[Manila Principles] Seeking your inputs on proposal to restructure the document

Raegan MacDonald raegan at accessnow.org
Fri Feb 13 10:31:17 PST 2015

Dear all,

Thank you Jyoti, Jeremy and everyone who has put in so much work to kick
start this ambitious initiative to come up with global principles on the
complicated issue of intermediary liability. The split in the document on
best practices and high level principles may provide needed precision.
However there is a further need to address the various instances where
intermediary liability/voluntary actions may come into play. E.g. the
blocking of:

   - criminal content by judicial order;
   - voluntary blocking of allegedly criminal content;
   - alleged civil infringements;

as well as takedowns in relation to the above, and blocking/takedowns that
is not alleged to be either criminal or civil infringements.

I regret to say that the document requires a significant amount of work,
and we are not in a position to submit comments in the short time frame
that has been suggested. We would like to request that the deadline be

Thank you for your consideration and we look forward to providing input on
this important issue.

All the best,

On 10 February 2015 at 06:19, Jyoti Panday <jyoti at cis-india.org> wrote:

> Dear All,
> Thank you to all of you who have taken out the time to comment
> and provide your feedback on the principles.
> On behalf of the steering committee of the Manila Principles project, I
> am writing to you update you on our discussions on the way forward
> following the end of the comment period on 15th February
> 2015.
> As we have highlighted earlier, the Manila Principles will be a best
> practices framework and set of baseline safeguards for regulators and
> intermediaries to consider when developing, adopting, and reviewing
> legislation, policies and practices that extend liability to
> intermediaries for online third party content.
> One of the issues that has come up in the preliminary feedback, is
> that the Manila Principles are aiming to be both a best practices
> document and create a set of cross cutting principles. As some of you
> have pointed out this does not provide guidance on what kind of
> intermediary liability regime should be adopted under certain
> circumstances.
> In response to the preliminary feedback and towards resolving this, we
> are currently deliberating a proposal of splitting the document between
> principles and best practices.
> We have attached a PDF of the working draft in this email illustrating
> the proposed split. Please note that the attached document is not a
> final version and there are many comments from the consultation that are
> yet to be integrated. The purpose of circulating this version is to seek
> input on structuring the recommendations and the proposed split between
> the principles and the best practices.
> We would be very grateful if you could provide your feedback and
> comments on this proposed structure.
> Many thanks, and we look forward to working with you as we jointly
> develop and launch the Manila Principles on Intermediary Liability.
> Sincerely,
> Jyoti Panday
> _______________________________________________
> ManilaPrinciples mailing list
> ManilaPrinciples at eff.org
> https://lists.eff.org/mailman/listinfo/manilaprinciples

*Raegan MacDonald*
European Policy Manager
Access | accessnow.org <https://www.AccessNow.org/>

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