[lac-discuss-en] RV: ICANN News Alert - ICANN Seeks Public Comment on 2013 RAA Data Retention Specification Data Elements and Legitimate Purposes for Collection and Retention
asoto at ibero-americano.org
asoto at ibero-americano.org
Thu Apr 3 23:57:06 UTC 2014
[[--Translated text (es -> en)--]]
Subject: Re: RV: ICANN News Alert - ICANN Seeks Public Comment on 2013 RAA Data Retention Specification Data Elements and Legitimate Purposes for Collection and Retention
From: asoto at ibero-americano.org
Impeccable Ada. The period I had said was to discuss the
list, but until now there were only three comments. The term
pblicos comments estarabierto to 23:59 UTC on April 21.
Thank you and congratulations on your dedication!
Alberto Soto
From: Aida Noblia [mailto: aidanoblia at gmail.com]
Posted on: Thursday, April 3, 2014 08:36 pm
To: Alberto Soto
CC: Fatima Cambronero; LACRALO Espaol
Subject: Re: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN
Seeks Public Comment on 2013 RAA Data Retention Data Elements Specification
and Legitimate Purposes for Collection and Retention
Hello everyone:
Thanks Alberto for comprehensive information. Also not to bore and
I have direct information, leave the link to the government site where
legislacin are national and some of the Latin American and
national jurisprudence <http://www.datospersonales.gub.uy/>
www.datospersonales.gub.uy.
Although the term is not estvencido you posted if the comment period
or at least as Decas understand that the issue is very important.
That and because I can not send this wiki because I can not enter because
There were problems with the wiki, mailing them this vein that drafted
A couple of comments, which are requested prior to focus specifically on
the declaration:
On the one hand these new rights to access personal data and information,
ESTN will still not incorporated in the paradigms of the people, it is very
asymmetrical process, many do not know it, human rights are new
generation of the Digital Age, will inserting into the consciousness of the
people.
In different countries the real gap is so great that many people do not
understand that these are your rights, claiming that ESTN other
emergency department: safe streets, stop violence, hunger, right
health, etc..
I understand that from the point of view of ICANN's good to know these
provisions topic has already been studied for the last time in the EWG
According mencionCarlton in B. Aires last year.
On the other hand: the same laws have exceptions, pretty
strict and limited, even in respect of periods of comunicacino
preservation of data, there are other community interests
priority, eg set them in the bublic data sources or lists,
Database or the Central Bank on credit data, or the
characteristics determined by law. What are the exception pblicos
the data of your credit responsibility of persons (defaults,
etc.) for a specified period, for protection of stability
financial market.There are also other for certain FIELDS, but
to omit the subject to focus on, we ESTN in laws.
In the specific case raised from the declaration, the exencin occurs for
protect interests of records, given their difficulties in
meeting legal standards, according to the statement made by the interested parties.
I think from the point of view of ICANN's good to know the
laws, an issue that has already been studied in the EWG According mencionCarlton
B. Aires last year.
But it is also necessary to consider the specific reason and
proposed target is a particular problem, referred to the
Declaration dealing with the issue of establishing an appropriate policy of ICANN
globally, that can address the needs of the services
provides, without prejudice to laws, but assume no responsibility for
issues that do not belong legally and without exemptions, the
case, impair the reliability, stability and safety
ICANN provides service to the community.Establishing the new AAR
applicant's responsibilities and recorder, which, by
exencin procedure referring to the Declaration under study,
Free registration to release the preservation of data.
Aquhay solve a particular problem is not only in this
Declaration on the matter on which they are made these comments. ICANN not
you can free the parties to a legal obligation because it has
powers for that. Try to solve the problem for hold serve
reliably and safely, mxime with the new risks posed by
new gTLDs. But it is not and never was the owner of the database or which
receive and control data or maintained.
That was an obligation to the applicant, who will pay for
manage the domain and is entitled to claim that you pay as
legal. Also the applicant has in turn obligation to provide
and update data.That "bottom-up" system applies regarding the
as cooperation and responsibility for system operation
global, because who is the owner of the data is that estprotegido by
the system, usually the more interested in protecting their data, and that
ms can contribute them directly in the minimum time.
On the issue of liability, which is the game who are in the
Records if you're seeing, it is very clear who they are the
responsible and qu. Whether the new RAA (Registracin Agreements)
In other cases even legal exemptions to the preservation of data
personal, for example in Uruguay, with regard to the credit bureau
credit that mencionantes, expressly provides that persons
physically challenged and legal bodies of the system of financial intermediation that provide
the information contained in the Central Credit Risk by the
Central Bank of Uruguay Sern the Nicaraguan responsible for the accuracy and
Upgrading of the same.
The database takes the Central Bank, which is a third, but remains
clearly not responsible for the content of the database because only maintains
one computer system based on data that are provided. It is this
responsibility who are game, which is governed by the logic of justice
responding by themselves or dependent events. The Bank responds
the proper functioning of the computer system holding base
data online.
I understand that in the case of ICANN, any exencin be made, it should be
expressly stated that ICANN does not assume responsibility for any
reglamacin that might arise in this regard. This I can not overemphasize
importance to ICANN interspblico defense and compliance
their own purposes.
The problem arises reason of the complexity added by the incorporation of
new gTLDs, which increases exponentially the Administration and
handling a much larger amount of data, which means reception,
control data quality, conservation, modification processes
where appropriate, or if cancelacin. The way in which regulates
Now mejorarindidablemente the quality of data and service
general.
The position of the records before this is trying to break free from the
complexity and in the case of the obligation of preservation of data Ass
have these problems and these responsibilities, but ms delegacin
there, ICANN is not and never was the owner of the database are as
earlier records responsible recoleccin as both the
conservation.
The interest of ICANN, is not the same as the registers, it is more
Overall, properly manage and secure and reliable Internet
and all domains.Must be address the interests and needs of
PARTS AND all involved, that's what your own funciny
purpose. In this case, ICANN requires desempear well the function that has
good of the Internet community, not in their benefit, working
for the same security network and generated the least amount possible
Conflict: accurate, relevant, not excessive, and timely data ...
quality and quantity of data, delete Erroneous, extemporneos data
store the necessary for the time necessary to better meet your
function.
The records remain responsible base as always, what
they can handle in maintaining recolecciny data, but with
a specialized service that supports them so that they can better fulfill their
function in the new era and these new domains. What is outsourced
to improve is a part of their work, which is part of your business. This
is not a criticism, but simply the situation is in fact what we are
expressing.
I understand why estbien the Declaration, agree with it and
with trying those who are responsible and have its economic advantage in
activity they provide, also comply with the rules properly, and
that if ICANN internally exonerate the relationship, arise
sb injury is not ICANN OF ANY way responsible for it,
subsisting liability on those who have legally. although they
but involves higher costs. I understand this must be expressly
drawn up and signed by both parties.
Otherwise injured party will be able to understand that ICANN exempt
registrars of the responsibility is on the keychain subrogating
consequences that may prepare legal bodies for the fact registrars
not comply with the conservation of the data.
Greetings to all
The March 27, 2014, 0:58, Alberto Soto <asoto at ibero-americano.org
<mailto:asoto at ibero-americano.org> > Wrote:
Ada and all.Our laws (Uruguay and Argentina), inspired ESTN
LSI espaola, asque may differ somewhat in form but not in substance.
Argentina's Law of Personal Data Protection does not speak of retention of
data communications. S, there was a law on this last topic, but was
left in suspension by the numerous criticisms received.
The Act Argentina is the No. 25326, which also defines personal data
(Information of any kind referred to physical persons or existence
ideally determined or determinable; and sensitive data (personal data
revealing racial and ethnic background, policies opinions, convictions
religious, Philosophical or moral, union affiliation and information
concerning health or sex life).
Also defines Data processing: Operations and procedures
sistemticos, electrnicos or not, enabling the recoleccin, conservation,
ordenacin, storage, modification, relationship, evaluation,
blockade, destruction, and general processing of personal data, as
as also his third cesina to Travs communications, consultations,
interconnections or transfers.
With regard to information security, our law says: 1. The
responsible or user data file must adopt measures techniques
and organizational measures necessary to ensure the safety and
confidentiality of personal data, in order to avoid adulteracin,
loss, or unauthorized consultation, and to detect
deviations, intentional or otherwise, of information, whether the risks
from human action or technician medium used.
