[gnso-dow123] Draft minutes WHOIS combined task force call 14 June 2005
[To: gnso-dow123[at]gnso.icann.org] Dear Task Force members Attached please find the draft minutes which include Maria Farrell's summary of the Whois task force call held on 14 June 2005. Please let me know what changes you would like to see. Thank you. Kind regards, Glen -- Glen de Saint Géry GNSO Secretariat - ICANN gnso.secretariat[at]gnso.icann.org http://gnso.icann.org <!--#set var="bartitle" value="WHOIS Task Forces 1 2 3 teleconference
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<h4 align="center"> </h4>
<h4 align="center"><font face="Arial, Helvetica, sans-serif"><b>WHOIS Task
Forces
1 2 3<br>
<br>
14 June 2005 - Minutes</b></font></h4>
<p><font face="Arial, Helvetica, sans-serif"><b>ATTENDEES:<br>
GNSO Constituency representatives:<br>
</b> Jordyn Buchanan - Chair<br>
gTLD Registries constituency - Ken Stubbs<br>
gTLD Registries constituency - David Maher <br>
Registrars constituency - Tim Ruiz (alternate)<br>
Registrars constituency - Ross Rader <br>
Non Commercial Users Constituency - Milton Mueller<br>
Non Commercial Users Constituency - Kathy Kleiman<br>
Commercial and Business Users Constituency - David Fares<br>
Intellectual Property Interests
Constituency - Steve Metalitz<br>
Intellectual Property Interests Constituency - Niklas Lagergren <br>
Internet Service and Connectivity Providers constituency - Maggie Mansourkia
<br>
Internet Service and Connectivity Providers constituency - Greg Ruth <br>
<br>
<strong>Liaisons</strong><br>
At-Large Advisory Committee (ALAC) liaisons - Wendy Seltzer</font> <font
face="Arial, Helvetica, sans-serif"> - absent <br>
GAC Liaison - Suzanne Sene <br>
<br>
<b>ICANN Staff</b>: <br>
Maria Farrell Farrell - ICANN GNSO Policy Officer<br>
<b>GNSO Secretariat </b>- Glen
de Saint Géry <br>
<br>
<b>Absent:</b><br>
Registrars constituency - Paul Stahura <br>
Registrars constituency - Tom Keller - apologies <br>
Commercial and Business Users constituency - Marilyn Cade - apologies <br>
Non Commercial Users Constituency
- Marc Schneiders<br>
Non Commercial Users Constituency - Frannie Wellings <br>
Commercial and Business Users Constituency - Sarah Deutsch - apologies<br>
Internet Service and Connectivity Providers constituency - Tony Harris -
apologies <br>
<br>
</font> <font face="Arial, Helvetica, sans-serif"><strong>MP3 Recording<br>
Summary
<br>
</strong><br>
<strong>Agenda
</strong></font></p>
<font face="Arial, Helvetica, sans-serif"><a
href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";>1. Policy and
Advice Recommendation 2 </a><br>
2 Purpose of Whois – questions for public forum in Luxembourg<br>
<a href="http://forum.icann.org/lists/gnso-dow123/msg00375.html";>Initial list
of questions regarding purpose<br>
<br>
</a><a
href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";><strong>Policy
and Advice Recommendation 2 </strong></a></font>
<p><font face="Arial, Helvetica, sans-serif"><strong>Steve Metalitz
</strong>reported that he had worked with Kathy Kleiman to divide the
recommendation into a policy recommendation and advice on the procedure that
the ICANN staff could use in implementation Most of the <a
href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";>present
document</a> was drawn from earlier versions.<br>
The goals listed for the procedure include: </font></p>
<p><font face="Arial, Helvetica, sans-serif">a. Ensuring that ICANN staff is
informed of a conflict at the earliest appropriate juncture;</font></p>
<p><font face="Arial, Helvetica, sans-serif">b. Resolving the conflict, if
possible, in a manner conducive to stability and uniformity of the Whois
system;<br>
this is the level playing field</font></p>
<p><font face="Arial, Helvetica, sans-serif">c. Providing a mechanism for the
recognition, in appropriate circumstances where the conflict cannot be
otherwise resolved, of an exception to contractual obligations with regard to
collection, display and distribution of personally identifiable data via Whois;
and </font></p>
<p><font face="Arial, Helvetica, sans-serif">d. Preserving sufficient
flexibility for ICANN staff to respond to particular factual situations as they
arise.<br>
(c and d grew out of a discussion with the staff, letting staff respond to
situations as they arose.)
</font></p>
<p><font face="Arial, Helvetica, sans-serif"> Part two is identical to what it
was before.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Kathy Kleiman</strong>
commented that the text of the procedure still contained the <a
href="http://forum.icann.org/lists/gnso-dow123/msg00223.html";>previous edits,
e.g. from Tom Keller </a>which could be discussed by the task force. The four
high level goals would be part of the consensus policy.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Ross Rader </strong>asked
for an explanation on the notion of the "level playing field".<br>
<strong>Steve Metalitz </strong>explained that it came from postings to
the combined task force list and Jordyn Buchanan added that it reflected the
registrars' concern that the procedure had the potential to create competitive
imbalances.<br>
<strong>Kathy Kleiman</strong> added that it also concerned stability and
uniformity and captured language about the level playing field that Task Force
2 had been discussing. </font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Ross Rader</strong>
commented that the term " whois system " should be broadened for the
staff to apply the guidelines in a broader context and he suggested further
consultation with his constituency.<br>
Constituency statements usually took 2 to 4 weeks to develop.
<br>
<br>
<strong>Jordyn Buchanan </strong>suggested working Ross Rader's concern on
the mailing list and then making a call for constituency statements on the
policy recommendation and the advice on the procedure at the same time.<br>
<br>
<br>
Where does this fit in with the<a
href="http://www.icann.org/general/archive-bylaws/bylaws-08apr05.htm#AnnexA";>
policy development process (PDP) in the ICANN Bylaws</a>?<br>
The PDP requires constituency statements: <br>
<B><a
href="http://www.icann.org/general/archive-bylaws/bylaws-08apr05.htm#AnnexA";>6.
Public Notification of Initiation of the PDP<br>
</a></B></font><font face="Arial, Helvetica, sans-serif">After initiation of
the PDP, ICANN shall post a notification of such action to the Website. A
public comment period shall be commenced for the issue for a period of twenty
(20) calendar days after initiation of the PDP. The Staff Manager, or some
other designated representative of ICANN shall review the public comments and
incorporate them into a report (the "Public Comment Report") to be included in
either the Preliminary Task Force Report or the Initial Report, as
applicable.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><a
href="http://www.gnso.icann.org/mailing-lists/archives/dow1tf/docXYvP0cQIIC.doc";>Task
Force 1</a>, <a
href="http://gnso.icann.org/mailing-lists/archives/tf2-survey/";>Task Force 2
</a>and <a
href="http://www.gnso.icann.org/issues/whois-privacy/Whois-tf3-preliminary.html";>Task
Force 3</a> constituency statements were not germane to the specific policy
<a href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";>recommendation
2</a>.</font> <br>
<font face="Arial, Helvetica, sans-serif">In November 2004 the <a
href="http://www.gnso.icann.org/issues/whois-privacy/whois-tf-conflict-30nov04.pdf";>recommendation
2</a> was <a
href="http://www.gnso.icann.org/mailing-lists/archives/dow1-2tf/msg00183.html";>responded
to by Paul Verhoef</a>. ICANN General Counsel and senior staff discussed the
recommendation with the combined Whois task force on <a
href="http://forum.icann.org/lists/gnso-dow123/msg00094.html";>March 15,
2005</a> . There has been no public comment period.<br>
Thus, step 6 in the PDP process is being revisited which will enable the GNSO
policy officer to incorporate the constituency statements and provide a
preliminary report that will be posted for public comment. <br>
<br>
<strong>Jordyn Buchanan proposed the following timelines:</strong><br>
-
allowing one week for additional edits from the task force on <a
href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";>recommendation 2,
policy and procedure</a> before constituency comments were requested <br>
- <strong>Tuesday 21 JUNE 2005</strong> - aim to distribute the
recommendation to constituencies for formal comment. <br>
- <strong>Thursday 21 JULY
2005</strong> - Deadline for constituency responses.<br>
<strong>Next step:</strong><br>
<strong>Maria Farrell</strong> will draft a preliminary report and it will be
determined whether or not any changes to the recommendations are appropriate in
light of the constituency statements.<br>
<br>
<strong>Tuesday 2 AUGUST 2005 </strong>- Target date for task force to vote
on recommendations
in the preliminary report, and to make it available for public comments.
