[governance] Proposed statement on .ORG sale

[Sheetal Kumar]

Dear all,

Thanks for weighing in. Everyone agrees that transparency is what we must
ask for, at a minimum but there seems to be general agreement that this
isn't enough to ask for. I get the impression that there are two approaches
suggested here: 1) an approach that accepts the deal is going ahead and
asking for PIR to be incorporated as a benefit corporation 2) asking for a
halt/suspension to the sale unless certain conditions are met.

Opinions seem to weigh in more on the second approach but I suggest we hold
a poll to ascertain which path to go down and then go with that.


Best
Sheetal

On Fri, 6 Dec 2019 at 20:47, Ayden Férdeline <ayden at ferdeline.com> wrote:

> Thank you Imran, I do appreciate your edits, comments, and questions.
>
> It's not that I am comfortable with this deal. I suspect it will be a
> disaster.
>
> I just do not believe we will be able to persuade ISOC to change its
> decision here.
>
> All of the comments that I have seen individual ISOC Trustees make
> indicate a low level of understanding of the difference between a
> non-profit entity and a for-profit entity.
>
> They see PIR as an asset to be sold, like an office building, and believe
> the financial sustainability of ISOC is more important than meeting the
> public interest elements of their charter.
>
> I also see a deep belief in technological determinism in many of their
> comments.
>
> So I was trying to be as pragmatic as possible in what I was proposing.
>
> If this deal is happening, and ISOC doesn't seem to be backing down (nor
> in their evaluation do they believe criticism is sincerely held by anyone
> but a small number of individuals), then I think we need to put pressure on
> the Board to condition the sale on there being certain protections in place
> for registrants.
>
> PIR is transitioning into a for-profit company. I think that ISOC may have
> already petitioned the Orphans Court in Pennsylvania for this to happen.
> Ethos Capital will have a fiduciary duty to its shareholders, and it will
> be required to increase wholesale costs on .ORG domain names to fulfil that
> obligation. While their CEO has said they have no intention of operating
> PIR differently going forward, this is not consistent with his fiduciary
> duty. His role is to maximize shareholder value for Ethos Capital and act
> in the best interest of the corporation – not .ORG registrants.
>
> The only way we can be assured that they consider more than just the
> fiduciary interests of the corporation is to have PIR incorporated as a
> real benefit corporation (NOT a B Lab B Certification, which is what we are
> being offered at the moment). I think that is the best thing we can ask for
> at present.
>
> If PIR is a benefit corporation, this cannot be reversed, even if PIR is
> subsequently sold by Ethos Capital, and so we have long-term assurances
> that PIR will be legally obliged to consider societal impacts as well as
> fiduciary ones. But a B Lab B Certification can be dropped at any time if
> Ethos Capital so desires.
>
> ISOC's Board does not seem willing to rise to the occasion and to consider
> what is in the interests of the broader non-profit, non-governmental
> organization, and non-commercial communities. The Board is not in listening
> mode, they are just being defensive. I don't see that changing
> unfortunately, and I see no way to compel ISOC to listen to us. It is not a
> membership-based organization, it is essentially an independent trust.
> There are serious governance deficiencies that we need to attempt to
> address there in the future, particularly as the organization absorbs
> $1.135 billion. But the Board wants the money, and unless someone else
> steps forward offering more, they seem unwilling to change their mind.
>
> If that's the case, I regretfully feel like we have to ask for what little
> we can get in order to try to minimize the harm that is likely to accrue to
> .ORG, .NGO, and .ONG registrants.
>
> Best wishes,
>
> Ayden Férdeline
>
>
>
> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
> On Friday, 6 December 2019 13:17, Imran Ahmed Shah <
> governance at lists.riseup.net> wrote:
>
>
> Dear Sheetal,
>
> I agree with the Ian Peter. We needs the point to weigh-in our statement.
>
> I have some queries, suggestions and recommendations on the initial draft
> of Ayden and copying hereunder.
>
> Few comments:
> I think we should not evaluate Public Interest in terms of Money.... in
> any case...
> We should not to be more concerned with the financial figures.
