[gnso-rpm-wg] Fwd: Recommendation for Questions #7 and #16 (Design Mark and Appropriate Balance)

Paul Tattersfield gpmgroup at gmail.com
Thu Apr 27 14:23:55 UTC 2017


J Scott wrote:

"A letter or call to a registrar is FAR more complex at effective than a
UDRP action. Unfortunately, the former rarely results in the behavior being
stopped and the later does"

This should be a serious matter for ICANN compliance.

Best regards,

Paul.

On Thu, Apr 27, 2017 at 3:21 PM, Paul Tattersfield <gpmgroup at gmail.com>
wrote:

> This should be a serious matter for ICANN compliance.
>
> On Thu, Apr 27, 2017 at 12:30 PM, J. Scott Evans <jsevans at adobe.com>
> wrote:
>
>> A letter or call to a registrar is FAR more complex at effective than a
>> UDRP action. Unfortunately, the former rarely results in the behavior being
>> stopped and the later does.
>>
>> Sent from my iPhone
>>
>> On Apr 27, 2017, at 3:14 AM, Beckham, Brian <brian.beckham at wipo.int>
>> wrote:
>>
>> Paul,
>>
>>
>>
>> It is important to look at the actual language of section 3.18 of the
>> RAA.  This provides that registrars “shall take reasonable and prompt steps
>> to investigate and respond” to allegations of illegal activity.
>>
>>
>>
>> Looking at this carefully crafted contract language, it is easy to see
>> that taking reasonable steps is subject to interpretation, just as is the
>> corresponding obligation to investigate and respond.  This is in no way
>> meant to suggest that registrars are not complying with their ICANN
>> obligations, but whether those obligations necessarily address the claimed
>> illegal behavior and achieve the result sought is another matter
>> altogether.  RPMs on the other hand are specifically designed with criteria
>> to assist a substantive determination (which the registrar need only
>> implement).
>>
>>
>>
>> Indeed, the very fact that we have a working group dedicated to address
>> ongoing claims of trademark abuse suggests that some claimed abuse is not
>> being addressed through this RAA provision (which by the way is titled – my
>> emphasis: “Registrar’s Abuse Contact and *Duty to Investigate* Reports
>> of Abuse”).
>>
>>
>>
>> Quickly:  searching WIPO’s public case database for the term “fraud”
>> produces 1066 results (http://www.wipo.int/amc/en/do
>> mains/search/fulltext_decisions.jsp?tab=1&q=fraud&rows=20
>> <https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.wipo.int%2Famc%2Fen%2Fdomains%2Fsearch%2Ffulltext_decisions.jsp%3Ftab%3D1%26q%3Dfraud%26rows%3D20&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=ObK9VTHBPGrufXw9rVbAeMSmPR4LDiAFv6UouawPAgw%3D&reserved=0>),
>> searching for “phishing” yields 659 results (
>> http://www.wipo.int/amc/en/domains/search/fulltext_decision
>> s.jsp?tab=1&q=phishing&rows=20
>> <https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.wipo.int%2Famc%2Fen%2Fdomains%2Fsearch%2Ffulltext_decisions.jsp%3Ftab%3D1%26q%3Dphishing%26rows%3D20&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=EPAoSFpvzSW0q%2BAll7SLMLN62KSXT8rpyo9IUPlRtIA%3D&reserved=0>),
>> etc.
>>
>>
>>
>> If those instances of claimed abuse could be solved with a simple request
>> to the registrar, trademark owners might be saved the time and expense of
>> invoking RPMs.  It is therefore difficult to see what is “incorrect” about
>> this “narrative” which is based on actual cases, not assumptions.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Brian
>>
>>
>>
>> *From:* gnso-rpm-wg-bounces at icann.org [mailto:gnso-rpm-wg-bounces at ic
>> ann.org <gnso-rpm-wg-bounces at icann.org>] *On Behalf Of *Paul Tattersfield
>> *Sent:* Thursday, April 27, 2017 11:16 AM
>> *To:* Rebecca Tushnet
>> *Cc:* gnso-rpm-wg at icann.org
>> *Subject:* Re: [gnso-rpm-wg] Fwd: Recommendation for Questions #7 and
>> #16 (Design Mark and Appropriate Balance)
>>
>>
>>
>> Greg, a similar line of thinking was used by WIPO in response to the
>> initial Report on IGO Access to Curative Rights Protection Mechanisms.
