[ALAC] RAA 3.7.8

[Alan Greenberg]

Holly, the Whois accuracy program specification does go into some 
detail about what validations are to be done (still not agreed to by 
registrars). Given the fact that this *might* be the last opportunity 
to alter the RAA before adoption, if you feel that there needs to be 
further definition or clarity in those words, you need to propose 
alternative wording now. I personally think that we will not get a 
lot more clarity into those words "in this coming version" than what 
ICANN is now requesting, so I am not sure the effort is well placed 
at this time.

But that was not the issue that Garth raised on the call, nor what he 
had earlier proposed (https://community.icann.org/x/SQcQAg). His 
issue was whether the provisions required to registrar to take action 
if there were inaccuracies identified (even within the current weak 
definitions, such as not having an @ sign in an e-mail address, or 
having no address or phone number at all), or whether they could 
safely ignire the requirement with impunity. The latest draft sets a 
time limit and very clearly tells the registrar what actions they 
need to take if they are to be compliant with the RAA.

Alan

At 22/03/2013 03:40 PM, Holly Raiche wrote:
>Hi Alan
>
>Not that simple
>
>What is meant by 'at the time' - this was one of the issues raised - 
>and not agreed to - in the negotiations.  Is it solved?
>
>As the Final Final report said, the requirement for re-verification 
>hasn't worked
>
>What is meant by 'accurate' - or 'inaccurate' - the clause talks 
>about a policy that would define what is reasonable and commercially 
>practicable to obtain accuracy.  It doesn't exist and we do not know 
>what is meant - or rather what the registries and registrars believe 
>it means.  Michele, for one, has used different terms and made some 
>suggestions. There was a whole session two ICANN's ago on what it 
>might mean.....
>
>So Alan - on the face of it, you are correct.  But if there is no 
>understanding/agreement of what the terms mean, enforcement is an issue.
>
>On Monday, I"ll be doing a lot of work to contribute to the 
>discussion but please, do not pretend that clause 3.7.8 is 
>enforceable, even with the new bits.
>
>Holly
>On 23/03/2013, at 5:57 AM, Alan Greenberg wrote:
>
> > Garth, on the recent teleconference on the RAA you raised the issue
> > of RAA 3.7.8 and said the problem of its being unenforceable by ICANN
> > was still not resolved.
> >
> > As I read it, 3.7.8 (and associated specifications) now says:
> >
> > - verification of contact information at time of registration required
> > - periodic re-verification
> > - upon notification of inaccuracy
> > - if inaccurate information is found and not corrected within 15
> > days, registrar must terminate or suspend registration, or place it
> > on clientHold.
> >
> > If the registrar does not do this, they have violated the terms of the RAA.
> >
> > What more is it that you are looking for?
> >
> > Alan
> >
> > _______________________________________________
> > ALAC mailing list
> > ALAC at atlarge-lists.icann.org
> > https://atlarge-lists.icann.org/mailman/listinfo/alac
> >
> > At-Large Online: http://www.atlarge.icann.org
> > ALAC Working Wiki: 
> https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALAC)