[GNSO-RPM-WG] ACTION ITEM: Questions re: Converted Individual Proposal #34/URS Rec #9

Tue Oct 6 12:47:10 UTC 2020

Hi Georges,It's not my language, it's the language of our agreed URS
Rec#9.
Best, Kathy

----- Original Message -----
From: "Nahitchevansky Georges" 
To:"Kathy Kleiman" , "Zak Muscovitch" , "Griffin Barnett" , "BECKHAM
Brian" , "Julie Hedlund" , "gnso-rpm-wg at icann.org" 
Cc:
Sent:Tue, 6 Oct 2020 12:42:50 +0000
Subject:RE: [GNSO-RPM-WG] ACTION ITEM: Questions re: Converted
Individual Proposal #34/URS Rec #9

	I disagree with Kathy’s proposed revision and agree with Brian’s
language.  I don’t think the location of the proxy/privacy service
should determine the language.  This will create an open gateway to
gaming to increase the burden on complainants.  Some registrars have
set up privacy services in Panama, for example, because easy it is
easy and more cost efficient to do so.  Spanish is the language
there.  If the registrar is in the US or Europe, how would it be
relevant that the privacy service is in Panama for purely business and
administrative purposes.  Put another way, a party registers a domain
name in Europe, China or the US and clicks on a box to opt for the
registrar privacy service.  That service happens to be in Panama. 
Would the complaint thus possibly need to be in Spanish.  That would
be absurd and I don’t think we should be including proxy services in
that consideration.  The bullet on following UDRP procedure in which
a panelist looks at the totality of the circumstances to determine
whether to proceed in a language other than the registration agreement
language more than covers all of this already.  Why complicate it
even more.

	Georges 

	FROM: GNSO-RPM-WG  ON BEHALF OF Kathy Kleiman
SENT: Tuesday, October 6, 2020 8:24 AM
TO: Zak Muscovitch ; Griffin Barnett ; BECKHAM Brian ; Julie Hedlund ;
gnso-rpm-wg at icann.org
SUBJECT: Re: [GNSO-RPM-WG] ACTION ITEM: Questions re: Converted
Individual Proposal #34/URS Rec #9

	Hi All,

	As we head into our next RPM meeting (shortly) I want to raise one
small concern.  Wasn't the underlying reason for our well-agreed URS
Rec #9 that we do not know the language of the registration
agreement?  In the URS, as you know, the Provider works closely with
the Registry; in the UDRP, the Provider works closely with the
Registrar (who provides the Registration agreement).

	Hence in URS Rec #9, we had "proxies" to help us understand what the
language of the registrant was likely to be.  I include them below
and suggest they be incorporated into the final decision.  If I am
missing something, please let me know.  See everyone soon!

	Best, Kathy

	------------

	URS FINAL RECOMMENDATION XX#9

	The Working Group recommends that as implementation guidance, the IRT
consider developing guidance to assist the URS providers in deciding
what language to use during a URS proceeding and when issuing a
Determination. Such guidance should take into account the fact that
domains subject to a URS Complaint may have been registered via a
privacy or proxy service and the location of the service will
determine the language of that service, which may be relevant.

	Furthermore, the guidance may include, but is not limited to:

	 1) whether it is possible to ascertain the language of the
registration agreement from the registrar; 

	 2) principles articulated in section 4.5 of the WIPO Overview; 

	 3) procedures followed under the UDRP; 

	 4) the language used by the registry and/or predominant language of
the country of the registry; and 

	5) the language used by the registrar and/or predominant language of
the country of the registrar. 

 ----- Original Message -----

	FROM:

	"Zak Muscovitch" 

	TO:

	"Griffin Barnett" , "BECKHAM Brian" , "Julie Hedlund" ,
"gnso-rpm-wg at icann.org [5]" 

	CC:

	SENT:

	Mon, 5 Oct 2020 18:03:01 +0000

	SUBJECT:

	Re: [GNSO-RPM-WG] ACTION ITEM: Questions re: Converted Individual
Proposal #34/URS Rec #9

	I think Brian’s revised language is very good and support it as
well. 

