[PC-NCSG] [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 1.3.3

Stephanie Perrin stephanie.perrin
Thu Apr 30 07:32:53 EEST 2015


I sent it to the list, no response so far.  I will try to draft 
something up tonight.
Thanks for the support Kathy!
Cheers SP

On 2015-04-30 11:14, Kathy Kleiman wrote:
> I agree with Stephanie - strongly. Why not ask for a single additional 
> question:
>     - is this type of content regulation outside of ICANN's balliwick 
> and the proper province of national law?
> Then we can all answer yes.
>
> I think someone other than me should do this since I raised the first 
> round of big questions on the text. Stephanie?
> Best,
> Kathy
>
> On 4/29/2015 11:53 AM, Stephanie Perrin wrote:
>> I believe the proposed language is biased, and leading.  It prompts 
>> people to answer questions that favor the minority who were still 
>> pushing to ban use for commercial transactions.  Every IP law student 
>> in American is probably being told to send in their comments on these 
>> three questions. IF you are going to ask these three questions to 
>> clarify their position, then we need three questions on our side (it 
>> is late here, all i can think of right now is Do you believe in human 
>> rights?  If so, do you think ICANN should protect them or annihilate 
>> them?  (getting a wee bit grumpy with the amount of work coming our 
>> way.....:-) )
>> cheers steph
>> PS and yes we can leave it in and comment on it, but I think the 
>> questions in the initial report should be balanced.
>> On 2015-04-29 20:02, Amr Elsadr wrote:
>>> Hi Stephanie,
>>>
>>> Thanks for forwarding this. I certainly agree with your take on 
>>> this, although I can see why the many IPC members of the 
>>> PPSAI-PDP-WG would not. As far as I know there are no laws 
>>> prohibiting, or even addressing the use of privacy/proxy services by 
>>> any kind of registrant (commercial or other). I certainly do not 
>>> agree that ICANN should start classifying registrants based on their 
>>> intended use of a domain name. I?m actually not sure how a 
>>> privacy/proxy service provider can do this at the time of 
>>> registration. Is a registrant supposed to indicate his/her/its 
>>> intent of use of the domain name at the time of registration? What 
>>> if the intent changes after registration? Is this a tactic to revoke 
>>> privacy services from a domain name already using one? And I see no 
>>> reason why there should be any special consideration for commercial 
>>> registrants of any kind anyway (I mean in principle). Local laws (as 
>>> far as I know) require that businesses with a web presence publish 
>>> contact information on their websites, so as far as local laws are 
>>> concerned, it?s more of a web content issue than a domain name 
>>> registration issue.
>>>
>>> I find it a bit surprising, with the initial report looming in the 
>>> near future, that three of the original charter questions have still 
>>> not been adequately addressed. From your email, I?m guessing there 
>>> have been significant discussions, but why hasn?t the WG taken a 
>>> position after all this time? What are the consensus levels looking 
>>> like around the answers to those questions? What are the RrSG and 
>>> At-Large folks thinking on these questions?
>>>
>>> Also, when you say /*?we need to act fast if there is agreement in 
>>> NCSG to push back?*/, what exactly do you mean? Where does the NCSG 
>>> or NCSG PC fit into this at this time? This is still a WG 
>>> discussion, right? Soon, we will have the opportunity to comment on 
>>> the initial report, but is there something you are asking us to do 
>>> before then?
>>>
>>> Thanks.
>>>
>>> Amr
>>>
>>> On Apr 29, 2015, at 12:55 AM, Stephanie Perrin 
>>> <stephanie.perrin at mail.utoronto.ca 
>>> <mailto:stephanie.perrin at mail.utoronto.ca>> wrote:
>>>
>>>> Hi folks, I am forwarding to you my latest missive to the privacy 
>>>> proxy services working group.  While this is very instructive to 
>>>> see how ICANN operates as an institution, particularly when the IPC 
>>>> is chairing, we need to act fast if there is agreement in NCSG to 
>>>> push back.  We are on our 74th working group meeting apparently now 
>>>> and there is a push for closure as you can see below....they want 
>>>> the 100 page report out for comment by May 4.  We have been 
>>>> demanding a longer comment period so we can reach out to users of 
>>>> privacy proxy services, suggestion is 60 days.   The issue of use 
>>>> of proxy services by those "conducting commercial activity" in the 
>>>> view of facebook and the IPC includes a charity asking for 
>>>> donations (even though the financial bit is through a  provider 
>>>> service) or an entity of individual serving ads and thereby getting 
>>>> micropayments.  This is a matter for national law in my view, and 
>>>> ICANN should not be dabbling in it.  It guts privacy.  I would 
>>>> remind everyone thinking about this for the first time that the 
>>>> argument is being made on the basis of a web service paradigm, but 
>>>> it would have to be implemented in a way that includes the 
>>>> stockpiling of names that are not being actively used, or are only 
>>>> used for email.
>>>>
>>>> Advice on pushback welcome, I have not even waited to consult my 
>>>> colleagues on the group as time is pressing; I know we have been 
>>>> fighting this for a year and a half and I spent a lot of time on 
>>>> the EWG fighting back Facebook on the same issue.
>>>> Reactions and strategy??  AS you can see I am protesting the short 
>>>> turn around time for dissenting statements too....although Kathy no 
>>>> doubt has anticipated a slimey move like this one and has one 
>>>> written just in case:-) With respect to strategy.....if we leave 
>>>> this in we have a lovely headline (ICANN moves to restrict privacy 
>>>> proxy services for endangered groups and human rights workers).
>>>> cheers Stephanie
>>>> PS yes I do know this is only a consultation, but it is the big 
>>>> one....especially with no reply comments period.
>>>> -------- Forwarded Message --------
>>>> Subject: 	Re: [Gnso-ppsai-pdp-wg] PPSAI Comment Period and Section 
>>>> 1.3.3
>>>> Date: 	Wed, 29 Apr 2015 07:39:04 +0900
>>>> From: 	Stephanie Perrin<stephanie.perrin at mail.utoronto.ca>
>>>> To: 	gnso-ppsai-pdp-wg at icann.org
>>>>
>>>>
>>>>
>>>> SInce I think there is a distinct set of questions that can be 
>>>> asked on the other side, and that indeed have been asked, I would 
>>>> not support the inclusion of this set of (in my view) leading 
>>>> questions without the opposing questions.  To do so would be to 
>>>> reflect a fundamental bias.  I would prefer to say something along 
>>>> the lines of the use of proxy services by commercial entities could 
>>>> be restricted by national law, where such law applies.
>>>> I believe we had a lengthy discussion about defining commercial 
>>>> activity.  It seems to me it is not for ICANN to impose such 
>>>> restrictions on Internet activity through its limited remit over 
>>>> domain name registration, a point which we have made repeatedly.
>>>> If you are going to insist on the inclusion of this (in my view 
>>>> leading) text then we need a few more days to prepare an opposing 
>>>> statement.....April 30 is an artificial deadline which I am 
>>>> surprised to see announced at this late date.
>>>> cheers Stephanie
>>>>
>>>> On 2015-04-29 6:17, Graeme Bunton wrote:
>>>>> Thanks to all WG members for a very productive call earlier 
>>>>> today(and to Steve for his chairing acumen).  The co-chairs and 
>>>>> staff met this afternoon to tie down two loose ends from the call.
>>>>>
>>>>> Regarding the deadline for public comments on the Initial Report, 
>>>>> we recognize there is considerable support for extending the 
>>>>> public comment period to 60 days instead of the standard 40 days 
>>>>> on which we have all been planning.   We are prepared to agree to 
>>>>> this, but with the caveat that this will have repercussions on the 
>>>>> pace and intensity of our work once public comments have been 
>>>>> received. Specifically, if the public comment deadline is extended 
>>>>> until July 3 (60 days after our publication date of May 4), we 
>>>>> will need to plan on at least weekly calls throughout July and 