Two. It is prohibited to record personal data in files, records or
banks not renan techniques Payment integrity and security.
Regarding confidentiality: 1.And responsible persons
involved at any stage of the processing of personal data ESTN
bound to secrecy regarding the same. Such obligation
subsistiraun completed after his relationship with the owner of the file
data.
Two. The forced podrser relieved of secrecy by resolution
court and for compelling grounds relating to public safety,
national defense or public health.
Regarding the Cesin Data: 1. Personal data object
treatment can only be assigned to fulfill the purposes
directly related to the legitimate interest of the transferor and
assignee and with the consent of the owner of the data, which
must be informed about the purpose of identifying the CESINE
transferee or the elements to do so.
After this long introduction, I must agree with you on virtually
everything.
I understand that both a Registrar as a Registrant, have (or MUST
have!) an appropriate technology infrastructure needs.This is
say that they have an adequate system of information security, with
separations between their servers and production management areas,
including systems development if they have this area. In addition to
its internal communications network, separated and denied access
between different areas, elemental a service provider
internet. This, in addition to comply with the local laws of protection of
personal data.
This would involve, for example, that the data elements described in the
points 1.1.8 (Processing recurring payments); and 1.2.1. (Information
on concurrent payments) ESTN sheltered in a different place
elements Whois data, which access to them is
only possible for this last free, and internal staff
registrar or registrant to information of the aforementioned tems, which
contain associated names, credit cards, addresses, etc.. It
states that if the source of payment information is deleted, not a registrant
tendrmanera evaluate claims dispute facturacino
Returns the position of the process.In many cases in dispute with
credit cards or bank charges.
The legislation this estrelacionado with each country. In Argentina, the
credit cards and banks have the obligation to keep such
of information for many years; at this time I do not remember if there are seven
or ten years. If as there are at least two places with information
necessary.
With regard to the issues of hacking, irregular domain sale by deception
Buyer, etc.., speaks of a aooms of data retention. This
term must have prescripcin relationship with the crime,
because if barred two years, I should not keep them for three years.
I understand that retention periods are set, because this issue has been and
remains very controversial because it requires storage measures
additional security, etc.. And msan being traffic data.
I hope I have not bored
Best Regards
Alberto Soto
From: Aida Noblia [mailto: aidanoblia at gmail.com <mailto:aidanoblia at gmail.com> ]
Posted on: Wednesdays, March 26, 2014 4:55 pm
To: Alberto Soto
CC: Fatima Cambronero; LACRALO Espaol
Subject: Re: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN
Seeks Public Comment on 2013 RAA Data Retention Data Elements Specification
and Legitimate Purposes for Collection and Retention
Fatima, Alberto, Alejandro and all
Ses understand that a very important issue, and also in the complex
laws, I could not attend the roundtable mencionFtima is
You can listen any recording? is still some time for
comments? I am not clear what is the closing date for comments.
National legislation on protection of personal data are
rather strict, and also the right of access to information
pblica because ahestara the limit necessary to know what can and
must publish and what not, with quextensin, for how long, quines
they can do it, you can publish lbremente qudatos cules and require
free, express, written consent of the owner ...
In Uruguay the Law 18331 and its implementing regulations refer to the
protection of personal data (qualified in two types (sensitive or not)
As a human right protected by the constitution of the Republic. It
provides the owner of the personal data ARCO rights acronym that
level legislation includes right to access the database,
Corrigendum of Erroneous or modified in reality data correction
of Erroneous or inaccurate data and Oposicina done what the law calls
"Treatment" of the data that is generally any use of such data
personal, without the express written consent of its owner.
There is a Regulatory Unit Registration and Control of such data by the
Agency electronic government, in the Register of the Specifications
contain mandatory for all personal data that has a base, and
is of public or private persons, controls, and procedures performed
auditing and punishing violators with fines and even closure of the
database.
There is a base charge and take charge of the practice by
account of others or their own. The law regulates their responsibilities. The
Database Owner, or physical person jurdica is responding by
use or processing of personal data to the owner of that data.
An when they can use or deal in certain circumstances,
consent of the owner or in cases of data that supports your
treatment without l, personal data can not be used for other
purposes for which the owner permitted use.