> Perhaps, we may be concerned if it is being discussed in reference of the
> ICANN's decision and reasoning behind handing over the dotOrg to ISOC 'to
> support recurring expenses etc.'.. and now, if the ISOC has gotten enough
> benefits out of it,......dotORG should have to be returned to ICANN, so
> that ICANN can handover to some other similar not-for-profit trustworthy,
> credible organizations working for Public Interests, having the capacity to
> over see the Internet in Public domain and public interest.... to benefit
> next one after ISOC....
>
> Secondly, our goal is the protection of dotOrg from going it into the hand
> of commercial and nonpublic interest companies even if they could be able
> to recruiting, the hundreds of the CS members or can employee (or buy in
> some in-kind trade) ..to address public interests to claim.some kind of notional
> support board...
>
> I also suggest to create etherpad document... just created with the points
> shared by you... https://pad.riseup.net/p/IGConPIRv0NiRaxk3qi-keep
>
> = = = =  = = = = = = = = = = = = = = =  = = = = = = = = = = =
>
>  *To: Gonzalo Camarillo, Chair of the Board of Trustees, Internet Society*
>
> *As members of a network which encompasses many non-commercial
> organizations and public interest technologists, we are concerned by the
> announcement that Ethos Capital is acquiring the assets of the Public
> Interest Registry (PIR) from the Internet Society (ISOC), including the
> .ORG, .NGO, and .ONG Registry Agreements.  *
>
> *Principally, we are concerned that the sale of PIR to a private entity
> will significantly alter the Domain Name System and weaken ISOC. PIR played
> an important role, as the only remaining non-commercial top-level domain
> registry operator, in serving as a counterbalance against commercial
> exploitation. PIR ran .ORG, .NGO, and .ONG for the benefit of its users,
> whereas other top-level domains are run by private companies with purely
> financial objectives. While the interests of companies and users do at
> times overlap, they can also conflict, and when this occurs there are
> significant human rights implications. PIR, as a subsidiary of ISOC, could
> be relied upon to do what was best for domain name registrants, and has a
> proud history of doing just that. However, PIR also gave ISOC legitimacy
> and influence. It allowed ISOC to take an active role in shaping Internet
> infrastructure **[IAS: suggest to add here… “keeping the Public Interest
> Intact”]**. In relinquishing its control over PIR, ISOC loses its ability
> to directly impact how millions of people around the world positively
> experience the Internet every day, and we think that is a great pity.*
>
> *This is a significant change, for ISOC and for the Internet community,
> and we are not yet satisfied that there are appropriate safeguards in place
> to protect the interests of .ORG, .NGO, and .ONG registrants and the people
> who visit their websites every day. You have the ability to put requests to
> Ethos Capital and to call this deal off if appropriate and binding
> safeguards cannot be put in place**.* *[IAS: it very polite, humble
> request or perhaps diplomatic sentence/phrase. Which will result a simple
> answer “thanks for your deep concerns but we do not feel it appropriate at
> this stage the take the deal off”, the same I have listen from ICANN Chair
> in 2009]** We encourage you to do just that.** [IAS: What to do, to stop
> the deal or what is appropriate? Need to change this sentence and to be
> specific result that we are recommending or demanding] **As a sign of
> good faith, we ask that ISOC have Ethos Capital commit to incorporating PIR
> as a benefit corporation. **[IAS: again we are allowing them to proceed
> with the deal and seeking the alteration of the terms, rules/bylaws and
> commitment of a commercial entity to keep this public interest entity
> protected as a benefit organization…? Secondly, believing and understanding
> that the Investor “Ethos Capital” has invested the PIR to convert in
> B-Corp/ commercial entity how we assume that he will be accepting when he
> has investing billions..] **We understand that Ethos Capital has said
> they are evaluating becoming a B Lab B Corp, but this is not the same thing
> as a benefit corporation and is instead a non-binding certification. **[IAS:
> I suggest that we should use it as a proof that Ethos Capital has intention
> to transform the public interest entity into a B-Corp/ commercial entity.
