RE: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG Proposal

["Gomes, Chuck" <cgomes@xxxxxxxxxxxx>]

Greg,

Does that mean you are volunteering to be a part of a small group to refine the 
wording?  :) 

Chuck

> -----Original Message-----
> From: Shatan, Gregory S. [mailto:GShatan@xxxxxxxxxxxxx]
> Sent: Tuesday, November 13, 2012 2:41 PM
> To: 'pdiaz@xxxxxxx'; Gomes, Chuck; 'gnso-igo-ingo@xxxxxxxxx'
> Cc: Maher, David; 'jbikoff@xxxxxxxxx'; 'dheasley@xxxxxxxxx';
> 'kmalancharuvil@xxxxxxxxx'
> Subject: Re: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> I'm all in favor of soliciting the GCO's imput.  I just want to make
> sure that the request is properly framed so that the advice is as
> helpful to our work as possible.
> --------------------------
> Sent from my BlackBerry Wireless Device
> 
> 
> ----- Original Message -----
> From: Paul Diaz [mailto:pdiaz@xxxxxxx]
> Sent: Tuesday, November 13, 2012 01:01 PM
> To: Chuck Gomes <cgomes@xxxxxxxxxxxx>; gnso-igo-ingo@xxxxxxxxx <gnso-
> igo-ingo@xxxxxxxxx>
> Cc: David W. Maher <dmaher@xxxxxxx>; Shatan, Gregory S.; Jim Bikoff
> <jbikoff@xxxxxxxxx>; David Heasley <dheasley@xxxxxxxxx>; Kiran
> Malancharuvil <kmalancharuvil@xxxxxxxxx>
> Subject: Re: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> +1
> 
> This debate is getting pretty arcane for ICANN policy work.  The WG
> would be well-served by the input of ICANN's General Counsel early in
> the policy development process for the reasons Chuck sets out below.
> 
> Best, P
> 
> PAUL DIAZ
> Director of Policy
> .ORG, The Public Interest Registry
> Main: +1 703 889-5778  | Direct: +1 703 889-5756  | Mobile: +1 703 973-
> 1667 | Skype: pdiazaim | Fax: +1 703 889-5779 |
> 
> Find us on Facebook<http://www.facebook.com/pir.org>  |  .ORG
> Blog<http://blog.pir.org/> | Flickr<http://flickr.com/orgbuzz> |
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> 
> On Nov 13, 2012, at 11:16 AM, Gomes, Chuck wrote:
> 
> 
> It seems to me that the WG clearly needs direction from the GCO
> regarding the applicability of international statutes and national laws
> regarding domain registrations involving the organizations under the
> purview of our charter.  Not only will that direction guide our work
> but it also will help the GNSO deal with the GAC's question as to why a
> PDP is needed; the GAC appears to believe that the law is clear so a
> PDP isn't even needed.  There is no doubt in my mind that there are
> international statutes and national laws that deal with this subject
> but I am not at all clear regarding how the actually apply to
> registration of domain names nor am I qualified to make that judgment.
> 
> Our challenge then is to word the request in a way that maximizes our
> chances of getting a helpful response from the GCO.  Would it be
> helpful to form a small subgroup of qualified volunteers to refine the
> wording of the request?  If so, I would recommend that Greg and David
> be the first volunteers.
> 
> Chuck
> 
> -----Original Message-----
> From: David W. Maher [mailto:dmaher@xxxxxxx]
> Sent: Tuesday, November 13, 2012 10:54 AM
> To: Shatan, Gregory S.; Gomes, Chuck; Jim Bikoff; gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>
> Cc: David Heasley; Kiran Malancharuvil
> Subject: Re: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> Please see further comments
> David W. Maher
> Senior Vice President - Law & Policy
> Public Interest Registry
> 312 375 4849
> 
> From: "Shatan, Gregory S."
> <GShatan@xxxxxxxxxxxxx<mailto:GShatan@xxxxxxxxxxxxx><mailto:GShatan@Ree
> dSmith.com>>
> Date: Tue, 13 Nov 2012 02:55:32 -0500
> To: David Maher
> <dmaher@xxxxxxx<mailto:dmaher@xxxxxxx><mailto:dmaher@xxxxxxx>>, CHUCK
> GOMES
> <cgomes@xxxxxxxxxxxx<mailto:cgomes@xxxxxxxxxxxx><mailto:cgomes@verisign
> .com>>, Jim Bikoff
> <jbikoff@xxxxxxxxx<mailto:jbikoff@xxxxxxxxx><mailto:jbikoff@xxxxxxxxx>>
> , "gnso-igo- ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx>" <gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx><mailto:gnso-igo-ingo@xxxxxxxxx>>
> Cc: David Heasley
> <dheasley@xxxxxxxxx<mailto:dheasley@xxxxxxxxx><mailto:dheasley@xxxxxxxx
> m>>,
> Kiran Malancharuvil
> <kmalancharuvil@xxxxxxxxx<mailto:kmalancharuvil@xxxxxxxxx><mailto:kmala
> ncharuvil@xxxxxxxxx>>
> Subject: RE: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> My responses are below.
