Subject: RE: [Asrg] 6. Proposals - Legal - Subject labeling - FTC response

From: "Hallam-Baker, Phillip" <[email-masked]>
Date: Tue, 2 Dec 2003 11:21:14 -0800

> Hmmm ... I went back and look at section 111.2 of the bill.  I'm not
> sure I read it as requiring any action by the IETF.  Section 111.2
> merely says that any solution should conform to IETF standards,
> e.g., RFCs 2822, 2821.

In the light of this point and the points made by Yakov I suggest we proceed
as follows:

1) Send a note to the IAB telling them that we think that this is their tar
baby and that they should deal with it.

2) Attach to the note a >short< summary of the discusion on ASRG, viz

  * Concerns were raised about the practical value of labelling which the
FTC can evaluate for itself in the light of their mandate from Congress.

  * Responsibility for defining label terms and their use is properly the
domain of the FTC, the role of the IETF would appear to be limited to
defining the mechanism by which the labels are expressed.

  * Various mechanisms for expressing labelling were discussed, these
include overloading the subject line, use of the keywords field, defining a
new header. The advantages of and objections to overloading the subject line
and defining a new header are largely self evident.

  * The principal difficulty with use of keyword terms is the risk of
collision. This risk may be mitigated by defining some form of prefix scheme
analogous to the namespace scheme employed in XML. Keyword labels might be
encoded as USFTC:Spam or possibly IETF:Spam. It is likely that IANA
registration will be sufficient to avoid prefix collisions.

Given that we are not the IETF and given that we report through the IAB and
given that political philosophy is out of scope that would appear to be the
sum total of the discussion of the topic here that has relevance.

		Phill

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---

From: [email-masked]
Date: Tue, 2 Dec 2003 23:41:04 -0800

On Tue, Dec 02, 2003 at 11:21:14AM -0800, Hallam-Baker, Phillip wrote:
[...]
> defining the mechanism by which the labels are expressed.

The IETF is global, and the standards it develops are not restricted to
the US.  While it is very tempting to simply use labels from CAN-SPAM,
what if the Chines Government (for example) produced similar laws, but
with different labels? (The US government has limited jurisdiction over
email that originates from China.)

[...]

> registration will be sufficient to avoid prefix collisions.

Perhaps, but there are other issues.  The common case in an IANA
registry is that one or more "technical experts" are annointed to pass
on additions to the registry, but that doesn't seem appropriate here. 
There is another possible model, that of the urn/uri registries, where
essentially anyone can register a schema, and obvious problems are
vetted via a mailing list of interested parties.  It's not clear that's
appropriate, either. 

> sum total of the discussion of the topic here that has relevance.

OK, but... the IANA registry being hinted at seems to me to have some 
fairly unique characteristics, and it would probably be worth trying to 
outline at least some possibilities of how the IANA would manage it.

Regards

Kent

-- 
Kent Crispin                               "Be good, and you will be
[email-masked],[email-masked]            lonesome."
p: +1 310 823 9358  f: +1 310 823 8649               -- Mark Twain