	Zak

	FROM: Griffin Barnett 
SENT: Monday, October 5, 2020 2:00:17 PM
TO: BECKHAM Brian ; Zak Muscovitch ; Julie Hedlund ;
gnso-rpm-wg at icann.org [11] 
SUBJECT: RE: ACTION ITEM: Questions re: Converted Individual Proposal
#34/URS Rec #9 

	All – for the record, I support Brian Beckham’s suggested
refinements below.

	Best,

	Griffin

	FROM: BECKHAM Brian [mailto:brian.beckham at wipo.int [13]] 
SENT: Monday, October 5, 2020 1:57 PM
TO: Zak Muscovitch ; Griffin Barnett ; Julie Hedlund ;
gnso-rpm-wg at icann.org [17]
SUBJECT: RE: ACTION ITEM: Questions re: Converted Individual Proposal
#34/URS Rec #9

	Thanks Zak,

	Did you happen to see my later email on this – I have attached it,
but also paste here below the text:

	--

	Thanks Griffin, 

	I mainly agree re combining these, and I apologize for introducing
any confusion last night (as mentioned I was in the car so could not
see the text onscreen).

	A few suggestions (the numbers refer to Griffin’s new numbering):

	IMPLEMENTATION BULLET 2: add “, where applicable,” so that it
reads “The Notice of Complaint should, where applicable,
contain…” as (based on our UDRP experience) this will not be
required in the majority of cases, and may introduce confusion if made
a standard practice

	IMPLEMENTATION BULLET 3: I think this proposed revision would track
the intent, as we do not want to create a wide open option to submit
documents grossly in excess of the word limit:  “If a translation
is ordered, as long as the original submission meets the word limits
in the original language, the translation of the original submission
may nominally exceed the prescribed word limit;  for the avoidance of
doubt, the translation may not introduce new facts or arguments which
may be contained in the Language of Proceeding submission.”

	IMPLEMENTATION BULLET 4: should be slightly reworded in the
beginning, and should refer to examiners, not providers, and I propose
that it read, in full:  

	“The IRT should consider developing guidance to assist URS
examiners in deciding whether to deviate from the default language in
the context of a particular proceeding.  Such guidance may take into
account the language of the relevant registration agreement
(irrespective of whether registered through a privacy or proxy service
or reseller), the language requested by one of the parties, principles
articulated in the relevant section (presently 4.5) of the WIPO
Overview, or any other matters considered relevant.”

	For context on the above:  the language “for purposes of the
parties’ filings and when issuing a Determination” is unnecessary
as those items are covered by the “Language of Proceeding”
concept.  I am also unclear on the relevance of the predominant
language of the country of the registry, and frankly for that of the
country of the registrar or privacy/proxy service or reseller, and for
that matter even that of the registrant.  For example, if I register
a domain under a RY (or privacy/proxy service or reseller) based in
Switzerland, what language would control under this proposal? 
French?  German?  Italian?  (There was even a narrowly-defeated
vote on adding English as a fourth official language.)  None of those
3 would be the language I would use to register a domain name, and
introducing them into the proceedings could create an unfair
prejudice.

	--

	Brian 

	FROM: GNSO-RPM-WG  ON BEHALF OF Zak Muscovitch
SENT: Monday, October 5, 2020 6:05 PM
TO: Griffin Barnett ; Julie Hedlund ; gnso-rpm-wg at icann.org [21]
SUBJECT: Re: [GNSO-RPM-WG] ACTION ITEM: Questions re: Converted
Individual Proposal #34/URS Rec #9

	Further to Griffin’s below email suggesting a ‘combined
recommendation’ integrating Recommendation 9 and Proposal 34, I
agree with the proposed solution. I also agree with Griffin’s
observation that ‘Rec 9 may have been prepared before we understood
that we may have consensus on moving Individual Proposal 34 on as a
Recommendation and thus Rec 9 was meant to address concerns about the
current URS rule on language of proceedings which refers to English as
the default language always’.

