Privacy matters

[Collin Grady <collin@xxxxxxxxxxxxxxx>]

Your proposed rules will be abused by those seeking to quash free speech
they don't agree with. It is far too open to abuse.

Why does an IP owner need direct contact info for the domain holder, when
they can simply pursue that through the existing legal system?

Why does a Law Enforcement Agency need a special provision when they could
get a standard warrant?

> What, if any, are the baseline minimum standardized reveal processes that
should be adopted by ICANN-accredited privacy/proxy service providers?

A warrant or subpoena should be required, at a minimum. In the case of a
subpoena, the user whose data is being sought should have a chance to file
a response.

> Should ICANN-accredited privacy/proxy service providers be required to
reveal customer identities for the specific purpose of ensuring timely
service of cease and desist letters?

No. One could simply require that they forward email on to a valid address.

> What safeguards must be put in place to ensure adequate protections for
privacy and freedom of expression?

Not doing any of this. Allowing a method outside of the legal system is
just asking for abuse.

> What circumstances, if any, would warrant access to registrant data by
law enforcement agencies?

A warrant, obviously. If an agency has a valid purpose, they can get a
warrant to request that information.

> What safeguards or remedies should be available in cases where
publication is found to have been unwarranted?

If you go through with this anyway, large monetary damages to both the
provider and the person requesting the information without good cause.

-- 
Collin Grady