>> https://forum.icann.org/lists/comments-igo-ingo-crp-access-i
>> nitial-20jan17/msg00000.html
>> <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fforum.icann.org%2Flists%2Fcomments-igo-ingo-crp-access-initial-20jan17%2Fmsg00000.html&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=JbNkJvGhH91k%2BoSORw6sLtAIFc%2Bb8pRJeBnZ2nBu67g%3D&reserved=0>
>>
>> It is troubling if this line of thinking is held within the wider ICANN
>> community, especially so, if this line of thinking is held by those seeking
>> to change the current RPMs.
>>
>> A much better understanding of the underlying issues is needed if we are
>> to better protect the goods and services of all rights holders through
>> better RPMs and at the same time build a more equitable framework for all.
>>
>> My reply https://forum.icann.org/lists/comments-igo-ingo-crp-access-i
>> nitial-20jan17/msg00038.html
>> <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fforum.icann.org%2Flists%2Fcomments-igo-ingo-crp-access-initial-20jan17%2Fmsg00038.html&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=PhO4Rkkg5jPCnI0AZtXula%2FnZ3cx834B3tUc5xAXSqQ%3D&reserved=0>
>> to WIPO’s comments demonstrates on a very simple level how your assumptions
>> set an incorrect narrative which sends people off in the wrong direction
>> when seeking to solve the problem.
>>
>> RPMs are not the best way of dealing with the kind of bad behaviour you
>> cite. A far better approach is to use section 3.18 of the 2013 Registrar
>> Accreditation Agreement (RAA) which requires registrars to take action
>> against this sort of behaviour.
>>
>> The advantage of using the 3.18 approach is it doesn’t require any domain
>> name infringement to take action which means all of the bad behaviour
>> involving a domain cited by yourself and WIPO can easily be dealt with and
>> without any costs beyond the time spent identifying offending sites and
>> requesting their suspension.
>>
>> Paul
>>
>>
>>
>> On Thu, Apr 27, 2017 at 6:08 AM, Rebecca Tushnet <
>> Rebecca.Tushnet at law.georgetown.edu> wrote:
>>
>> What would lead cybersquatters to choose common terms that, while
>> protectable for specific goods or services, are not generally known
>> for those meanings, as opposed to APPLE or MICROSOFT or other strong
>> marks?  That seems like a poor cybersquatting strategy, especially
>> done retail rather than wholesale.
>>
>> Circumstantial evidence is evidence too.
>> Rebecca Tushnet
>> Georgetown Law
>> 703 593 6759
>>
>> On Thu, Apr 27, 2017 at 1:03 AM, Greg Shatan <gregshatanipc at gmail.com>
>> wrote:
>> > We have no idea who abandoned these registration attempts, or even if
>> it was
>> > done by humans, much less rightsholders.
>> >
>> > If we want to make assumptions that support arguments, rather than
>> engaging
>> > in evidence-based inquiry, I'll offer the assumption that all the
>> abandoned
>> > carts were started by cybersquatters that intended to use the domains to
>> > engage in spam, malware, phishing, spearphishing, fraud, theft and
>> botnet
>> > farming.
>> >
>> > Greg
>> >
>> >
>> > On Wed, Apr 26, 2017 at 11:27 PM Rebecca Tushnet
>> > <Rebecca.Tushnet at law.georgetown.edu> wrote:
>> >>
>> >> Forwarding to match.
>> >>
>> >> If you think that lots of people have valid uses--including rights--in
>> >> those terms, then when they stop trying to register those terms, that
>> >> is overdeterrence.  I think what I said was clear.
>> >>
>> >> Rebecca Tushnet
>> >> Georgetown Law
>> >> 703 593 6759
>> >>
>> >>
>> >> On Wed, Apr 26, 2017 at 11:03 PM, Greg Shatan <gregshatanipc at gmail.com
>> >
>> >> wrote:
>> >> > Your guess -- and overdeterrence is just a guess, with nothing to
>> back
>> >> > it up
>> >> > -- is as good as mine.  My guess is that it absolutely is not
>> >> > overdeterrence.
>> >> >
>> >> > And my point was that your statement was a mischaracterization of the
>> >> > way
>> >> > the TMCH, Sunrise and Claims work, as well as a mischaracterization
>> of
>> >> > how
>> >> > trademarks work.  So I don't think "My point exactly" is what you
>> meant
>> >> > to
>> >> > say (though I wish it were).