> 
> -----Original Message-----
> From: David W. Maher [mailto:dmaher@xxxxxxx]
> Sent: Monday, November 12, 2012 11:11 PM
> To: Shatan, Gregory S.; CHUCK GOMES; Jim Bikoff; gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx><mailto:gnso-igo-ingo@xxxxxxxxx>
> Cc: David Heasley; Kiran Malancharuvil
> Subject: Re: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> Please see comments below:
> David W. Maher
> Senior Vice President - Law & Policy
> Public Interest Registry
> 312 375 4849
> 
> From: "Shatan, Gregory S."
> <GShatan@xxxxxxxxxxxxx<mailto:GShatan@xxxxxxxxxxxxx><mailto:GShatan@Ree
> dSmith.com<mailto:GShatan@Reed
> Smith.com<http://Smith.com><mailto:GShatan@xxxxxxxxxxxxx>>>
> Date: Mon, 12 Nov 2012 19:38:08 -0500
> To: CHUCK GOMES
> <cgomes@xxxxxxxxxxxx<mailto:cgomes@xxxxxxxxxxxx><mailto:cgomes@verisign
> .com<mailto:cgomes@verisign.
> com<mailto:cgomes@xxxxxxxxxxxx>>>, Jim Bikoff
> <jbikoff@xxxxxxxxx<mailto:jbikoff@xxxxxxxxx><mailto:jbikoff@xxxxxxxxx<m
> ailto:jbikoff@xxxxxxxxx<ma
> ilto:jbikoff@xxxxxxxxx>>>, "gnso-igo-ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>><mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>>>" <gnso-igo-
> ingo@xxxxxxxxx<mailto:gnso-igo-ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>>>>
> Cc: David Heasley
> <dheasley@xxxxxxxxx<mailto:dheasley@xxxxxxxxx><mailto:dheasley@xxxxxxxx
> m<mailto:dheasley@xxxxxxxxx
> <mailto:dheasley@xxxxxxxxx>>>, Kiran Malancharuvil
> <kmalancharuvil@xxxxxxxxx<mailto:kmalancharuvil@xxxxxxxxx><mailto:kmala
> ncharuvil@xxxxxxxxx<mailto:kmalan
> charuvil@xxxxxxxxx<mailto:charuvil@xxxxxxxxx><mailto:kmalancharuvil@sgb
> dc.com>>>
> Subject: RE: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> I think that, as drafted, this request is troublesome and ambiguous in
> several respects (with or without Jim Bikoff's additions).
> 
> First, the request only asks if ICANN is "aware" of any jurisdiction,
> etc.  Thus, it is phrased as a request based on ICANN's current
> knowledge, not a request for research or analysis, and would not result
> in any kind of "definitive" response.  Rather, it would result in an
> anecdotal response, which would essentially be worthless.
> DWM: The question leaves it up to the GC office to do research if they
> believe it necessary.
> GSS: I disagree.  The GCO  would need to freelance beyond the stated
> bounds of the question to do new research.  As I'm sure you are aware,
> when a contract asks a party to make a representation or state
> something as to "knowledge", that is only based on what they know
> (actual knowledge) and not what they should have known (constructive
> knowledge) or would find out if they did some research (due inquiry).
> I think "aware" here works like a "knowledge" limitation.  If we want
> the GC to tell us more than what they happen to know now, we need to
> specify that their "awareness" comes after due inquiry, or remove the
> reference to "awareness" altogether.