<br>
<strong>Tuesday 23 AUGUST</strong> Public comment period ends. Consider
whether any modifications needed to be made to the recommendations in light of
the public comment. <br>
If not, a Final Report that incorporates the public comments would be
forwarded to the GNSO Council, probably at the end of August.<br>
<br>
<strong>Maria Farrell</strong> proposed sending the <a
href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";>recommendation 2
</a>to ICANN General and Deputy Counsel at the same time as it would be sent
for constituency statements. <br>
<br>
<strong><a
href="http://forum.icann.org/lists/gnso-dow123/msg00392.html";>Summary 1
Recommendation 2 on conflicts with national laws</a></strong></font></p>
<p><font face="Arial, Helvetica, sans-serif">Steve Metalitz and Kathy Kleiman
had circulated their revised draft to the mailing list several days previously.
As requested by the task force, they divided the document into a recommendation
and a procedure staff could use to implement it.</font></p>
<p><font face="Arial, Helvetica, sans-serif">The text of the procedure still
contains the edits suggested previously - e.g. by Tom Keller – and the
drafters have not amended these.<br>
<br>
The current version of the recommendation was sent by Kathy Kleiman to the list
on Monday, 13 June (subject line: Fwd: [gnso-dow123] Policy and Advice:
Recommendation 2)<br>
<br>
Decisions</font></p>
<p><font face="Arial, Helvetica, sans-serif">The task force has one week to
comment on and finalize it for circulation for constituency statements. <br>
As the previous public comments on the relevant task force were not germane
to this recommendation, we will solicit constituency statements pursuant to
section 7(d) of the PDP. <br>
Once we have received constituency statements, Maria Farrell will craft a
draft preliminary report and we will determine whether or not any changes to
the recommendations are appropriate in light of the constituency statements.
<br>
August 2 is the target date to vote on the recommendations in the preliminary
report, and to make it available for public comments. At that point, a public
comment period begins which should run through about August 23. <br>
The task force then would consider whether any modifications need to be made to
the recommendations in light of the public comment. If no modifications are
needed,a Final Report that incorporates the public comments would be forwarded
to the GNSO Council, probably at the end of August 2005.<br>
<br>
Actions</font></p>
<p><font face="Arial, Helvetica, sans-serif">Jordyn will send a <a
href="http://forum.icann.org/lists/gnso-dow123/msg00383.html";>note to the task
force outlining the steps to be taken</a>. (This was done immediately after the
task force call on 14 June, 2005). <br>
Maria to assist Jordyn in determining if no round of constituency comments
more germane to this recommendation has already been conducted. <br>
Initial suggestions will be submitted no later than June 16, and further
edits may take place over the following few days. <br>
On Tuesday 21 June the recommendation will be distributed to constituencies
for formal comments. Deadline for responses will be July 21. <br>
Ross Rader to submit his comments on the use of the term ‘the whois
system’. <br>
</font><font face="Arial, Helvetica, sans-serif"><br>
<strong>2. Purpose of Whois – questions for public forum in Luxembourg<br>
<a href="http://forum.icann.org/lists/gnso-dow123/msg00375.html";>Initial list
of questions regarding purpose<br>
</a></strong><a
href="http://forum.icann.org/lists/gnso-dow123/msg00375.html";><strong><br>
</strong></a></font><strong><font face="Arial, Helvetica, sans-serif">Jordyn
Buchanan</font></strong><font face="Arial, Helvetica, sans-serif"> referred to
his <a
href="http://forum.icann.org/lists/gnso-dow123/msg00375.htmlhttp://forum.icann.org/lists/gnso-dow123/msg00375.html";>posting
of 13 JUNE 2005</a> and possible questions to pose at the public forum in
Luxembourg on<a href="http://forum.icann.org/lists/gnso-dow123/msg00375.html";>
task 1 and 2 of the terms of reference</a><br>
Task
1, Define the purpose of the WHOIS service in the context of ICANN's mission
and
relevant core values<br>
Task
2 Define the purpose of the Registered Name Holder, technical, and
administrative
contacts, in the context of the purpose of WHOIS, and the purpose for which
the
data was collected.<br>
Two ways were proposed: <br>
-
gathering input on answering the questions or <br>
-
reviewing data items from the past. <br>
Past work includes:<br>
-