>> >> >
>> >> > Greg
>> >> >
>> >> > Greg Shatan
>> >> > C: 917-816-6428
>> >> > S: gsshatan
>> >> > Phone-to-Skype: 646-845-9428
>> >> > gregshatanipc at gmail.com
>> >> >
>> >> >
>> >> > On Wed, Apr 26, 2017 at 10:57 PM, Rebecca Tushnet
>> >> > <Rebecca.Tushnet at law.georgetown.edu> wrote:
>> >> >>
>> >> >> My point exactly.  So what explains the over 90% abandonment rate,
>> >> >> other than overdeterrence, especially with those most returned
>> terms?
>> >> >> Rebecca Tushnet
>> >> >> Georgetown Law
>> >> >> 703 593 6759
>> >> >>
>> >> >>
>> >> >> On Wed, Apr 26, 2017 at 10:53 PM, Greg Shatan <
>> gregshatanipc at gmail.com>
>> >> >> wrote:
>> >> >> > "Maybe absolutely no one else besides the TMCH entrant/s had a
>> >> >> > legitimate
>> >> >> > business using those terms."
>> >> >> >
>> >> >> > That is clearly and absolutely not the basis of trademark rights,
>> >> >> > trademark
>> >> >> > registration or entry into the TMCH.  Nor is it the way Sunrise or
>> >> >> > Claims
>> >> >> > work.  Ridiculous.
>> >> >> >
>> >> >> > Greg
>> >> >> >
>> >> >> > Greg Shatan
>> >> >> > C: 917-816-6428
>> >> >> > S: gsshatan
>> >> >> > Phone-to-Skype: 646-845-9428
>> >> >> > gregshatanipc at gmail.com
>> >> >> >
>> >> >> >
>> >> >> > On Wed, Apr 26, 2017 at 10:45 PM, Rebecca Tushnet
>> >> >> > <Rebecca.Tushnet at law.georgetown.edu> wrote:
>> >> >> >>
>> >> >> >> Yes, because we don't have good survey evidence, one of the
>> >> >> >> questions
>> >> >> >> is what we can infer from the circumstantial evidence available
>> to
>> >> >> >> us,
>> >> >> >> particularly the over 90% abandonment rate combined with the top
>> >> >> >> queries being words like forex, cloud, and love.  Maybe
>> absolutely
>> >> >> >> no
>> >> >> >> one else besides the TMCH entrant/s had a legitimate business
>> using
>> >> >> >> those terms.  But I doubt it.
>> >> >> >> Rebecca Tushnet
>> >> >> >> Georgetown Law
>> >> >> >> 703 593 6759
>> >> >> >>
>> >> >> >>
>> >> >> >> On Wed, Apr 26, 2017 at 10:37 PM, icannlists
>> >> >> >> <icannlists at winston.com>
>> >> >> >> wrote:
>> >> >> >> > Thanks Rebecca.  I've never heard of a trademark owner being
>> >> >> >> > deterred
>> >> >> >> > by
>> >> >> >> > a claims notice since one of the explicit defenses in the UDRP
>> is
>> >> >> >> > when a
>> >> >> >> > registrant has rights or legitimate interests in a
>> corresponding
>> >> >> >> > trademark.
>> >> >> >> > So, I think that one may be a bit of a red herring.
>> >> >> >> >
>> >> >> >> > However, your comment about avoiding overreach is well received
>> >> >> >> > and
>> >> >> >> > we
>> >> >> >> > should keep it in mind while at the same time not
>> under-reaching
>> >> >> >> > either -
>> >> >> >> > when we do that, Grandma gets phished.
>> >> >> >> >
>> >> >> >> > Best,
>> >> >> >> > Paul
>> >> >> >> >
>> >> >> >> >
>> >> >> >> >
>> >> >> >> > -----Original Message-----
>> >> >> >> > From: Rebecca Tushnet [mailto:Rebecca.Tushnet at law.ge
>> orgetown.edu]
>> >> >> >> > Sent: Wednesday, April 26, 2017 9:17 PM
>> >> >> >> > To: icannlists <icannlists at winston.com>
>> >> >> >> > Cc: Silver, Bradley <Bradley.Silver at timewarner.com>;
>> >> >> >> > gnso-rpm-wg at icann.org
>> >> >> >> > Subject: Re: [gnso-rpm-wg] Recommendation for Questions #7 and
>> #16
>> >> >> >> > (Design Mark and Appropriate Balance)
>> >> >> >> >
>> >> >> >> > Avoiding overreaching is pro-trademark, as the public reaction
>> to
>> >> >> >> > SOPA/PIPA and patent trolls has shown with respect to copyright
>> >> >> >> > and
>> >> >> >> > patent.