> DWM: This is not a contract negotiation. I would leave It up to the GC
> to decide what to do Second, it asks the GC's office to identify
> jurisdictions where applicable law "prohibits . the following actions
> by or under the authority of ICANN."  This is a very narrow phrasing of
> this question.  Given the slow pace at which statutes and especially
> treaties change, it is highly unlikely that laws in many (if any)
> jurisdictions specifically mention delegation of top level domains or
> domain names of IGO or INGOs, or mention ICANN.  In many if not most
> cases, we will be dealing with generally drafted laws of broad
> applicability dating from before the Internet era.  The question may be
> one of first impression - I am certainly not aware of any cases
> construing laws applicable to IGO/INGO names in the domain name
> context, much less the gTLD context, which is by definition an
> unanswered question.  So, while it is likely that there are few if any
> laws that specifically and explicitly prohibit these specific named
> activities by these specific named actors, that is not how the law
> works.  The question instead should be phrased to ask whether there are
> any applicable laws that could be interpreted to prohibit such actions.
> This would by definition require research, analysis and consideration
> of various interpretations of statutes and treaties relating to
> IGO/INGO names, without engaging in advocacy for one approach over
> another.
> DWM: I have no objection to use of the phrase "can be construed or
> interpreted to",  but I object to the other changes, and the deletion
> of "by or under the authority of ICANN". We, the WG, are trying to
> decide whether there are legal constraints that affect the policy
> questions that form the subject matter of this WG's charter. There
> could be years of research and analysis of statutes and treaties, but
> we need to start w/ the opinion of ICANN counsel on this specific
> question.
> GSS:   How can (a) or (b) happen, except under the authority of ICANN?
> The "by or under the authority of ICANN" language is either redundant
> or is creating an artificially high standard (that the law must mention
> ICANN by name).  Either way, it shouldn't be there.  There are
> certainly not years of research required to get an understanding of
> what is out there - maybe a solid week or two of fulltime research.  An
> "opinion" without research isn't going to be worth much, unless the GCO
> is already very well informed on international law relating to IGO/INGO
> names.
> DWM: The wording defines the question. This WG is trying to decide what
> is the scope and purpose of our work.
> Third, the question makes reference to the qualification that an
> international non-governmental organization must be "receiving
> protections under treaties and statutes under multiple jurisdictions"
> in order to be considered.  This "gating factor" has not been agreed on
> as a minimum qualification, and one of the things this WG should be
> doing  is deciding whether this is a valid and appropriate distinction.
> For instance, treaties may or may not require enabling legislation in
> order to be effective in a given jurisdiction; thus, the existence of
> the treaty itself could and should be sufficient to merit consideration
> with or without enabling legislation.  In other cases there could be
> applicable statutes in multiple jurisdictions but no treaty; this
> should not be a disqualification.  Put another way, the idea that there
> need to be "two levels of protection" in order to merit consideration
> for reservation is an assertion and not a given. (On a smaller point it
> is unclear whether the question intends to apply this test to IGOs as
> well; it seems to apply to INGOs only as drafted given the placement of
> the acronyms.)
> 
> DWM: The qualification re: INGOs comes from the wording of the Mission
> and Scope of the WG in the proposed charter that is now a motion before
> the GNSO Council.
> GSS:  Well, touché.  Now there doesn't need to be a basis in law or
> policy for this distinction, because it's "in the charter." Due to the
> press of other business I did not look at the proposed charter as
> closely as I should have, so I suppose it's my fault.  I have just come
> from the Berlin Wall site, and I am now deep in formerly Soviet-
> controlled Poland, so this seems apropos.  I have to say that, by
> adopting this artificial distinction, we have probably irreparably
> hobbled the work of this group.  At the very least, we have let process
> dictate outcome. Perhaps you would indulge and explain why this
> distinction makes sense, other than "it's in the proposed charter."
> DWM: The wording is also in the GNSO motion. It defines the scope of
> the PDP and the work of the WG.
> 
> Finally, this is really not comparable to asking ICANN for guidance on
> registry/registrar agreements.  These are contracts promulgated by
> ICANN and to which ICANN is a party.  ICANN counsel may be (indeed
> should be) competent to answer questions of contractual interpretation.
> Whether they are competent to opine on matters of international and
> transnational legal interpretation is an entirely different matter.
> 
> DWM: I believe ICANN counsel is competent to opine on the legal
> obligations that are the subject of the proposed question.
> GSS:  We shall see.  Regardless, they are not uniquely competent to do
> so, as they are in connection with ICANN documents.  So, whatever they
> come up with would have no greater weight than the opinion of any other
> competent counsel.
> DWM: This is a GNSO PDP, not an international convention. We need
> guidance from the ICANN GC.
> 
> As such, it is an interesting (and interestingly drafted) request, but
> I don't think it will be definitive or clarifying.  At most, It might
> start a lively debate.  I would suggest the following changes, based on
> the above comments.