	I have appended Griffin’s proposed ‘combined recommendation’
below, for ease of reference:

	_URS RECOMMENDATION [/ CONVERTED INDIVIDUAL PROPOSAL] #XX_

	_ _

	_The Working Group recommends that the URS Rules be amended to
incorporate in full Rule #11 of the UDRP Rules regarding “Language
of Proceedings”, see:
__https://www.icannorg/resources/pages/udrp-rules-2015-03-11-en
[22]__  _

	_ _

	 _“(a) Unless otherwise agreed by the Parties, or specified
otherwise in the Registration Agreement, the language of the
administrative proceeding shall be the language of the Registration
Agreement, subject to the authority of the Panel to determine
otherwise, having regard to the circumstances of the administrative
proceeding_

	_ _

	 _(b) The Panel may order that any documents submitted in languages
other than the language of the administrative proceeding be
accompanied by a translation in whole or in part into the language of
the administrative proceeding.”_

	_ _

	_IMPLEMENTATION GUIDANCE:__ _

	_As implementation guidance, the Working Group recommends that the
IRT consider the following:_

	* _Preliminary submissions by either side to the Panel regarding the
language of the proceeding should be limited to 250 words, and not be
counted against the existing URS word limits _

	* _The Notice of Complaint should contain a section explaining that
the Respondent may make a submission regarding the language of the
proceedings. _

	* _If a translation is ordered, exceeding the URS word limits should
be permitted, as long as the original submission meets the word limits
in the original language._

	* _The should also IRT consider developing guidance to assist URS
providers in deciding whether to deviate from the default language in
the context of a particular proceeding for purposes of the parties’
filings and when issuing a Determination. Such guidance should take
into account the fact that domains subject to a URS Complaint may have
been registered via a privacy or proxy service or reseller and the
location of the privacy or proxy service provider or reseller may
determine the language of the domain name registration agreement and
thus the default language of the URS proceeding.  This potential
guidance could also consider the relevance of other factors, such as
the language requested by either party, the predominant language of
the country or territory of the registrant, the language used by the
registry and/or predominant language of the country of the registry,
if different from that of the registration agreement, and the
language used by the registrar and/or predominant language of the
country of the registrar if different from the language of the
registration agreement._

	Zak Muscovitch

	FROM: GNSO-RPM-WG  ON BEHALF OF Griffin Barnett
SENT: Thursday, October 1, 2020 6:17 PM
TO: Julie Hedlund ; gnso-rpm-wg at icann.org [25]
SUBJECT: Re: [GNSO-RPM-WG] ACTION ITEM: Questions re: Converted
Individual Proposal #34/URS Rec #9

	Hi all,

	As I noted during the call where this came up, I see Converted
Individual Proposal #34 and Recommendation #9 as complementary and not
duplicative or conflicting. 

	Converted Proposal 34 says:

	The Working Group recommends that the URS Rules be amended to
incorporate in full Rule #11 of the UDRP Rules regarding “Language
of Proceedings”, see:
https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en
[26]  

	 “(a) Unless otherwise agreed by the Parties, or specified
otherwise in the Registration Agreement, the language of the
administrative proceeding shall be the language of the Registration
Agreement, subject to the authority of the Panel to determine
otherwise, having regard to the circumstances of the administrative
proceeding.

	 (b) The Panel may order that any documents submitted in languages
other than the language of the administrative proceeding be
accompanied by a translation in whole or in part into the language of
the administrative proceeding.”

	IMPLEMENTATION GUIDANCE: 

	As implementation guidance, the Working Group recommends that the IRT
consider the following:

	* Preliminary submissions by either side to the Panel regarding the
language of the proceeding should be limited to 250 words, and not be
counted against the existing URS word limits. 

	* The Notice of Complaint should contain a section explaining that
the Respondent may make a submission regarding the language of the
proceedings. 

	* If a translation is ordered, exceeding the URS word limits should
be permitted, as long as the original submission meets the word limits
in the original language.

	Rec 9 says:

	The Working Group recommends that as implementation guidance, the IRT
consider developing guidance to assist the URS providers in deciding
what language to use during a URS proceeding and when issuing a
Determination. Such guidance should take into account the fact that
domains subject to a URS Complaint may have been registered via a
privacy or proxy service and the location of the service will
determine the language of that service, which may be relevant.  