>> >> >> >> > There are also the interests of trademark owners who aren't
>> >> >> >> > participating in
>> >> >> >> > this process but may want to register domain names that are
>> >> >> >> > perfectly
>> >> >> >> > legitimate for their goods/services and jurisdictions.  Some of
>> >> >> >> > them
>> >> >> >> > may
>> >> >> >> > inevitably receive notices and be deterred, but there are
>> steps we
>> >> >> >> > can take
>> >> >> >> > to limit that problem.
>> >> >> >> > Rebecca Tushnet
>> >> >> >> > Georgetown Law
>> >> >> >> > 703 593 6759
>> >> >> >> >
>> >> >> >> >
>> >> >> >> > On Wed, Apr 26, 2017 at 9:50 PM, icannlists
>> >> >> >> > <icannlists at winston.com>
>> >> >> >> > wrote:
>> >> >> >> >> Thanks Rebecca.  I'm not characterizing you as anti-trademark;
>> >> >> >> >> just
>> >> >> >> >> your arguments and positions to date on this list.  We would
>> very
>> >> >> >> >> much
>> >> >> >> >> welcome anything favorable to trademarks that you wish to add
>> to
>> >> >> >> >> the
>> >> >> >> >> discourse.
>> >> >> >> >>
>> >> >> >> >> Best,
>> >> >> >> >> Paul
>> >> >> >> >>
>> >> >> >> >>
>> >> >> >> >>
>> >> >> >> >> -----Original Message-----
>> >> >> >> >> From: Rebecca Tushnet [mailto:Rebecca.Tushnet at law.ge
>> orgetown.edu]
>> >> >> >> >> Sent: Wednesday, April 26, 2017 8:00 PM
>> >> >> >> >> To: icannlists <icannlists at winston.com>
>> >> >> >> >> Cc: Silver, Bradley <Bradley.Silver at timewarner.com>;
>> >> >> >> >> gnso-rpm-wg at icann.org
>> >> >> >> >> Subject: Re: [gnso-rpm-wg] Recommendation for Questions #7 and
>> >> >> >> >> #16
>> >> >> >> >> (Design Mark and Appropriate Balance)
>> >> >> >> >>
>> >> >> >> >> Please don't characterize me as anti-trademark; I strongly
>> >> >> >> >> believe
>> >> >> >> >> in
>> >> >> >> >> the consumer protection function of trademarks, and also in
>> >> >> >> >> trademark
>> >> >> >> >> protection in some circumstances for business purposes.  See
>> >> >> >> >>
>> >> >> >> >>
>> >> >> >> >> https://harvardlawreview.org/2017/01/registering-disagreemen
>> t-registra
>> <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fharvardlawreview.org%2F2017%2F01%2Fregistering-disagreement-registra&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=iu0yMvKbDyZebmCpHx42pp%2BuQGNY3aNnUVn7YgzLoA8%3D&reserved=0>
>> >> >> >> >> tion-in-modern-american-trademark-law/
>> >> >> >> >>
>> >> >> >> >> Asking again: for those of you who think it doesn't matter if
>> >> >> >> >> claimants
>> >> >> >> >> who don't own relevant rights get to use the TMCH, what then
>> did
>> >> >> >> >> ICANN mean
>> >> >> >> >> by its stated intent not to expand trademark rights?
>> >> >> >> >> Rebecca Tushnet
>> >> >> >> >> Georgetown Law
>> >> >> >> >> 703 593 6759
>> >> >> >> >>
>> >> >> >> >>
>> >> >> >> >> On Wed, Apr 26, 2017 at 8:46 PM, icannlists
>> >> >> >> >> <icannlists at winston.com>
>> >> >> >> >> wrote:
>> >> >> >> >>> Thanks Rebecca.  There is not much new here.  Whomever
>> registers
>> >> >> >> >>> a
>> >> >> >> >>> second level domain name first (Sunrise - TM owner), Premium
>> >> >> >> >>> (Rich
>> >> >> >> >>> person)
>> >> >> >> >>> or Landrush (TM owner who didn't want to pay the Sunrise
>> >> >> >> >>> shakedown
>> >> >> >> >>> price or
>> >> >> >> >>> regular folks like all of us), someone gets the exclusive
>> rights
>> >> >> >> >>> to
>> >> >> >> >>> that
>> >> >> >> >>> second level.  So, it is not just a question of if, but of
>> when
>> >> >> >> >>> and
>> >> >> >> >>> who.  I
>> >> >> >> >>> think it is OK to just say "I don't want it to be a trademark
>> >> >> >> >>> owner."
>> >> >> >> >>> Others will disagree, but we don't have to keep this in a
>> >> >> >> >>> mysterious context
>> >> >> >> >>> or otherwise try to layer on some free speech issue that
>> doesn't
>> >> >> >> >>> exist.
>> >> >> >> >>> Trademark owners want them first in order to protect their
>> >> >> >> >>> brands
>> >> >> >> >>> and
>> >> >> >> >>> consumers.  Others who are anti-trademarks don't want them to
>> >> >> >> >>> have
>> >> >> >> >>> them
>> >> >> >> >>> first and would prefer someone else gets the exclusive right.
>> >> >> >> >>> Fair
>> >> >> >> >>> enough.
>> >> >> >> >>> Now we see if we can get to consensus on changing the AGB.  I
>> >> >> >> >>> doubt
>> >> >> >> >>> we will,
>> >> >> >> >>> but at least the free speech veneer is pulled back.
>> >> >> >> >>>
>> >> >> >> >>> Best,
>> >> >> >> >>> Paul
>> >> >> >> >>>
>> >> >> >> >>>
>> >> >> >> >>>
>> >> >> >> >>> -----Original Message-----
>> >> >> >> >>> From: gnso-rpm-wg-bounces at icann.org
>> >> >> >> >>> [mailto:gnso-rpm-wg-bounces at icann.org] On Behalf Of Rebecca
>> >> >> >> >>> Tushnet
>> >> >> >> >>> Sent: Wednesday, April 26, 2017 3:11 PM
>> >> >> >> >>> To: Silver, Bradley <Bradley.Silver at timewarner.com>
>> >> >> >> >>> Cc: gnso-rpm-wg at icann.org
>> >> >> >> >>> Subject: Re: [gnso-rpm-wg] Recommendation for Questions #7
>> and
>> >> >> >> >>> #16
>> >> >> >> >>> (Design Mark and Appropriate Balance)
>> >> >> >> >>>
>> >> >> >> >>> By that logic the mandate not to expand on trademark rights
>> >> >> >> >>> would
>> >> >> >> >>> have been pointless because no activity in domain name space
>> >> >> >> >>> could
>> >> >> >> >>> ever have expanded trademark rights.  Call it a right, call
>> it a
>> >> >> >> >>> privilege, call it an alien from Xenon if you like, but ICANN
>> >> >> >> >>> did
>> >> >> >> >>> not
>> >> >> >> >>> want trademark owners to be able to assert control over
>> domain
>> >> >> >> >>> names
>> >> >> >> >>> in excess of what underlying trademark law would have
>> allowed.
>> >> >> >> >>> Under
>> >> >> >> >>> the "nothing in domain names can expand trademark rights
>> because
>> >> >> >> >>> they're never exclusive" logic, was the ICANN direction
>> >> >> >> >>> completely
>> >> >> >> >>> meaningless, or did it have some meaning?  (Trademark
>> rights, of
>> >> >> >> >>> course, are never "exclusive" either, which is why we can use
>> >> >> >> >>> any
>> >> >> >> >>> examples we want in this discussion.) Rebecca Tushnet
>> Georgetown
>> >> >> >> >>> Law
>> >> >> >> >>> 703 593 6759
>> >> >> >> >>>
>> >> >> >> >>>
>> >> >> >> >>> On Wed, Apr 26, 2017 at 1:41 PM, Silver, Bradley via
>> gnso-rpm-wg
>> >> >> >> >>> <gnso-rpm-wg at icann.org> wrote:
>> >> >> >> >>>> Jeremy - the TMCH does not allow exclusive rights in
>> domains.
>> >> >> >> >>>> Having
>> >> >> >> >>>> a mark in the TMCH affords nothing close an exclusive right.