> In the same context, we should ask ‘the Board’ that is this ‘intention’ was
> in their knowledge or in the knowledge of decision maker bodies that this
> faith base public interest entity will be commercialized by the new
> investor? If, yes, how they accepted it?]*
>
> *Large parts of the world* *[IAS: I suggest that here we have to use
> other terms which has higher weightage (weigh-in); e.g. one of the ISOC/PIR
> representative has responded like this “the objections are not reported
> from the majority of users, which means the majority of the users has no
> concern who is running the registry”]** are uncomfortable with the
> Internet being governed entirely by commercial interests, and many of our
> members **[IAS: I suggest that we have to elaborate “the members”, e.g
> IGC Members, IGC coalition Partners or perhaps including CSCG] **are
> deeply uncomfortable with PIR being sold at all. However, incorporation as
> a benefit corporation could provide a sturdier path forward if ISOC does
> proceed to sell the assets of PIR, and could be **[IAS: I suggest
> rephrase “Could have been assured”] **an effective means of mitigating
> against some of the risks that we can foresee emerging from this sale. A
> benefit corporation in the right jurisdiction would require the publication
> of comprehensive, credible, independent, and transparent annual reports on
> social impact and, most importantly, require the organization to consider
> benefits to the public in addition to profit when decisions are being made.
> And, it would oblige Ethos Capital to honor the promises and commitments it
> is making today.*
>
> *We trust that you understand why this is important to us. Ethos Capital
> is an unknown entity, and in the absence of clear information about their
> motives behind acquiring PIR and their sales pitch to investors, the
> non-profit and non-governmental communities require assurances that the
> future of the .ORG, .NGO, and .ONG domain names that we use for our email,
> websites, campaigns, and fundraising efforts are in safe hands. **[IAS: I
> suggest add these lines here “Our Data & Privacy is not being compromised,
> shared, observed, monitored are not shared or sold to the competitors
> (right now during transition or) in future by the Registry, or partner
> commercial/ noncommercial entities”] **These are more than just domains,
> they are symbols of our desire to do good.*
> = = = =  = = = = = = = = = = = = = = =  = = = = = = = = = = = = = = =  =
> = = = = = = = = = = = = = =  = = = = = = = = = = =
>
> *[IAS: I also have few more concerns:*
>
> *1.       **Needs transparency and disclosure of the followings (to
> re-establish of the trust being shacked):*
>
> *i.                     **the reasoning behind the selling PIR ‘out of
> the way’ (as apparently seems to me)?,*
>
> *ii.                   **the reasoning behind the avoidance of engaging a
> proper bidding?,*
>
> *iii.                  **the reasoning to giving sole power of decision
> of sales without the evaluation through open competition and opening
> comments to sell or not?,*
>
> *iv.                 **the information of intention disclosure regarding
> the commercialization aspect or transformation of PIR to B-Corp, when it
> came in to the knowledge of the selling bodies (prior/during/post sales
> agreement).*
>
> *v.                   **Technical Terms and basis of the Technical
> Evaluations of the Investor Ability, Capability, Credibility,
> Dependability.*
>
> *vi.                 **Safeguards evaluated in terms of Public Interest,
> Faith, Data Protection, Privacy, Security evaluated before making the
> decision of sales of PIR (.ORG/.NGO/.ONG)*
>
>
>
> *2.       **I would suggest that the statement should be in the following
> format:*
>
> Preamble/Preface paragraph:
>
> Objection/Obligation/Concerns
>
> What we demand:
>
> Our First Requirement is:
>
> Requirement of Information (e.g Transparency, Disclosure of deal/
> agreement/ technical/ functional/ organizational structural
> design/basis/planning)
>
> Our Second Requirement is:
>
> A.      The above facts and figures demand you to stop/end-up the due
> diligence process and stop the deal.
>
> If the efforts for A are convincingly & persuasively exercised and but
> could not achieving required goal-A, we recommends to achieve minimal
> goal-B after the adoption of above….
>
> B.      What we need if the Sales Deal is accomplished, i.e. ensure the
> commitment
>
> a.       Immediate commitment (prior to sale),
>
> b.      long term commitment (after sales),
>
> *(by the way I am not convinced that a commercial organization remains
> commitment for public interest for long term benefits. Maximum commitments
> one can expect is just for 2-3 years not beyond. Secondly, if the Ethos
> Capital sales this entity to any other commercial entity after changing its
> status to B-Corp, where the agreements with ISOC stands?)*
>  = = = = = = = = = = =  = = = = = = = = = = = = = = =  = = = = = = = = =
> = =
>
> Best Regards
>
> Imran Ahmed Shah
>
> [TLDians/UISoc/UiCouncil]
>
> On Friday, 6 December 2019, 01:13:59 GMT+5, Ian Peter <
> ian.peter at ianpeter.com> wrote:
>
>
> I agree approach and basic points Sheetal - but I would drop the human
> rights clause because it is contentious and does not add great value to the
> strong basic argument.