	Furthermore, the guidance may include, but is not limited to:

	1) whether it is possible to ascertain the language of the
registration agreement from the registrar; 

	2) principles articulated in section 4.5 of the WIPO Overview; 

	3) procedures followed under the UDRP; 

	4) the language used by the registry and/or predominant language of
the country of the registry; and 

	5) the language used by the registrar and/or predominant language of
the country of the registrar.

	If anything, Rec 9 could be absorbed as Implementation Guidance to
Converted Individual Proposal 34, which provides a more concrete rule
in terms of which language should be used for URS proceedings and
brings it into conformity with the UDRP rule – which creates
consistency between these mechanisms and predictability for users,
while preserving panelist discretion to deviate from the default
language where appropriate.  

	I also note my recollection that Rec 9 may have been prepared before
we understood that we may have consensus on moving Individual Proposal
34 on as a Recommendation and thus Rec 9 was meant to address concerns
about the current URS rule on language of proceedings which refers to
English as the default language always (with Notice of Complaint only
being translated into the “predominant language used in the
registrant’s country or territory” and where the Response could be
in that same “predominant” language) – see URS Procedure 4.2 and
URS Rules 4(b) and 9.  

	Accordingly, I might suggest merging the two pieces as follows:

	URS RECOMMENDATION [/ CONVERTED INDIVIDUAL PROPOSAL] #XX

	The Working Group recommends that the URS Rules be amended to
incorporate in full Rule #11 of the UDRP Rules regarding “Language
of Proceedings”, see:
https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en
[27]  

	 “(a) Unless otherwise agreed by the Parties, or specified
otherwise in the Registration Agreement, the language of the
administrative proceeding shall be the language of the Registration
Agreement, subject to the authority of the Panel to determine
otherwise, having regard to the circumstances of the administrative
proceeding.

	 (b) The Panel may order that any documents submitted in languages
other than the language of the administrative proceeding be
accompanied by a translation in whole or in part into the language of
the administrative proceeding.”

	IMPLEMENTATION GUIDANCE: 

	As implementation guidance, the Working Group recommends that the IRT
consider the following:

	* Preliminary submissions by either side to the Panel regarding the
language of the proceeding should be limited to 250 words, and not be
counted against the existing URS word limits. 

	* The Notice of Complaint should contain a section explaining that
the Respondent may make a submission regarding the language of the
proceedings 

	* If a translation is ordered, exceeding the URS word limits should
be permitted, as long as the original submission meets the word limits
in the original language.

	* The should also IRT consider developing guidance to assist URS
providers in deciding whether to deviate from the default language in
the context of a particular proceeding for purposes of the parties’
filings and when issuing a Determination. Such guidance should take
into account the fact that domains subject to a URS Complaint may have
been registered via a privacy or proxy service or reseller and the
location of the privacy or proxy service provider or reseller may
determine the language of the domain name registration agreement and
thus the default language of the URS proceeding.  This potential
guidance could also consider the relevance of other factors, such as
the language requested by either party, the predominant language of
the country or territory of the registrant, the language used by the
registry and/or predominant language of the country of the registry,
if different from that of the registration agreement, and the
language used by the registrar and/or predominant language of the
country of the registrar if different from the language of the
registration agreement.

	I hope these thoughts are helpful.

	Best regards,

	Griffin

	GRIFFIN M. BARNETT

	Associate

	Winterfeldt IP Group

	1601 K Street NW, Ste 1050

	Washington, DC  20006

	griffin at winterfeldt.law [28]

	+1 202 759 5836

	FROM: GNSO-RPM-WG [mailto:gnso-rpm-wg-bounces at icann.org [29]] ON
BEHALF OF Julie Hedlund
SENT: Thursday, October 1, 2020 4:55 PM
TO: gnso-rpm-wg at icann.org [30]
SUBJECT: [GNSO-RPM-WG] ACTION ITEM: Questions re: Converted Individual
Proposal #34/URS Rec #9

	Dear All,

	Per the action item from the WG meeting on 01 October (see the notes
and actions below), please see the following questions relating to
Converted Individual Proposal #34 and URS Recommendation #9 and
provide your input not later than 16:00 UTC ON MONDAY, 05 OCTOBER.  