>> >> >> >> >>>> That's a basic
>> >> >> >> >>>> truth which shouldn’t be ignored.
>> >> >> >> >>>>
>> >> >> >> >>>> -----Original Message-----
>> >> >> >> >>>> From: gnso-rpm-wg-bounces at icann.org
>> >> >> >> >>>> [mailto:gnso-rpm-wg-bounces at icann.org] On Behalf Of Jeremy
>> >> >> >> >>>> Malcolm
>> >> >> >> >>>> Sent: Wednesday, April 26, 2017 1:32 PM
>> >> >> >> >>>> To: gnso-rpm-wg at icann.org
>> >> >> >> >>>> Subject: Re: [gnso-rpm-wg] Recommendation for Questions #7
>> and
>> >> >> >> >>>> #16
>> >> >> >> >>>> (Design Mark and Appropriate Balance)
>> >> >> >> >>>>
>> >> >> >> >>>> On 26/4/17 9:00 am, Colin O'Brien wrote:
>> >> >> >> >>>>> Nice try Rebecca but I'm not attempting to overturn the
>> apple
>> >> >> >> >>>>> cart.
>> >> >> >> >>>>> If you have actual examples of problems then provide them
>> >> >> >> >>>>> otherwise this is
>> >> >> >> >>>>> an indulgent  academic exercise.
>> >> >> >> >>>>
>> >> >> >> >>>> The fact that the TMCH is allowing exclusive rights in
>> domains
>> >> >> >> >>>> that
>> >> >> >> >>>> go beyond the equivalent rights in domestic trademark law is
>> >> >> >> >>>> itself a
>> >> >> >> >>>> problem if we accept that the TMCH was meant to track
>> trademark
>> >> >> >> >>>> law.
>> >> >> >> >>>>
>> >> >> >> >>>> --
>> >> >> >> >>>> Jeremy Malcolm
>> >> >> >> >>>> Senior Global Policy Analyst
>> >> >> >> >>>> Electronic Frontier Foundation
>> >> >> >> >>>> https://eff.org
>> <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Feff.org&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=KzOy4znSpz0a9ehfGktwBDMo2ewTzNlJvPB42cYQEiE%3D&reserved=0>
>> >> >> >> >>>> jmalcolm at eff.org
>> >> >> >> >>>>
>> >> >> >> >>>> Tel: 415.436.9333 ext 161
>> >> >> >> >>>>
>> >> >> >> >>>> :: Defending Your Rights in the Digital World ::
>> >> >> >> >>>>
>> >> >> >> >>>> Public key:
>> >> >> >> >>>> https://www.eff.org/files/2016/11/27/key_jmalcolm.txt
>> <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.eff.org%2Ffiles%2F2016%2F11%2F27%2Fkey_jmalcolm.txt&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=xkQT0KuikbckR%2B74w%2Fz94XQg5UvkhiHvIw%2F7a4v5%2BjI%3D&reserved=0>
>> >> >> >> >>>> PGP fingerprint: 75D2 4C0D 35EA EA2F 8CA8 8F79 4911 EC4A
>> EDDF
>> >> >> >> >>>> 1122
>> >> >> >> >>>>
>> >> >> >> >>>>
>> >> >> >> >>>>
>> >> >> >> >>>>
>> >> >> >> >>>> ==============================
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>> >> >> >> >>>> ==============================
>> ===================================
>> >> >> >> >>>>
>> >> >> >> >>>> _______________________________________________
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>> >> >> >> >>> _______________________________________________
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>> >> >> >> _______________________________________________
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>> <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fmm.icann.org%2Fmailman%2Flistinfo%2Fgnso-rpm-wg&data=02%7C01%7C%7C90df5d6dcb74419126d508d48d56373b%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C0%7C636288848838788516&sdata=3ked8x9YllpWvJmgM05B1XWFTHvCz%2FsF0MQ2tL9qQME%3D&reserved=0>
>> >> >> >
>> >> >> >
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>> >> >
>> >> _______________________________________________
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>> >
>> > --
>> >
>> > Greg Shatan
>> > C: 917-816-6428 <(917)%20816-6428>
>> > S: gsshatan
>> > Phone-to-Skype: 646-845-9428 <(646)%20845-9428>
>> > gregshatanipc at gmail.com
>> _______________________________________________
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