The base is responsible for its own use or who decides: The data
personal is collected for a purpose and should be eliminated one
Once cumplila purpose for which it was collected, can be
transmit only in certain conditions .. etc.. It is the responsibility of the
base, which can be physical or legal person to whom the owner of the
Data may be enforced or penalties that may apply.
With variations, this is repeated in the legislation. In case of transfer
international data international law applies, and therefore there will
to analyze what is the applicable law and jurisdiction competition.
In the case of ICANN, the owner of the database is not ICANN, for
therefore is not legally responsible for processing that may occur to the
personal data.
According saw, in the system of the new agreement, the service is outsourced,
To improve it in terms of the quality of the data and also about its
treatment, but that does not mean the change of ownership.
So ICANN agrees the "excencin" of data retention in some
analyzing specific cases and by a special procedure, but
harming the intended service users improve this
new medium.
This is done at the request of the records to be released from their
liability because by not having to keep the data in accordance with
According to ICANN no longer have to answer to the law for their
conservation, damage, misuse, etc.. It emphasizes the need for the
good faith by the owner or holder of the database (check in)
which contains the data, though this good faith is a matter of difficult
certain proof.
Also, to not keep such data prevents any possibility
fulfill the functions of ICANN in such cases, with respect to the prevention of
damages that may result from misuse of domain names and
similar.
The issue in each case is to analyze these requests, if you really
retention of such data is necessary for the service prestacin
to Travs registry is provided or if it constitutes a violation of the
law. The blog that cases can be referred to and do not appear
so rare. And the position of registrars is clearly find that
facilitate their task. but in this case may be against the effectiveness and
completeness of the service provided by ICANN. From what has already been given and can
see on the web, it seems that security prevails. But the ms allde
presentation requirements of having the case (with reports of attorney, etc.
) Should be studied very well in that case is given rather than presumed
good faith as a way to resolve these cases.
Otherwise give an endorsement by the owners of the Records
released from liability, affect the risk of compliance
other obligations, affect all other obligations of the
Register and its owner as dueoo who treats data.
As decan seems a matter of interest.
Regards
3/22/2014 20:59 GMT-03: 00 Alberto Soto <asoto at ibero-americano.org
<mailto:asoto at ibero-americano.org> >:
Fatima, only Sern 04:00 am in Buenos Aires but I promise participate.
Thank you!
Alberto Soto
From: Fatima Cambronero [mailto: fatimacambronero at gmail.com
<mailto:fatimacambronero at gmail.com> ]
Posted on: by saturday, March 22, 2014 8:54 pm
To: Alberto Soto
CC: Dr. Alejandro Pisanty Baruch; LACRALO Espaol
Subject: Re: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN
Seeks Public Comment on 2013 RAA Data Retention Data Elements Specification
and Legitimate Purposes for Collection and Retention
Alejandro, Alberto,
I share the view of that we are facing an interesting topic
deberamos to analyze and speak out from our region.
The da Monday 24 at 15 pm. Local Singapore estprevista a Table
Round about Directory Services Registration: present and future. If
While this issue is not specifically on the agenda estincluido of the meeting is
closely related perhaps a topic that appears in the discussions.
It will be good to participate in this Roundtable to hear and discuss the
comments you may have about it. I understand that the hours of
our countries is in a strip a little complicated. I'll be
attending this meeting. If there sb who want to comment or view
to get, I offer to transmit.
This is the link to the agenda of the Roundtable:
https://community.icann.org/display/atlarge/At-Large+Roundtable+on+Registrat
< https://community.icann.org/display/atlarge/At-Large+Roundtable+on+Registra
tion + Directory + Services% 3A + Now + and + the + Future + - +2014.03.24 + - + Singapore>
ion + Directory + Services% 3A + Now + and + the + Future + - +2014.03.24 + - + Singapore
That link to the Adobe Connect: https://icann.adobeconnect.com/sin49-vip/
(This is the same for all meetings of At-Large of the week).
