Emeritus Executive Director and Legal Counsel Coalition for Online Accountability
Joined on January 11, 2023
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Dean S. Marks is Emeritus Executive Director for the Coalition for Online Accountability (“COA”) and served as Executive Director and Legal Counsel for COA from 2018 through 2022. He was in-house counsel for more than 25 years with Warner Bros. and Time Warner, most recently as Senior Vice President, Intellectual Property. From 2015 to 2017, Dean was Deputy General Counsel and Chief, Global Content Protection for the Motion Picture Association of America, where he headed a global team to safeguard film and television content from all forms of piracy. He served as Vice President of the Intellectual Property Constituency at ICANN from 2018-2021 and currently serves on the Advisory Council of the DNS Abuse Institute.
On June 9 CircleID published an insightful article by Thomas Rickert entitled "Demystifying Art 28 NIS2." In that piece Thomas set forth two alternative interpretations of Article 28(6) of NIS2, and argued that TLD registries should not be required to maintain a separate database of the registrant data under NIS2. In my view, Thomas' approach is inconsistent with the remainder of Article 28, and would not achieve the goals of NIS2 to improve cybersecurity across the EU member states. more
The recent adoption at the end of December of the new EU Directive for a high level of cybersecurity across the Union -- commonly referred to as "NIS2" - paved the way for important updates to the domain name system (DNS). Most significantly, Article 28 of NIS2 and its related recitals resolved any ambiguities about the public interest served by a robust and objectively accurate WHOIS system that permits legitimate access by third parties to data... more
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