>
> Ian
>
> ------ Original Message ------
> From: "Sheetal Kumar" <sheetal at gp-digital.org>
> To: "parminder" <parminder at itforchange.net>
> Cc: "governance" <governance at lists.riseup.net>
> Sent: 6/12/2019 6:48:38 AM
> Subject: Re: [governance] Proposed statement on .ORG sale
>
> Dear Ayden, Parminder, all,
>
> First, thank you very much Ayden for putting this together! I appreciate
> the attempt to reconcile opposing views, which are clearly present in the
> IGC.
>
> I would just say that we have heard from very few others on this list.
> This may be for any number of reasons, and we could do a poll if its
> helpful to gather views, including whether people feel they need more
> information to be able to weigh in.
>
> To move forward, if we can agree on the following key points that we need
> to get across, we can work together on editing/finalising text.
>
> Short of a poll, if everyone could weigh-in on whether they agree on these
> points that would be helpful.
>
>
>    - There is a need for greater transparency about the terms of the sale
>    - There are potential implications for human rights if the sale goes
>    through (need to list/clearly enumerate these)
>    - As a result, many members of IGC align themselves with the
>    statements from EFF and Access Now and the call for an outright halt to the
>    sale.
>    - At a minimum, all IGC members agree there is a need for greater
>    transparency regarding the terms and potential implications of this sale,
>    and that there are appropriate safeguards in place to protect the interests
>    of .ORG, .NGO, and .ONG registrants and the people who visit their websites
>    every day
>
>
> It's difficult to get consensus at best of times, but this is a tricky
> issue and if we want to put forward something together we might need to go
> with what we can all agree on at a top-level.
>
> I look forward to hearing from a wide-range of people, and if anyone has
> alternative ideas please let us know.
>
> Best
> Sheetal
>
> On Wed, 4 Dec 2019 at 08:12, parminder <parminder at itforchange.net> wrote:
>
> thanks for this effort Ayden
>
> But when there is such a strong 'stop the sale' movement out there, it
> will be embarrassing for the IG related civil society groups to say, well,
> at least let Ethos now behave when ISOC did not .... Why ask Ethos to set
> PIR as a benefit corporation (which they will certainly not) when the
> existing arrangement (since the sale is not through) is itself more
> satisfactory? Why not ask for status quo and stopping the sale?
>
> parminder
> On 04/12/19 6:01 PM, Ayden Férdeline wrote:
>
> Dear all,
>
> I have a new proposed statement that I hope we may consider issuing.
> Please see below. I have used Sheetal's language as a starting point (thank
> you!) but I am afraid I did change the messaging quite a bit. This is just
> a suggestion and please do feel free to edit it to pieces.
>
> Like Brett, I too would prefer we advocate for stopping the sale
> altogether, but in the spirit of compromise and given a number of posts on
> this list that seem supportive of the sale, I've tried a different approach
> here.