Best Regards,
Fatima Cambronero
3/21/2014 23:40 GMT-03: 00 Alberto Soto <asoto at ibero-americano.org
<mailto:asoto at ibero-americano.org>
<mailto:asoto at ibero-americano.org <mailto:asoto at ibero-americano.org> >>:
I think the interest should be sufficient. It is just one of the topics
make the existence of end-user oriented entities Internet
ie U.S..
Surely there are different laws for each country, at least in
some substantial tems. Although there are countries that do not have an legislation.
There are 30 days for comments, there is little time for the importance of the subject.
Suggest that very quickly the respective ALS each country of our
Regin, read the history of this item, then inform the
legislacin force in their respective country, with reviews.Also I suggest
that for this first phase, the closing date is the Friday Prximo
28/03/2014.
Also suggest that those who are participating in Singapore, are exempt from
participate, have very important things to do for us.
Best Regards
Alberto Soto
----- Original Message -----
From: lac-discuss-es-bounces at atlarge-lists.icann.org
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org>
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org> >
[Mailto: lac-discuss-es-bounces at atlarge-lists.icann.org
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org>
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org> >] On behalf of Dr.
Alejandro Pisanty Baruch
Posted on: Friday, March 21, 2014 11:25 pm
To: lac-discuss-es at atlarge-lists.icann.org
<mailto:lac-discuss-es at atlarge-lists.icann.org>
<mailto:lac-discuss-es at atlarge-lists.icann.org
<mailto:lac-discuss-es at atlarge-lists.icann.org> >
Subject: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN Seeks
Public Comment on Data Retention RAA 2013 Specification and Data Elements
Legitimate Purposes for Collection and Retention
Colleagues,
called Annex may have significant legal implications in our
region. Let us summon experts in protection of personal data and other
issues related to data retention (Computational forensics, law
telecommunications, Civil Marco in the case of Brazil) to
form a opininslida, if there is enough interest.
Alejandro Pisanty
---------------------------
Dr. Alejandro Pisanty
UNAM Faculty of Chemistry
3000 University Avenue, 04510 Mexico DF Mexico
+52-1-5541444475 <tel:%2B52-1-5541444475> FROM ABROAD
+525541444475 <tel:%2B525541444475> SMS +525541444475 FROM MEXICO
<tel:%2B525541444475>
Blog: http://pisanty.blogspot.com
LinkedIn: http://www.linkedin.com/in/pisanty
Join the LinkedIn group UNAM,
http://www.linkedin.com/e/gis/22285/4A106C0C8614
Twitter: http://twitter.com/apisanty
---- >> Join ISOC Mexico, http://www.isoc.org
. . . . . . . . . . . . . . . .
________________________________________
From: alac-announce-bounces at atlarge-lists.icann.org
<mailto:alac-announce-bounces at atlarge-lists.icann.org>
<mailto:alac-announce-bounces at atlarge-lists.icann.org
<mailto:alac-announce-bounces at atlarge-lists.icann.org> >
[Alac-announce-bounces at atlarge-lists.icann.org
<mailto:alac-announce-bounces at atlarge-lists.icann.org>
<mailto:alac-announce-bounces at atlarge-lists.icann.org
<mailto:alac-announce-bounces at atlarge-lists.icann.org> >] On behalf of
ICANN
At-Large
Staff [staff at atlarge.icann.org <mailto:staff at atlarge.icann.org>
<mailto:staff at atlarge.icann.org <mailto:staff at atlarge.icann.org> >] Sent
on: Friday, March 21, 2014
20:00
To: ALAC-Announce at atlarge-lists.icann.org
<mailto:ALAC-Announce at atlarge-lists.icann.org>
<mailto:ALAC-Announce at atlarge-lists.icann.org
<mailto:ALAC-Announce at atlarge-lists.icann.org> >
Subject: [ALAC-Announce] ICANN News Alert - ICANN Seeks Public Comment on
RAA 2013 Specification Data Retention Data Elements and Legitimate Purposes
for Collection and Retention
[Http://www.icann.org/images/gradlogo_bow.jpg] <http://www.icann.org/>
News Alert
http://www.icann.org/en/news/announcements/announcement-3-21mar14-en.htm
________________________________
ICANN Seeks Public Comment on 2013 RAA Data Retention Data Specification
Elements and Legitimate Purposes for Collection and Retention
21 March 2014
ICANN has-been in discussions with a number of Registrars Regarding data
retention requests waiver ("Waiver Requests") submitted under the 2013
Registrar Accreditation Agreement (the "2013 RAA").Some Registrars are
seeking an exemption from Un certain collection and / or retention requirements