the original WHOIS task force co-chaired by Marilyn Cade and Tony Harris <a
href="http://www.dnso.org/dnso/notes/whoisTF/20020625.TFwhois-report.pdf";>Whois
task force report June 2002 </a>- <a
href="http://www.gnso.icann.org/issues/whois-privacy/Whois-tf2-preliminary.html";>WHOIS
</a><a
href="http://www.gnso.icann.org/issues/whois-privacy/Whois-tf2-preliminary.htmlhttp://www.gnso.icann.org/issues/whois-privacy/Whois-tf2-preliminary.html";>task
force 2</a> did a survey soliciting public comment on the uses of WHOIS <br>
- the <a
href="http://www.icann.org/gnso/transfers-tf/report-exhc-12feb03.htm";>Transfers
task force defined uses of WHOIS
</a><br>
- recently
Maria Farrell's work on the <a
href="http://forum.icann.org/lists/gnso-dow123/msg00384.html";>uses of WHOIS
data</a> <br>
<br>
The issues were broken into
three subsets, <br>
1.
the uses of the WHOIS, which may or may not be distinct from the purpose of
WHOIS. <br>
2.
work intended to define the purpose of whois<br>
3.
the ways various people make use of the various contacts.<br>
<br>
There seemed to be general agreement that sufficient data had been gathered
on the uses of WHOIS.<br>
To articulate or define the purpose of WHOIS was one of the tasks in the terms
of reference, and as Tim Ruiz and David Maher suggested it was a policy issue
which could be worked on in the task force.</font> </p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Kathy Kleiman
</strong>disagreed and believed that the purpose of WHOIS had not been
sufficiently examined because, firstly, it was set as a task in the terms of
reference and secondly it was a term of art in the European Union (EU)
Directive. The purpose should be seen in the terms of ICANN's mission, and in
relation to the EU Directive. "Purpose" was an important criteria and
a legal term, and not a collection of uses, thus the constituencies should be
consulted.<br>
<br>
<strong>Milton Mueller</strong> suggested asking what was the purpose of the
WHOIS system as it contributed to ICANN's mission. International laws affecting
privacy or WHOIS were constraints external to the WHOIS system and ICANN
itself that had to be respected but it would be useful, as an exercise, to
examine "given ICANN's mission and core values, what do we want the
purpose of WHOIS to be in ICANN's mission ?" A data protection law expert
could be invited to explain some of the interpretations of how purpose has been
used in the past as a factual matter when referring to terms such as databases
and data collection.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Ross Rader</strong>
believed that the task force should be directly engaged in the
question.,</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>David Fares</strong>
cautioned that two concepts were being blurred:<br>
at the
international level, purpose specification on privacy was related to data
collection. <br>
the issue regarding use of that data. <br>
What the task force was concerned about was the purpose of WHOIS which should
be kept separate.</font></p>
<p><strong><font face="Arial, Helvetica, sans-serif">Kathy
Kleiman</font></strong><font face="Arial, Helvetica, sans-serif"> supported by
<strong>Maggie Mansourkia </strong>suggested soliciting expert advice before
the constituencies were asked to respond and emphasised that the intention was
to ask an expert to define and frame what that question was and how the task
force answer would be interpreted. There were many groups that examined the
legal purpose of information collection and its use, however this was a foreign
concept under US law but not under European law.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Steve Metalitz</strong>
agreed that the constituencies should be asked to comment on <a
href="http://gnso.icann.org/policies/terms-of-reference.html";>task 1</a> but
had reserves about it being useful as a public forum topic on the purpose of
WHOIS at the Luxembourg meetings and believed the one area still to be explored
was law enforcement's uses of the WHOIS.</font> <font face="Arial, Helvetica,
sans-serif">He mentioned the <a
href="http://www.icann.org/presentations/mithal-whois-workshop-24jun03.pdf";>presentation
at the ICANN meetings in Montreal</a>, in June 2003 by Maneesha Mithal of the
Federal Trade commission<br>
<br>
</font><font face="Arial, Helvetica, sans-serif"><strong>Jordyn
Buchanan</strong> summarised:<br>
- request constituency positions on the purpose of WHOIS within the context
of ICANN's mission, <a
href="http://gnso.icann.org/policies/terms-of-reference.html";>task 1</a>. <br>
