[RRA] RRA Amendment Notification for .link [ ref:_00D616tJk._5004MtpC4w:ref ]

Tue Oct 18 22:49:20 UTC 2022

Hi Vaughn,

I just want to confirm, the addition of the URS language and the UK IDTA
are the only changes from the version we recently reviewed?  If there are
other changes, can you please call them out?

Thanks,
Catherine
*Catherine Merdinger **| *Corporate Counsel *| Identity Digital *Inc. *|*
+1.319.541.9416 *| *she/her

On Sun, Oct 16, 2022 at 10:40 PM Vaughn Liley <vaughn at nova.link> wrote:

> Morning Catherine,
>
> Please find attached the revised redline version of the proposed RRA
> relating to case number 01152917.
>
>
>
> I would like to draw your attention to section 2.17 which we believe
> addresses the Rights Protection Mechanisms (RPMs) that are required per the
> Specification of the registry agreement (RA).
>
>
>
> *2.17 Registrar shall include in its Registration Agreements a provision
> prohibiting Registered Name Holders from distributing malware, abusively
> operating botnets, phishing, piracy, trademark or copyright infringement,
> fraudulent or deceptive practices, counterfeiting or otherwise engaging in
> activity contrary to applicable law and provide consequences for such
> activities including suspension of the domain name without notice or such
> other actions as may be deemed appropriate.*
>
>
>
> In addition, we have addressed the request to incorporate the UK IDTAs
> (SCCs) in our Data Processing Addendum for registrars to execute as
> applicable. As an EU based business, it does not make sense for us to
> include UK specific clauses and instead we propose to include the following
> clause in the Data Processing Addendum.
>
>
>
> *5b) A Party may only transfer Shared Personal Data relating to EU
> individuals to outside of the European Economic Area (“EEA”) (or, if such
> Shared Personal Data is already outside of the EEA, to any third party also
> outside the EEA), in compliance with the terms of this Data Processing
> Addendum and the requirements of Applicable Laws, the latter including any
> relevant Adequacy Decision of the European Commission or the use of EU
> ‘Standard Contractual Clauses’. Where Standard Contractual Clauses for data
> transfers between EU and non-EU countries are required to be executed
> between the Parties, they may be found and downloaded, to be incorporated
> herein as part of this Data Processing Addendum upon execution, at *
> *https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en*
> <https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en>* or
> as set out in the attached International Data Transfer Addendum Annex 2 (or
> such link location as may be updated from time to time).*
>
>
>
> I trust these updates meet with the approval of the Registrar Stakeholder
> Group.
>
>
>
> I look forward to your feedback.
>
>
>
> Kind regards,
>
>
>
> Vaughn Liley
> *General Manager | .link*
>
>
> On Thu, 15 Sept 2022 at 16:06, Catherine Merdinger
> <catherine at identity.digital> wrote:
>
>> Whoops - forgot to include the typographical errors - I blame the jet lag
>> as I recently arrived in KL.  Find the list below.
>>
>>
>>    - 1.14.    "Registry Agreement" means the agreement between the
>>    Registry Operator and ICANN controlling the terms and conditions of
>>    Registry Operator’s license to operate and maintain the TLD…. [add
>>    “agreement”]
>>    - 2.1.      System Operation and Access. Throughout the term of this
>>    Agreement, the Registry Operator’ …. [delete apostrophe]
>>    - 2.28. … Unless Emergency Circumstances require a shorter notice
>>    period, the Registry Operator will provide Registrar with at least thirty
>>    (30) days’ notice prior to the implementation of material changes
>>    [add “days”]
>>
>> *Catherine Merdinger **| *Corporate Counsel *| Identity Digital *Inc. *|*
>>  +1.319.541.9416 *| *she/her
>>
>>
>>
>> On Thu, Sep 15, 2022 at 10:04 PM Catherine Merdinger
>> <catherine at identity.digital> wrote:
>>
>>> ICANN,
>>>
>>> Overall, the registrars do not have any major concerns about the
>>> proposed RRA amendments, though we have noted a few typographical errors
>>> below, which we would ask the Registry Operator to correct in the final
>>> version.  We would also like to encourage the Registry Operator to
>>> incorporate the UK IDTAs (SCCs) in their Data Processing Addendum for
>>> registrars to execute as applicable.  We are making this request of every
>>> registry operator whose RRA we are reviewing and would be delighted to
>>> expedite the review of such additional language.
>>>
>>> Thank you, as always, for the opportunity to review the proposed changes.
>>> Catherine
>>> *Catherine Merdinger **| *Corporate Counsel *| Identity Digital *Inc.
>>> *|* +1.319.541.9416 *| *she/her
>>>
>>>
>>>
>>> On Fri, Aug 26, 2022 at 1:12 AM ICANN Global Support Center <
>>> globalsupport at icann.org> wrote:
>>>
>>>> Hello Ashley,
>>>>
>>>> Attached, please find the cover letter and the red-lined RRA Amendment
>>>> for the following TLD(s) submitted by *Nova Registry Ltd* to be shared
>>>> with your Stakeholder Group:
>>>>
>>>>    - *.link*
>>>>
>>>> Please respond by 23:59 UTC on *15 September 2022* to let us know if
>>>> your Stakeholder Group has concerns, does not have concerns, or if
>>>> additional review time is required.If the Stakeholder Group has concerns,
>>>> ICANN org will continue with the next step of the RRA Amendment Procedure,
>>>> which is to consult with the RrSG and the Registry Operator to attempt to
>>>> resolve any such concerns.
>>>>
>>>> Warm Regards,
>>>> Maritza Alarcon
>>>> GDS Service Delivery
>>>>
>>>> ref:_00D616tJk._5004MtpC4w:ref
>>>>
>>>
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