> 
> 
> IGO-INGO Legal Review request:
> 
> With respect to the question of securing legal advice regarding the
> protection of IGO-INGO names, taking into account the work previously
> done regarding the IOC/Red Cross Red Crescent, the WG requests from the
> office of the ICANN General Counsel an answer to the following
> question:
> 
> 
> 
> Is ICANN aware of any jurisdiction in which a statute, treaty or other
> applicable law can be construed or interpreted to prohibit either or
> both of the following actions by or under the authority of ICANN:
> 
> a)      the assignment by ICANN at the top level, or
> 
> b)      the registration by a registry or a registrar accredited by
> ICANN of a domain name requested by any party at the second level,
> 
> of the name or acronym of
> 
> (i)                 an intergovernmental organization (IGO) or
> 
> (ii)               an international non-governmental organization
> receiving protections under treaties or and statutes having effect
> inunder multiple jurisdictions (INGO)?
> 
> 
> 
> If the answer is affirmative, please specify the jurisdiction(s) and
> cite the statute, treaty or other applicable law.  Please also cite the
> statutes, treaties and applicable laws considered, and the reasons for
> an affirmative or negative determination.
> 
> 
> 
> 
> 
> Best regards,
> 
> 
> 
> Greg
> 
> 
> 
> Gregory S. Shatan
> Partner
> Reed Smith LLP
> 599 Lexington Avenue
> New York, NY 10022
> 212.549.0275 (Phone)
> 917.816.6428 (Mobile)
> 212.521.5450 (Fax)
> gshatan@xxxxxxxxxxxxx<mailto:gshatan@xxxxxxxxxxxxx><mailto:gshatan@reed
> smith.com<mailto:gshatan@reeds
> mith.com<http://mith.com><mailto:gshatan@xxxxxxxxxxxxx>>
> www.reedsmith.com<http://www.reedsmith.com><http://www.reedsmith.com>
> 
> 
> 
> 
> 
> From: owner-gnso-igo-ingo@xxxxxxxxx<mailto:owner-gnso-igo-
> ingo@xxxxxxxxx><mailto:owner-gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx><mailto:owner-gnso-igo-
> ingo@xxxxxxxxx<mailto:owner-gnso-
> igo-ingo@xxxxxxxxx<mailto:igo-ingo@xxxxxxxxx>>> [mailto:owner-gnso-igo-
> ingo@xxxxxxxxx] On Behalf Of Gomes, Chuck
> Sent: Monday, November 12, 2012 6:26 PM
> To: Jim Bikoff; gnso-igo-ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>>>
> Cc: David Heasley; Kiran Malancharuvil
> Subject: RE: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG
> Proposal
> 
> Jim,
> 
> Registries and registrars need a definitive response from the ICANN
> General Counsel's Office regarding whether there are jurisdictions for
> which registration of IOC, RC and IGO names are illegal.  It will be up
> to the GC Office as to whether they can answer the questions using
> existing research that has already been done or whether they need any
> more research.  If you are correct, they may not need to do any further
> research for the IOC and RC names.  The RySG suggested request of the
> GC Office is not a request for legal research but rather a request for
> direction regarding the legality of registering IOC, RC and IGO names
> because we are required to follow applicable laws.  It is a common
> practice in the GNSO to request legal direction from the GC Office with
> regard to our registry and registrar agreements.
> 
> With regard to your suggested changes to the recommended RySG request,
> I personally do not see any problems with them, but I will leave it up
> to David Maher as the official RySG representative to the WG to
> respond.  The changes you propose don't seem necessary to me because I
> cannot imagine the GC Office handling the request without doing what
> you suggest, but neither do they seem to change the substance of the
> request so making them seems okay to me.
> 
> It is also my opinion that the GC Office response to the request will
> clarify the work needed by the WG.
> 
> Chuck
> 
> From:owner-gnso-igo-ingo@xxxxxxxxx<mailto:owner-gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>><mailto:owner-gnso-igo-
> ingo@xxxxxxxxx> [mailto:owner- gnso-igo-ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx>] On Behalf Of Jim Bikoff
> Sent: Monday, November 12, 2012 5:50 PM
> To: gnso-igo-ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx><mailto:gnso-igo-ingo@xxxxxxxxx<mailto:gnso-
> igo-ingo@xxxxxxxxx<mailto:igo-ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx>>
> Cc: David Heasley; Kiran Malancharuvil
> Subject: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG Proposal
> 
> Dear All,
> 
> The IOC does not believe that it is necessary to ask for legal review
> in respect to protections for the IOC and Red Cross.  If the group
> decides that the inquiry should be made, the IOC requests that issues
> relating to the IOC and Red Cross be separated from the issues relating
> to IGO/INGO names and acronyms, taking into account the work that was
> done previously.