	For reference see the following documents:

	-- For Converted Individual Proposal #34, see page 7 at:
https://docs.google.com/document/d/1qjiKBaAAMNPctSIwP932OKT6vrgkFXxdVYVf6DAz2no/edit?usp=sharing
[31].  

	-- For URS Recommendation #9, see page 14 at:
https://docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing
[32] 

	Questions for review:

	1. Whether these separate recommendations are in conflict or
complementary.

	2. if these separate recommendations are in conflict should the
Implementation Guidance from the new recommendation be incorporated
into recommendation #9.

	Kind regards,

	Mary, Ariel, and Julie

	FROM: GNSO-RPM-WG  on behalf of Julie Hedlund 
DATE: Thursday, October 1, 2020 at 3:45 PM
TO: "gnso-rpm-wg at icann.org [35]" 
SUBJECT: [GNSO-RPM-WG] Notes and Action Items: RPM PDP WG Meeting 01
October 2020

	Dear All,

	Please see below the action items captured by staff from the RPM PDP
Working Group call held on 01 October 2020 at 17:00 UTC. 
Staff will post these to the wiki space.  _PLEASE NOTE THAT
THESE ARE HIGH-LEVEL NOTES AND ARE NOT MEANT AS A SUBSTITUTE FOR
THE RECORDING, CHAT ROOM, OR TRANSCRIPT__._ The recording, Zoom
chat, transcript and attendance records are posted on the wiki at:
https://community.icann.org/display/RARPMRIAGPWG/2020-10-01+Review+of+all+Rights+Protection+Mechanisms+%28RPMs%29+in+all+gTLDs+PDP+WG
[37]. 

	Best Regards,

	Mary, Ariel, and Julie

	==

	ACTION ITEMS: 

	URS Final Recommendations – Revised URS Recommendation #3

	ACTION ITEM: Change “Working Group believes” to “Working Group
is unaware of any contradiction” in the context.

	Overarching Data Collection Recommendation

	ACTION ITEM: Change text to “over the preceding period of [not less
than every 12 months]

	URS Rec # (was Individual Proposal #28):

	ACTION ITEM: Put the four options for revised text out for review by
the WG on the email distribution list and discuss during a future
meeting.

	URS Rec # (was Individual Proposal #34):

	ACTION ITEM: Staff to send a separate email that will have links to
both of the recommendations and will ask WG members to weigh in on 1)
whether these separate recommendations are in conflict or
complementary and 2) if they are in conflict should the Implementation
Guidance from the new recommendation be incorporated into
recommendation #9.

	NOTES:

	1. Updates to Statements of Interest: No updates provided.

	2. URS Final Recommendations – Revised URS Recommendation #3;
see: https://docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing
[docs.google.com] [docs.google.com] [38]

	ACTION ITEM: CHANGE “WORKING GROUP BELIEVES” TO “WORKING GROUP
IS UNAWARE OF ANY CONTRADICTION” IN THE CONTEXT.

	3. URS Final Recommendations – Revised URS Recommendation #2,
see: https://docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing
[docs.google.com] [docs.google.com] [39]

	-- The WG agrees to the revised language.

	4. URS Final Recommendations – Revised URS Recommendation #8,
continued from last meeting,
see: https://docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing
[docs.google.com] [docs.google.com] [40]

	New suggested text from staff: “In addition, the Working Group
agrees that as set out in the URS Rules and Procedure, a domain name
suspension can be extended for one additional year, and the WHOIS for
the domain name shall continue to display all of the information of
the original Registrant and reflect that the domain name will not be
able to be transferred, deleted, or modified for the life of the
registration.”

	-- The WG agrees to the revised language.