>>>>> August, some of which may need to be more than an hour in length, 
>>>>> to review these comments and move toward a Final Report.  
>>>>> Otherwise, we jeopardize the prospects for getting the Final 
>>>>> Report in front of the GNSO council no later than the Dublin ICANN 
>>>>> meeting.  As was noted on the call today, many additional steps 
>>>>> need to take place even after this WG issues its Final Report 
>>>>> before any new accreditation system can be implemented, so the 
>>>>> time pressure imposed by the expiration of the Interim 
>>>>> Specification at the end of next year is already real.
>>>>>
>>>>> Also, as previously announced over the past few weeks, if any WG 
>>>>> members (or group of members) wish to submit a brief separate or 
>>>>> additional statement for inclusion in the package posted for 
>>>>> public comment next Monday, such statements need to be received by 
>>>>> staff no later than Thursday, April 30.
>>>>>
>>>>> Lastly, the other loose end involves proposed revisions to section 
>>>>> 1.3.3 of the Initial Report, which were presented on the call 
>>>>> earlier today but which we did not have time to discuss fully.  We 
>>>>> agree that this section could benefit from some revision, but 
>>>>> believe it should take the form of greater concision, not 
>>>>> additional presentation of arguments for the divergent positions.  
>>>>> Thus we suggest that section 1.3.3 be revised to read as follows:
>>>>>
>>>>> ---
>>>>>
>>>>>     Although the WG agreed that the mere fact that a domain name
>>>>>     is registered by a commercial entity or by anyone conducting
>>>>>     commercial activity should not preclude the use of P/P
>>>>>     services , there was disagreement over whether domain names
>>>>>     that are actively used for commercial transactions (e.g. the
>>>>>     sale or exchange of goods or services) should be prohibited
>>>>>     from using P/P services. While most WG members did not believe
>>>>>     such a prohibition is necessary or practical, some members
>>>>>     believed that registrants of such domain names should not be
>>>>>     able to use or continue using proxy or privacy services.
>>>>>
>>>>>     For those that argued that it is necessary and practical to
>>>>>     limit access to P/P services to exclude commercial entities,
>>>>>     the following text was proposed to clarify and define their
>>>>>     position: ?domains used for online financial transactions for
>>>>>     commercial purpose should be ineligible for privacy and proxy
>>>>>     registrations.?
>>>>>
>>>>>     Public comment is therefore specifically invited on the
>>>>>     following questions:
>>>>>
>>>>>       * Should registrants of domain names associated with
>>>>>         commercial activities and which are used for online
>>>>>         financial transactions be prohibited from using, or
>>>>>         continuing to use, privacy and proxy services?
>>>>>       * If so, will it be useful to adopt a definition of
>>>>>         ?commercial? or ?transactional? to define those domains
>>>>>         for which P/P service registrations should be disallowed?
>>>>>         And if so, what should the definition(s) be??
>>>>>       * Will it be necessary to make a distinction in the WHOIS
>>>>>         data fields to be displayed as a result?
>>>>>
>>>>> ---
>>>>> Thanks,
>>>>>
>>>>> Graeme Bunton & Steve Metalitz
>>>>>
>>>>> -- 
>>>>> _________________________
>>>>> Graeme Bunton
>>>>> Manager, Management Information Systems
>>>>> Manager, Public Policy
>>>>> Tucows Inc.
>>>>> PH: 416 535 0123 ext 1634
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> Gnso-ppsai-pdp-wg mailing list
>>>>> Gnso-ppsai-pdp-wg at icann.org
>>>>> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
>>>>
>>>>
>>>>
>>>> _______________________________________________
>>>> PC-NCSG mailing list
>>>> PC-NCSG at ipjustice.org <mailto:PC-NCSG at ipjustice.org>
>>>> http://mailman.ipjustice.org/listinfo/pc-ncsg
>>>
>>
>

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mailman.ipjustice.org/pipermail/pc-ncsg/attachments/20150430/a0272c41/attachment-0001.html>



More information about the NCSG-PC mailing list