> 
> Accordingly, the IOC submits the following revised language:
> 
> IGO-INGO Legal Review request:
> 
> With respect to the question of securing legal advice regarding the
> protection of IGO-INGO names, taking into account the work previously
> done regarding the IOC/Red Cross Red Crescent, the WG requests from the
> office of the ICANN General Counsel an answer to the following
> question:
> 
> 
> 
> Is ICANN aware of any jurisdiction in which a statute, treaty or other
> applicable law prohibits either or both of the following actions by or
> under the authority of ICANN:
> 
> a)      the assignment by ICANN at the top level, or
> 
> b)      the registration by a registry or a registrar accredited by
> ICANN of a domain name requested by any party at the second level, of
> the name or acronym of an intergovernmental organization (IGO) or an
> international non-governmental organization receiving protections under
> treaties and statutes under multiple jurisdictions (INGO)?
> 
> 
> 
> If the answer is affirmative, please specify the jurisdiction(s) and
> cite the law.
> 
> 
> 
> The WG requests that any previous correspondence, determination and
> research from ICANN General Counsel or ICANN Outside Counsel as to the
> IOC and Red Cross Red Crescent Movements be provided as a matter of
> expediency, without duplicating previous efforts.
> 
> 
> 
> Best regards,
> 
> 
> 
> Jim
> 
> 
> James L. Bikoff
> Silverberg, Goldman & Bikoff, LLP
> 1101 30th Street, NW
> Suite 120
> Washington, DC 20007
> Tel: 202-944-3303
> Fax: 202-944-3306
> jbikoff@xxxxxxxxx<mailto:jbikoff@xxxxxxxxx><mailto:jbikoff@xxxxxxxxx<ma
> ilto:jbikoff@xxxxxxxxx<mai
> lto:jbikoff@xxxxxxxxx>>
> 
> 
> 
> 
> 
> From:owner-gnso-igo-ingo@xxxxxxxxx<mailto:owner-gnso-igo-
> ingo@xxxxxxxxx<mailto:ingo@xxxxxxxxx>><mailto:owner-gnso-igo-
> ingo@xxxxxxxxx> [mailto:owner- gnso-igo-ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx>] On Behalf Of Berry Cobb
> Sent: Wednesday, November 07, 2012 10:18 PM
> To: gnso-igo-ingo@xxxxxxxxx<mailto:gnso-igo-
> ingo@xxxxxxxxx><mailto:gnso-igo-ingo@xxxxxxxxx<mailto:gnso-
> igo-ingo@xxxxxxxxx<mailto:igo-ingo@xxxxxxxxx><mailto:gnso-igo-
> ingo@xxxxxxxxx>>
> Subject: [gnso-igo-ingo] IGO-INGO - Legal Issues Review - RySG Proposal
> 
> Team,
> 
> Below you will find the RySG's proposed version for the Legal Issue
> Review request.  Per our call today, the WG is welcome to make
> amendment suggestions via the list.  Thank you for your input.  B
> 
> IGO-INGO Legal Review request:
> 
> With respect to the question of securing legal advice regarding the
> protection of IGO-INGO names, the WG requests from the office of the
> ICANN General Counsel an answer to the following question:
> 
> 
> 
> Is ICANN aware of any jurisdiction in which a statute, treaty or other
> applicable law prohibits either or both of the following actions by or
> under the authority of ICANN:
> 
> a)      the assignment by ICANN at the top level, or
> 
> b)      the registration by a registry or a registrar accredited by
> ICANN of a domain name requested by any party at the second level, of
> the name or acronym of an intergovernmental organization (IGO) or an
> international non-governmental organization receiving protections under
> treaties and statutes under multiple jurisdictions (INGO)?
> 
> 
> 
> If the answer is affirmative, please specify the jurisdiction(s) and
> cite the law."
> 
> 
> Berry Cobb
> Internet Corporation for Assigned Names & Numbers (ICANN)
> 720.839.5735
> mail@xxxxxxxxxxxxx<mailto:mail@xxxxxxxxxxxxx><mailto:mail@xxxxxxxxxxxxx
> <mailto:mail@xxxxxxxxxxxxx<
> mailto:mail@xxxxxxxxxxxxx>>
> @berrycobb
> 
> 
> 
> 
> 
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