	5. Overarching Data Collection Recommendation;
see: https://docs.google.com/document/d/1Yg6XP1USJFK7Ko5eQFD5EGNC4gwWM-vh07MGSqJ3e0Q/edit?usp=sharing
[docsgoogle.com] [41]

	ACTION ITEM: CHANGE TEXT TO “OVER THE PRECEDING PERIOD OF [NOT LESS
THAN EVERY 12 MONTHS].

	6. Individual Proposals Converted into Recommendations, beginning
with URS Recommendations; see:
https://docs.google.com/document/d/1qjiKBaAAMNPctSIwP932OKT6vrgkFXxdVYVf6DAz2no/edit?usp=sharing
[docs.google.com] [docs.google.com] [42]

	URS Rec # (was Individual Proposal #1):

	-- The WG agrees to the recommendation and accompanying sections.

	URS Rec # (was Individual Proposal #2):

	-- The WG agrees to the recommendation and accompanying sections.

	URS Rec # (was Individual Proposals #26 and #27):

	-- The WG agrees to the recommendation and accompanying sections.

	URS Rec # (was Individual Proposal #28):

	Discussion:

	-- Some support for “effective, enforceable, and published”.

	-- Some questions about what “enforceable” means and who would
enforce.

	-- WIPO has a declaration of independence and impartiality. 
Published on the web site.  Covers the same ground as conflict of
interest.

	-- Seems obvious that it is enforceable by the provider, but make
that clear.  Several WG members agree.

	-- “enforceable by the provider against examiners” and delete
“binds”.

	-- Need to note that you are enforcing against any examiner that
violates the policy.

	-- What is the concern we are looking to address?  

	-- “Each URS Provider shall have an enforceable published examiner
Conflict of Interest policy.”

	-- Others disagree on using the term “enforceable”.

	-- Take out “enforceable” and just say “published”.

	Revised Text Options for the WG to consider:

	Option 1:

	The Working Group recommends that the URS Rule 6 be amended to add a
requirement that each URS Provider shall have an effective and
published Conflict of Interest (COI) policy that the Provider enforces
against any Examiners who violates such policy

	Option 2:

	The Working Group recommends that the URS Rule 6 be amended to add a
requirement that each URS Provider shall have an enforceable and
published Examiner Conflict of Interest (COI) policy.

	Option 3:

	The Working Group recommends that the URS Rule 6 be amended to add a
requirement that each URS Provider shall have a published Examiner
Conflict of Interest (COI) policy.

	Option 4:

	The Working Group recommends that the URS Rule 6 be amended to add a
requirement that each URS Provider shall have a published Conflict of
Interest (COI) policy that the Provider may reasonably enforce against
any Examiner who violates such policy.

	ACTION ITEM: PUT THE FOUR OPTIONS FOR REVISED TEXT OUT FOR REVIEW BY
THE WG ON THE EMAIL DISTRIBUTION LIST AND DISCUSS DURING A FUTURE
MEETING.

	URS Rec # (was Individual Proposal #34):

	-- Note that the recommendation may conflict URS Rec #9.

	-- Could be that they complement each other – could bring to Rec #9
the bullet points on Implementation Guidance from the new URS rec, and
strike the recommendation.

	-- Useful guide for panelists, but shouldn’t be mandatory.

	-- No reason to have the conflicting individual proposal
recommendation.

	-- Consider adding the IG to Rec #9.

	-- Concerns about dropping this new recommendation; these aren’t
duplicative.

	-- Can we make the complementary?

	ACTION ITEM: STAFF TO SEND A SEPARATE EMAIL THAT WILL HAVE LINKS TO
BOTH OF THE RECOMMENDATIONS AND WILL ASK WG MEMBERS TO WEIGH IN ON 1)
WHETHER THESE SEPARATE RECOMMENDATIONS ARE IN CONFLICT OR
COMPLEMENTARY AND 2) IF THEY ARE IN CONFLICT SHOULD THE IMPLEMENTATION
GUIDANCE FROM THE NEW RECOMMENDATION BE INCORPORATED INTO REC #9.

