[WHOIS-WG] [Registrants-rights] OPEN PUBLIC COMMENT: Proposed 2013 RAA Posted for Comment

[Holly Raiche]

First- a big thank you to Carlton

What he has shown is that the RRR group ranges across some very important and complex issues.  Whois is the most immediate, with its own set of issues, including most recently implications of the changes to the RAA on what is Whois data. And there are important pieces of the RRR developing - the survey we are commenting on, the RAA negotiations, the progress (or lack thereof) on necessary changes/ explanations for the requirements in Clause 3.7.8.  And complaint statistics are another really important piece of this issue. Perhaps the best way forward is to assign particular issues to individuals, and then bring it all together at Beijing.

More below

On 14/03/2013, at 6:45 AM, Carlton Samuels wrote:

> Dear Silvia:
> Holly is lead on the RAA itself via Chairing the Registrants Rights WG.  Her advice is key to moving forward.  I am keen to hear views on the elements in Clause 6.3 - Board-initiated action to amend RAA and Clause 1.23 which provides more leeway for initiating changes to RAA, including contemplating sanctions
I haven't had time to read this thoroughly, but this is potentially a very important new Compliance tool
> . 
> 
> In any event, the adoption of a WHOIS Accuracy Program Specification [Section 1.25]
This is also a very important issue.  It is now not clear what is means by steps that are reasonable for accuracy (Cl 3.7.8)  This will shed some light - and add to the enforceability of the clause
> , public WHOIS Access Requirements in thin vis-a-vis thick registries [Section 3.3.1]
ALAC has argued for Thick Whois across the board.  The warning shot here was Verisign not agreeing to the audit in relation to .net - a thin registry
> , Privacy and Proxy Accreditation Program and their requirements [Section 3.14.2]
If WEIRDS isn't on deck soon, then this becomes even more important
> + RDDS Specification [Section 3.2.1.2 et. al.]  in RAA 2013 requires some examination and possible feedback
Carlton - we need your expertise here
> .  We might also wish to explore how the WHOIS Accuracy Program Specs may influence interpretation of Clause 3.7.8
They absolutely will.  So we need to be part of this discussion


> .
> 
> In preparation, might I ask if staff could request compilation and return of the total number of complaints to Compliance by year and percentage of those that are about inaccurate WHOIS over say, the last 8 years?
Yes please - thank you Carlton for asking
> 
> And could staff also request data on the number of enforcement actions per annum and the percentage of those derived from inaccurate WHOIS?
Yes please - again
> 
> Kind regards,
> -Carlton  
> 
> ==============================
> Carlton A Samuels
> Mobile: 876-818-1799
> Strategy, Planning, Governance, Assessment & Turnaround
> =============================
> 
> 
> On Tue, Mar 12, 2013 at 7:20 PM, ICANN At-Large Staff <staff at atlarge.icann.org> wrote:
> Dear All,
> 
> Please note that a Public Comment on the Proposed 2013 RAA Posted for Comment<https://community.icann.org/x/xZRwAg> is now open.
> 
> Can you please confirm if a Statement on it is necessary? If so, can you please let Staff know who will be drafting it?
> 
> This Public Comment closes 28-Mar-2013 23:59 UTC.
> 
> Regards,
> 
> Heidi Ullrich, Silvia Vivanco, Matt Ashtiani, Gisella Gruber, Nathalie Peregrine and Julia Charvolen
> ICANN Policy Staff in support of ALAC
> E-mail: staff at atlarge.icann.org<mailto:staff at atlarge.icann.org>
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> WG Wiki: https://community.icann.org/x/vo4i
> 

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