- whether to include this as a topic for the GNSO public forum in
Luxembourg<br>
- whether to seek expert input on the purposes </font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Ross Rader
</strong>expressed concern about the time that would be spent consulting the
constituencies thought that there should be a conversation between the task
force members about the issue and have them consult their constituencies and
broader consultation could be provided during the public comment period<br>
<br>
</font><font face="Arial, Helvetica, sans-serif"><strong>Jordyn
Buchanan</strong> summarised the proposal generally agreed upon:<br>
- Requesting constituency statements on <a
href="http://gnso.icann.org/policies/terms-of-reference.html";>task one, the
purpose of WHOIS in the context of ICANN's mission<br>
</a>Time frame 21 July 2005 <br>
- In parallel, examine what should be done on the definition of
"purpose", data collection by Maria Farrell on the definition of
purpose in EU law and other jurisdictions
and if appropriate have outside advisors provide information. However this
discussion should be deferred. </font> </p>
<p><font face="Arial, Helvetica, sans-serif"><a
href="http://gnso.icann.org/policies/terms-of-reference.html";>Task 2 Define the
purpose of the
Registered Name Holder, technical, and administrative contacts, in the context
of the purpose of WHOIS, and the purpose for which the data was collected.
</a>– ok, let’s move on to our Jordyn Buchanan proposed <br>
-
calling for constituency statements due at the same time as those for task 1<br>
- referring to the definition of the contacts provided by the<a
href="http://www.icann.org/gnso/transfers-tf/report-exhc-12feb03.htm";> Transfer
policy report,</a> surveying the constituencies as to how members populate that
data to ascertain the current usage independently of the definitions. For
example what types of people are put in the technical contact role, are the
registrant and administrative role the same? </font> </p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Steve Metalitz</strong>
suggested broadening the enquiry to include registrants, Registries and
Registrars. Particularly the registrars to find out whether they provide
guidance to the registrants about who to fill in for the various
contacts.</font></p>
<p><strong><font face="Arial, Helvetica, sans-serif">Ross
Rader</font></strong><font face="Arial, Helvetica, sans-serif">, providing some
historical information, commented that the definition from the <a
href="http://www.icann.org/gnso/transfers-tf/report-exhc-12feb03.htm";>Transfers
task force </a>came from multiple definitions from the community and not from
the original work of the task force.<br>
He suggested presenting the definition as described in the <a
href="http://www.icann.org/gnso/transfers-tf/report-exhc-12feb03.htm";>Transfer
Policy Report</a> and asking the Registrar constituency what they were doing,
and Jordyn Buchanan suggested asking whether there was a default response that
went into the fields.<br>
<br>
<strong>David Farres </strong>reminded Jordyn Buchanan of<strong> Marilyn
Cade's</strong> questions as she was not able to be on the call and it was
agreed that they had been answered during the discussions.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>Jordyn Buchanan</strong>
summarised:<br>
</font><font face="Arial, Helvetica, sans-serif">- call for constituency
statements on<a href="http://gnso.icann.org/policies/terms-of-reference.html";>
task 1 and Task 2 of the terms of reference</a><br>
- supplemental question to users on how they populate <a
href="http://www.icann.org/gnso/transfers-tf/report-exhc-12feb03.htm";>contacts</a>
and to registrars on how they instruct or guide registrants on the purpose or
use of the contacts. <br>
- deadline for response 21st July 2005<br>
- defer call on 21 June to 28 June 2005<br>
- discuss on the list<br>
(i)<a href="http://forum.icann.org/lists/gnso-dow123/msg00376.html";> National
law recommendation 2</a> for constituency statements<br>
(ii)
how to move ahead with the meaning of the purpose for WHOIS .</font> <br>
<br>
<font face="Arial, Helvetica, sans-serif"><strong><a
href="http://forum.icann.org/lists/gnso-dow123/msg00392.html";>Summary - Purpose
of Whois – questions for public forum in
Luxembourg</a></strong></font></p>
<p><font face="Arial, Helvetica, sans-serif">The task force discussed the
questions to be put to the public during the GNSO public forum in Luxembourg on
the purpose of whois and the ways people use the various contact types.