>
> Thanks and best wishes,
> Ayden Férdeline
>
> *To:*    *Gonzalo Camarillo, Chair of the Board of Trustees, Internet
> Society*
>
> *As members of a network which encompasses many non-commercial
> organizations and public interest technologists, we are concerned by the
> announcement that Ethos Capital is acquiring the assets of the Public
> Interest Registry (PIR) from the Internet Society (ISOC), including the
> .ORG, .NGO, and .ONG Registry Agreements.  *
>
> *Principally, we are concerned that the sale of PIR to a private entity
> will significantly alter the Domain Name System and weaken ISOC. PIR played
> an important role, as the only remaining non-commercial top-level domain
> registry operator, in serving as a counterbalance against commercial
> exploitation. PIR ran .ORG, .NGO, and .ONG for the benefit of its users,
> whereas other top-level domains are run by private companies with purely
> financial objectives. While the interests of companies and users do at
> times overlap, they can also conflict, and when this occurs there are
> significant human rights implications. PIR, as a subsidiary of ISOC, could
> be relied upon to do what was best for domain name registrants, and has a
> proud history of doing just that. However, PIR also gave ISOC legitimacy
> and influence. It allowed ISOC to take an active role in shaping Internet
> infrastructure. In relinquishing its control over PIR, ISOC loses its
> ability to directly impact how millions of people around the world
> positively experience the Internet every day, and we think that is a great
> pity.*
>
> *This is a significant change, for ISOC and for the Internet community,
> and we are not yet satisfied that there are appropriate safeguards in place
> to protect the interests of .ORG, .NGO, and .ONG registrants and the people
> who visit their websites every day. You have the ability to put requests to
> Ethos Capital and to call this deal off if appropriate and binding
> safeguards cannot be put in place. We encourage you to do just that. As a
> sign of good faith, we ask that ISOC have Ethos Capital commit to
> incorporating PIR as a benefit corporation. We understand that Ethos
> Capital has said they are evaluating becoming a B Lab B Corp, but this is
> not the same thing as a benefit corporation and is instead a non-binding
> certification. *
>
> *Large parts of the world are uncomfortable with the Internet being
> governed entirely by commercial interests, and many of our members are
> deeply uncomfortable with PIR being sold at all. However, incorporation as
> a benefit corporation could provide a sturdier path forward if ISOC does
> proceed to sell the assets of PIR, and could be an effective means of
> mitigating against some of the risks that we can foresee emerging from this
> sale. A benefit corporation in the right jurisdiction would require the
> publication of comprehensive, credible, independent, and transparent annual
> reports on social impact and, most importantly, require the organization to
> consider benefits to the public in addition to profit when decisions are
> being made. And, it would oblige Ethos Capital to honor the promises and
> commitments it is making today.*
>
>
>
> *We trust that you understand why this is important to us. Ethos Capital
> is an unknown entity, and in the absence of clear information about their
> motives behind acquiring PIR and their sales pitch to investors, the
> non-profit and non-governmental communities require assurances that the
> future of the .ORG, .NGO, and .ONG domain names that we use for our email,
> websites, campaigns, and fundraising efforts are in safe hands. These are
> more than just domains, they are symbols of our desire to do good.*
>
>
>
>
> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
> On Sunday, 1 December 2019 17:44, Sheetal Kumar <sheetal at gp-digital.org>
> <sheetal at gp-digital.org> wrote:
>
> Dear Ayden, all,
>
> Thanks for your responses! It seems to me that if we're going to agree on
> anything, it's the lack of transparency that we can agree needs to be
> rectified. I've slightly reworded the below in light of the recent
> suggestions and remarks.
>
> What do others think about Sylvain's suggestions of asking about setting
> up a commons PIR (is this possible/feasible?) and of sending this also to
> ISOC's BoT and CEO? Do you have any others?
>
>
> *As members of a network which encompasses many non-commercial
> organisations, we are concerned about the lack of transparency regarding
> the sale of .ORG. When the board discusses the sale of .org, we request
> that these questions are considered in the due diligence process:   *
>
>
>
>
> *- What does the Board intend to do in order to protect the existing
> millions of .ORG registrants? - After the changes to the .ORG contract to
> preserve existing rights of .ORG registrants, how else does the Board
> intend to ensure the sale of PIR (this new steward of .org) will act on
> behalf of the public interest and the world community of noncommercial,
> civil society groups in the world? - What are ICANN's obligation to protect
> those organizations engaged in missions of "public interest around the
> world?" - How does the Board respond to allegations/concerns regarding
> possible conflict of interest in transference of stewardship to Ethos
> capital?*
>
> *We request answers to these questions in the spirit of building trust
> among NGOs and the non-commercial constituency more generally and those who
> play a key role in stewarding the Internet.*
>
>
>
>
> On Sat, 30 Nov 2019 at 17:58, Ayden Férdeline <ayden at ferdeline.com> wrote:
>
> While I agree these are questions for the ISOC Board of Trustees, I
> believe they are *also* questions for the ICANN Board. I expect that the
> ICANN Board will not respond to them, but I think they could - and should -
> and I encourage us to place pressure on both parties to take these
> questions and the sentiments behind them seriously.
>
> ICANN, in particular, does need to address at least the perception that
> there is a revolving door of insiders who are behind this and other deals.
> And ISOC needs to be more transparent about what due diligence it did
> before entering into the arrangement to sell PIR, and what mechanisms it
> has put in place (if any) to protect .ORG, .NGO, and .ONG registrants.