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Links:
------
[1] mailto:zak at muscovitch.com
[2] mailto:Griffin at Winterfeldt.law
[3] mailto:brian.beckham at wipo.int
[4] mailto:julie.hedlund at icann.org
[5] mailto:gnso-rpm-wg at icann.org
[6] mailto:gnso-rpm-wg at icann.org
[7] mailto:Griffin at Winterfeldt.law
[8] mailto:brian.beckham at wipo.int
[9] mailto:zak at muscovitch.com
[10] mailto:julie.hedlund at icann.org
[11] mailto:gnso-rpm-wg at icann.org
[12] mailto:gnso-rpm-wg at icann.org
[13] mailto:brian.beckham at wipo.int
[14] mailto:zak at muscovitch.com
[15] mailto:Griffin at Winterfeldt.law
[16] mailto:julie.hedlund at icann.org
[17] mailto:gnso-rpm-wg at icann.org
[18] mailto:gnso-rpm-wg-bounces at icann.org
[19] mailto:Griffin at Winterfeldt.law
[20] mailto:julie.hedlund at icann.org
[21] mailto:gnso-rpm-wg at icann.org
[22] https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en
[23] mailto:gnso-rpm-wg-bounces at icann.org
[24] mailto:julie.hedlund at icann.org
[25] mailto:gnso-rpm-wg at icann.org
[26] https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en
[27] https://www.icann.org/resources/pages/udrp-rules-2015-03-11-en
[28] mailto:griffin at winterfeldt.law
[29] mailto:gnso-rpm-wg-bounces at icann.org
[30] mailto:gnso-rpm-wg at icann.org
[31]
https://docs.google.com/document/d/1qjiKBaAAMNPctSIwP932OKT6vrgkFXxdVYVf6DAz2no/edit?usp=sharing
[32]
https://docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing
[33] mailto:gnso-rpm-wg-bounces at icann.org
[34] mailto:julie.hedlund at icann.org
[35] mailto:gnso-rpm-wg at icann.org
[36] mailto:gnso-rpm-wg at icann.org
[37]
https://communityicann.org/display/RARPMRIAGPWG/2020-10-01+Review+of+all+Rights+Protection+Mechanisms+%28RPMs%29+in+all+gTLDs+PDP+WG
[38]
https://urldefense.com/v3/__https:/docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing*20*5bdocs.google.com*5d__;JSUl!!PtGJab4!viwPahgRdyDaYI1QnH4o6SssNP1HyOdHX9Yl7QDtKMfV-ZMJDRsQ9Jz3ch5aeO-25dFeTSaDsQ%24
[39]
https://urldefense.com/v3/__https:/docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing*20*5bdocs.google.com*5d__;JSUl!!PtGJab4!viwPahgRdyDaYI1QnH4o6SssNP1HyOdHX9Yl7QDtKMfV-ZMJDRsQ9Jz3ch5aeO-25dFeTSaDsQ%24
[40]
https://urldefense.com/v3/__https:/docs.google.com/document/d/1huKNcgg3VAk95oybb-7u9papLZ4kEMUHNQNElMPWMFY/edit?usp=sharing*20*5bdocs.google.com*5d__;JSUl!!PtGJab4!viwPahgRdyDaYI1QnH4o6SssNP1HyOdHX9Yl7QDtKMfV-ZMJDRsQ9Jz3ch5aeO-25dFeTSaDsQ%24
[41]
https://urldefense.com/v3/__https:/docs.google.com/document/d/1Yg6XP1USJFK7Ko5eQFD5EGNC4gwWM-vh07MGSqJ3e0Q/edit?usp=sharing__;!!PtGJab4!viwPahgRdyDaYI1QnH4o6SssNP1HyOdHX9Yl7QDtKMfV-ZMJDRsQ9Jz3ch5aeO-25dEO9RdHog%24
[42]
https://urldefense.com/v3/__https:/docs.google.com/document/d/1qjiKBaAAMNPctSIwP932OKT6vrgkFXxdVYVf6DAz2no/edit?usp=sharing*20*5bdocs.google.com*5d__;JSUl!!PtGJab4!vZsg2hS1Risic1U8X8epV-sBDbYhlVUJXZ77LI1Q0wSRqEnapuPVHsTKSjS9nSBYoTRPwmVg2A%24

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