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

[Vaughn Liley]

Morning Catherine,

I can confirm that they are the only changes.

Kind regards,



Vaughn Liley
*General Manager | .link*


On Wed, 19 Oct 2022 at 00:49, Catherine Merdinger
<catherine at identity.digital> wrote:

> 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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