontiers.
> >>>>>>>>>>>
> >>>>>>>>>>> -----Original Message-----
> >>>>>>>>>>> From: gnso-rpm-wg-bounces at icann.org
> >>>>>>>>>>> [mailto:gnso-rpm-wg-bounces at icann.org
> <gnso-rpm-wg-bounces at icann.org>] On Behalf Of Michael Karanicolas
> >>>>>>>>>>> Sent: Thursday, April 06, 2017 5:53 AM
> >>>>>>>>>>> To: J. Scott Evans <jsevans at adobe.com>
> >>>>>>>>>>> Cc: gnso-rpm-wg at icann.org
> >>>>>>>>>>> Subject: Re: [gnso-rpm-wg] Action Items, Slides and Notes from
> the
> >>>>>>>>>>> Working Group call held earlier today
> >>>>>>>>>>>
> >>>>>>>>>>> Once again - I have to jump in. Freedom of expression is very
> much a
> >>>>>>>>>>> universal concept:
> >>>>>>>>>>>
> >>>>>>>>>>> http://www.un.org/en/universal-declaration-human-rights/
> >>>>>>>>>>> http://www.ohchr.org/EN/ProfessionalInterest/Pages/CCPR.aspx
> >>>>>>>>>>>
> >>>>>>>>>>> That's why we call them "human" rights. Not "American" rights.
> >>>>>>>>>>>
> >>>>>>>>>>>
> >>>>>>>>>>> On Thu, Apr 6, 2017 at 9:49 AM, J. Scott Evans via gnso-rpm-wg
> >>>>>>>>>>> <gnso-rpm-wg at icann.org> wrote:
> >>>>>>>>>>>> The law is clear: an exact match isn't free speech. It is
> trademark
> >>>>>>>>>>>> infringement. A domain that coveys a message (e.g., hotels
> suck.com) is free
> >>>>>>>>>>>> speech and protected accordingly. Also, "free speech" is a US
> constitutional
> >>>>>>>>>>>> concept adopted by some countries, but it is not a universal
> legal concept.
> >>>>>>>>>>>> Perhaps universal free speech is aspirational, but it is not
> reality.
> >>>>>>>>>>>>
> >>>>>>>>>>>> Sent from my iPhone
> >>>>>>>>>>>>
> >>>>>>>>>>>>> On Apr 6, 2017, at 5:44 AM, George Kirikos <icann at leap.com>
> wrote:
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> I'm not sure where J. Scott is getting his "facts", but my
> company
> >>>>>>>>>>>>> doesn't "arbitrage" nor has it registered *any* new gTLD
> domain
> >>>>>>>>>>>>> names
> >>>>>>>>>>>>> (and I have no desire for any), nor is it a "bad actor." If
> you have
> >>>>>>>>>>>>> proof that my company is a "bad actor", put it forward,
> rather than
> >>>>>>>>>>>>> sling unsupported innuendo.
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> The whole point is that the "barriers" are put forth as
> *required*
> >>>>>>>>>>>>> to
> >>>>>>>>>>>>> deal with so-called "bad actors", but are instead used to
> advantage
> >>>>>>>>>>>>> certain groups, far beyond the "damage" that is claimed to
> be caused
> >>>>>>>>>>>>> by the "bad actors."
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> I don't want to delve into politics, but some might see
> parallels to
> >>>>>>>>>>>>> certain government measures in some countries, where a
> "problem" is
> >>>>>>>>>>>>> claimed, but a Draconian solution is applied to deal with it.
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> When it comes to the sunrise periods for new gTLDs, the
> "problem" is
> >>>>>>>>>>>>> claimed to be cybersquatting, but instead of relying on
> curative
> >>>>>>>>>>>>> rights, the Sunrise policy went too far and gave too many
> advantages
> >>>>>>>>>>>>> to TM holders, essentially creating an unlevel playing field
> between
> >>>>>>>>>>>>> *good actors* and TM holders.
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> Free speech means *no prior restraints* (with very rare
> exceptions),
> >>>>>>>>>>>>> but harsh penalties for unlawful speech (curative rights).
> >>>>>>>>>>>>>
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> https://na01.safelinks.protection.outlook.com/?url=
> https%3A%2F%2Fwww.
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> law.cornell.edu%2Fwex%2Fprior_restraint&data=02%7C01%7C%
> 7C811dc6e8437
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> 245583fce08d47cea9d30%7Cfa7b1b5a7b34438794aed2c178de
> cee1%7C0%7C0%7C63
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> 6270794483518369&sdata=IyEiG%2FsY%
> 2BTgJkYPGzDiGtCEbfBWA4SVgJ4g%2FOWfC
> >>>>>>>>>>>>> H7s%3D&reserved=0
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> Sincerely,
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> George Kirikos
> >>>>>>>>>>>>> 416-588-0269 <(416)%20588-0269>
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> https://na01.safelinks.protection.outlook.com/?url=
> http%3A%2F%2Fwww.l
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> eap.com%2F&data=02%7C01%7C%7C811dc6e8437245583fce08d47cea
> 9d30%7Cfa7b1
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> b5a7b34438794aed2c178decee1%7C0%7C0%7C636270794483518369&
> sdata=6BJPNx
> >>>>>>>>>>>>> olmCYrJK3jZ5%2B7ZFJhorIvFPrA11%2FRit4QYdY%3D&reserved=0
> >>>>>>>>>>>>>
> >>>>>>>>>>>>>
> >>>>>>>>>>>>>> On Thu, Apr 6, 2017 at 8:08 AM, J. Scott Evans <
> jsevans at adobe.com>
> >>>>>>>>>>>>>> wrote:
> >>>>>>>>>>>>>> The same logic applies to you and other domaines,
> cybersquatters,
> >>>>>>>>>>>>>> speculators and small businesses. The fact that you want to
> arbitrage in
> >>>>>>>>>>>>>> terms that are also trademarks is your choice and you have
> to deal with the
> >>>>>>>>>>>>>> barriers put in place to deal with the bad actors.