under the Data Retention Specification (the "Specification") of the 2013
RAA. Section 2 of the Data Retention Specification sets forth requirements
Regarding the written materials to register must submit in support of its
good faith determination That the collection and / or retention of any data
element specified in the Specification Violates applicable law, and Provides
That Following notice to ICANN of the Waiver Request, ICANN and the
Register applicable Shall discuss the matter in good faith in an effort to
reach a mutually acceptable resolution of the matter. An update on the 2013
RAA data retention and the waiver process can be found here:
http://blog.icann.org/2014/02/update-on-2013-raa-and-data-retention-waiver-p
<http://blog.icann.org/2014/02/update-on-2013-raa-and-data-retention-waiver-
<http://blog.icann.org/2014/02/update-on-2013-raa-and-data-retention-waiver-
process />
process />
rocess /
ICANN staff Understands That data Should be Treated in Accordance with
applicable data protection laws, que Generally permit gathering and
personnel retention of data for legitimate purpose (s). ICANN Also Understands
That the law may vary from country to country as to (i) what is Considered to
legitimate purpose, (ii) Whether the personnel data is adequate, relevant and
not excessive in relation to the legitimate purpose for Which They are
collected and (iii) how long for Un Certain data elements May be Retained. In
other words, what is Considered a legitimate purpose for collection of
Un certain data in one country May not be Considered a legitimate purpose in
another country.
During ICANN's discussions in an effort to reach a mutually acceptable
resolution of the matter, some have Requested That ICANN Registrars (a)
AMclarify and better define Un certain data elements in the Data Described
Retention Specification Maintain That the Registrars are not Clearly
defined; and (b) describes Potentially legitimate ministering purposes for collection and
retention of each data element That would help Provide guidance for
Both Whether Registrars Such elements as to Lawfully May be collected, and,
if so, for how long Such elements Lawfully Might be Retained.
In response to requests from some These Registrars, ICANN is posting for
seeking public comment a document to what is meant by AMclarify Un certain data
elements Described in the Specification and Describing Data Retention
Potentially legitimate ministering purposes for collection and retention of Those data
elements. That document can be found
here <http://www.icann.org/en/resources/registrars/raa/draft-data-retention-s
<http://www.icann.org/en/resources/registrars/raa/draft-data-retention-spec-
<http://www.icann.org/en/resources/registrars/raa/draft-data-retention-spec-
elements-21mar14-en.pdf>
elements-21mar14-en.pdf>
Breast-elements-21mar14-en.pdf> [PDF, 116 KB]. The document will be posted for
a period of thirty (30) days to seek feedback and input from the community
on (i) Whether the data elements are Appropriately described, (ii) Whether
ministering purposes cited for the collection and retention are Appropriate and
legitimate, and (iii) Whether there are other legitimate Potentially
ministering purposes for collection and retention of data Such elements. After the
thirty (30) day period has expired Following this posting, ICANN will
Consider all feedback and input received in Connection with Ongoing ICANNs
discussions to reach a mutually acceptable resolution of Waiver Requests. In
the interim, ICANN will continue its Ongoing discussions to reach a mutually
acceptable resolution of Waiver Requests with Single Registrars With the
additional goal of Granting Waiver Requests as and when to Appropriate.
A public comment period will REMAIN open until 11:59 p.m. PDT / California, 21
April 2014. Public comments will be available for consideration by ICANN
ICANN staff and the Board.
* Comments can be posted to:
comments-retention-21mar14 at icann.org
<mailto:comments-retention-21mar14 at icann.org>
<mailto:comments-retention-21mar14 at icann.org
<mailto:comments-retention-21mar14 at icann.org> >
<mailto:comments-retention-21mar14 at icann
<mailto:comments-retention-21mar14 at icann>
<mailto:comments-retention-21mar14 at icann
<mailto:comments-retention-21mar14 at icann> >
. Org>
* Comments can be viewed at:
http://forum.icann.org/lists/comments-retention-21mar14/
_______________________________________________
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