> Thanks.
>
> Best wishes, Ayden Férdeline
>
>
>
> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
> On Saturday, 30 November 2019 13:34, James Gannon <james at cyberinvasion.net>
> wrote:
>
> These are questions for the ISOC Board not the ICANN board.
>
>
> Sent from my iPhone
>
> On 30 Nov 2019, at 13:09, Sheetal Kumar <sheetal at gp-digital.org> wrote:
>
> 
> Dear all,
>
> What do people think about sending a letter to the ICANN Board with a
> series of questions in order to get more transparency? Bruna and I
> discussed this, and chatted to others, and are wondering what you think of
> this approach. As the Board will meet and discuss the sale as part of a due
> diligence process, we thought it might be a constructive approach to
> request they consider and answer certain questions.
>
> It would be great to hear your views on this approach and on the
> questions. See below:
>
>
> *When the board discusses the sale of .org, we request that these
> questions are considered in the due diligence process:   *
>
>
>
>
> *- What does the Board intend to do in order to protect the existing
> millions of .ORG registrants? - After the changes to the .ORG contract to
> preserve existing rights of .ORG registrants, how else does the Board
> intend to ensure the sale of PIR (this new steward of .org) will act on
> behalf of the public interest and the world community of noncommercial,
> civil society groups in the world? - What's ICANN's obligation to protect
> those organizations engaged in missions of "public interest around the
> world?" - How does the Board respond to allegations/concerns regarding
> possible conflict of interest in transference of stewardship to Ethos
> capital*
>
> Best
> Sheetal
>
> On Fri, 29 Nov 2019 at 02:36, Sylvain Baya <governance at lists.riseup.net>
> wrote:
>
> Hi all,
>
> Le jeudi 28 novembre 2019, Bill Woodcock <woody at pch.net> a écrit :
>
> > they can (even without sourcing their affirmation) then note that the
> > minority of *non-commercial* [1] Internet Community is about to be
> *eliminated* by their
> > 'well intended' *big deal*.
> >
> > Why ?
> > ...i guess that 1% of 10M (domain names) +=> the non-commercial [1]
> world is under
> > the pressure of commercial world in the Internet, even in .ORG
> registrations they are
> > still oppressed by 99% of 10M
>
> None of the above parses.  Please try again, with simpler construction.
> You can break it out into as many sentences as you like, but please try to
> make each one encapsulate exactly one thought.  Else nobody is going to be
> able to engage in a constructive conversation with you.
>
>
> ...what's the point please, dear Bill ?
> Do you really want to convince me without argumenting ?
>
> Shalom,
> --sb.
>
>
>
>                                 -Bill
>
>
>
> --
>
>
>
>
> --
> Best Regards !
> baya.sylvain [AT cmNOG DOT cm] | <https://www.cmnog.cm> | <
> https://survey.cmnog.cm>
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> --
>
>
>
>
> *Sheetal Kumar*
> Senior Programme Lead | GLOBAL PARTNERS DIGITAL
> Second Home, 68-80 Hanbury Street, London, E1 5JL
> T: +44 (0)20 3 818 3258| M: +44 (0)7739569514  |
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> --
>
>
>
> *Sheetal Kumar*
> Senior Programme Lead | GLOBAL PARTNERS DIGITAL
> Second Home, 68-80 Hanbury Street, London, E1 5JL
> T: +44 (0)20 3 818 3258| M: +44 (0)7739569514  |
> PGP ID: E592EFBBEAB1CF31  | PGP Fingerprint: F5D5 114D 173B E9E2 0603
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> *Sheetal Kumar*
> Senior Programme Lead | GLOBAL PARTNERS DIGITAL
> Second Home, 68-80 Hanbury Street, London, E1 5JL
> T: +44 (0)20 3 818 3258| M: +44 (0)7739569514  |
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-- 


*Sheetal Kumar*
Senior Programme Lead | GLOBAL PARTNERS DIGITAL
Second Home, 68-80 Hanbury Street, London, E1 5JL
T: +44 (0)20 3 818 3258| M: +44 (0)7739569514  |
PGP ID: E592EFBBEAB1CF31  | PGP Fingerprint: F5D5 114D 173B E9E2 0603 DD7F
E592 EFBB EAB1 CF31|
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