</font></p>
<p> </p>
<p><font face="Arial, Helvetica, sans-serif">The task force also discussed
possible information gathering on the purpose of whois, particularly regarding
the meaning of purpose in the data protection context. </font></p>
<p> </p>
<p><font face="Arial, Helvetica, sans-serif">The task force also discussed the
purpose of the different contacts within the whois system. (e.g. administrative
contact, technical contact, etc.)</font></p>
<p><font face="Arial, Helvetica, sans-serif">Decisions</font></p>
<p><font face="Arial, Helvetica, sans-serif">Task force representatives will go
back to their constituencies for constituency statements on the purpose of
whois “in the context of ICANN's mission and relevant core values,
international and national laws protecting privacy of natural persons,
international and national laws<br>
that relate specifically to the WHOIS service, and the changing nature of
Registered Name Holders.” (terms of reference text) <br>
Task force will discuss on the list the definition of purpose and having
Maria and/or others gather information on this topic, as well as having an
outside expert address the meaning of purpose in data protection. <br>
<br>
</font><font face="Arial, Helvetica, sans-serif">Actions</font></p>
<p><font face="Arial, Helvetica, sans-serif">· Task force
representatives to produce constituency statements on the purpose of whois
“in the context of ICANN's mission and relevant core values,
international and national laws protecting privacy of natural persons,
international and national laws that relate specifically to the WHOIS service,
and the changing nature of Registered Name Holders” by Tuesday, 21 July
2005.</font></p>
<p> </p>
<p><font face="Arial, Helvetica, sans-serif">· Task force
representatives will also ask their constituencies (registrants) how they
populate the contact fields. This will be a supplemental question to the
question on the purpose of whois. </font></p>
<p> </p>
<p><font face="Arial, Helvetica, sans-serif">· Registrar representatives
are to request that constituency members provide information on what
instruction and guidance they provide to registrants about the correct data to
provide for each contact type, and to indicate whether there is default data
populated into each contact type. This will be a supplemental question to the
question on the purpose of whois. </font></p>
<p> <br>
<font face="Arial, Helvetica, sans-serif"><strong><a
href="http://forum.icann.org/lists/gnso-dow123/msg00392.html%20";>3 Next task
force call:</a></strong><br>
Task Force members have asked for the number of calls to be reduced and for
work to proceed on the mailing list as much as possible. </font></p>
<p><font face="Arial, Helvetica, sans-serif">The next conference call of this
task force will be held on June 28th, 2005. <br>
</font>
</p>
<p><font face="Arial, Helvetica, sans-serif">See <strong>Jordyn
Buchanan</strong> - <a
href="http://forum.icann.org/lists/gnso-dow123/msg00383.html";>Follow up items
from the call</a><br>
<br>
</font><font face="Arial, Helvetica, sans-serif"><strong>Jordyn Buchanan
</strong>thanked all the task force members for participating.</font></p>
<p><font face="Arial, Helvetica, sans-serif"><strong>The WHOIS task force call
ended at 17:35 CET </strong></font></p>
<p> <font face="Arial, Helvetica, sans-serif"><br>
</font></p>
<p><font face="Arial, Helvetica, sans-serif">-</font></p>
<p> </p>
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