> >>>>>>>>>>>>>>
> >>>>>>>>>>>>>> Sent from my iPhone
> >>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> On Apr 6, 2017, at 4:59 AM, George Kirikos <icann at leap.com>
> wrote:
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> Hi folks,
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>>> On Thu, Apr 6, 2017 at 4:19 AM, Beckham, Brian
> >>>>>>>>>>>>>>>> <brian.beckham at wipo.int> wrote:
> >>>>>>>>>>>>>>>> Finally, since the chart references the EFF letter, it is
> worth
> >>>>>>>>>>>>>>>> mentioning here that the fact that a trademark owner may
> pay
> >>>>>>>>>>>>>>>> (sometimes extremely high
> >>>>>>>>>>>>>>>> amounts) to defensively register a domain name exactly
> matching
> >>>>>>>>>>>>>>>> its trademark in a Sunrise process (and thereby taking it
> “off
> >>>>>>>>>>>>>>>> the
> >>>>>>>>>>>>>>>> market”) does not prevent free expression, which may be
> >>>>>>>>>>>>>>>> undertaken
> >>>>>>>>>>>>>>>> in countless other ways. The number of terms that may be
> >>>>>>>>>>>>>>>> appended
> >>>>>>>>>>>>>>>> to a trademark (not to mention typos) to engage in all
> manner of
> >>>>>>>>>>>>>>>> speech – fair or otherwise – is, practically-speaking,
> all but
> >>>>>>>>>>>>>>>> limitless.
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> By that "logic", the number of terms that may be appended
> to a
> >>>>>>>>>>>>>>> common dictionary word (not to mention typos) to create a
> >>>>>>>>>>>>>>> trademarkable brand is, practically-speaking, all but
> limitless.
> >>>>>>>>>>>>>>> :-)
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> In other words, those creating a new brand/trademark
> certainly had
> >>>>>>>>>>>>>>> the opportunity to create a longer (and thus inferior)
> alternative
> >>>>>>>>>>>>>>> to a commonly used dictionary word or other common term.
> The fact
> >>>>>>>>>>>>>>> that they decided instead to choose a common term that is
> widely
> >>>>>>>>>>>>>>> used by the public shouldn't give them any priority access
> in a
> >>>>>>>>>>>>>>> launch of a new gTLD.
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> "I created a problem for myself, and I want ICANN to fix
> it" is
> >>>>>>>>>>>>>>> the
> >>>>>>>>>>>>>>> essence of the sunrise argument for commonly used terms,
> like
> >>>>>>>>>>>>>>> dictionary words and short acronyms.
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> Sincerely,
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> George Kirikos
> >>>>>>>>>>>>>>> 416-588-0269 <(416)%20588-0269>
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> https://na01.safelinks.protection.outlook.com/?url=
> http%3A%2F%2Fwww
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> .leap.com%2F&data=02%7C01%7C%
> 7C2b7c1e08334543cacbff08d47ce46e63%7Cf
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> a7b1b5a7b34438794aed2c178decee1%7C0%7C0%
> 7C636270767931993418&sdata=
> >>>>>>>>>>>>>>> 6px9twhTFpg2YYaKWPoClt%2FQGQKnakm1jerYcSj%2F2w0%3D&
> reserved=0
> >>>>>>>>>>>>>>> _______________________________________________
> >>>>>>>>>>>>>>> gnso-rpm-wg mailing list
> >>>>>>>>>>>>>>> gnso-rpm-wg at icann.org
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> https://na01.safelinks.protection.outlook.com/?url=
> https%3A%2F%2Fmm
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> .icann.org%2Fmailman%2Flistinfo%2Fgnso-rpm-wg&data=
> 02%7C01%7C%7C2b7
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> c1e08334543cacbff08d47ce46e63%
> 7Cfa7b1b5a7b34438794aed2c178decee1%7C
> >>>>>>>>>>>>>>>
> >>>>>>>>>>>>>>> 0%7C0%7C636270767931993418&sdata=jZh3dzb5ycHMZLxsR4ZLmQdR%
> 2B2kWcBkF
> >>>>>>>>>>>>>>> D%2Fj6BAXDjiI%3D&reserved=0
> >>>>>>>>>>>>> _______________________________________________
> >>>>>>>>>>>>> gnso-rpm-wg mailing list
> >>>>>>>>>>>>> gnso-rpm-wg at icann.org
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> https://na01.safelinks.protection.outlook.com/?url=
> https%3A%2F%2Fmm.i
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> cann.org%2Fmailman%2Flistinfo%2Fgnso-rpm-wg&data=02%7C01%7C%
> 7C811dc6e
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> 8437245583fce08d47cea9d30%7Cfa7b1b5a7b34438794aed2c178de
> cee1%7C0%7C0%
> >>>>>>>>>>>>>
> >>>>>>>>>>>>> 7C636270794483518369&sdata=mJrIOSHwtTJCADlJ8m6UiUx7baKNfo
> XhIpZQh1s99f
> >>>>>>>>>>>>> s%3D&reserved=0
>
> >>>>>>>>>>>> _______________________________________________
> >>>>>>>>>>>> gnso-rpm-wg mailing list
> >>>>>>>>>>>> gnso-rpm-wg at icann.org
> >>>>>>>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rpm-wg
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> >>>>>>>>>
> >>>>>>>>>
> >>>>>>>>
> >>>>>>>
> >>>>>>>
> >>>>>>> _______________________________________________
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> >>>>>>> https://mm.icann.org/mailman/listinfo/gnso-rpm-wg
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