MARF Working Group                                               J. Falk
Internet-Draft                                               Return Path
Intended status: Experimental                           January 13, 2011
Expires: July 17, 2011


      A DNS TXT Record for Advertising and Discovering Willingness
                   to Provide or Receive ARF Reports
                draft-jdfalk-marf-reporting-discovery-03

Abstract

   This document defines a method for network operators to advertise
   their willingness to send feedback about received email to other
   parties, and for those other parties to advertise their willingness
   to receive such feedback.

Status of this Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
   Drafts is at http://datatracker.ietf.org/drafts/current/.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   This Internet-Draft will expire on July 17, 2011.

Copyright Notice

   Copyright (c) 2011 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents
   (http://trustee.ietf.org/license-info) in effect on the date of
   publication of this document.  Please review these documents
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   include Simplified BSD License text as described in Section 4.e of
   the Trust Legal Provisions and are provided without warranty as
   described in the Simplified BSD License.



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Table of Contents

   1.  Introduction . . . . . . . . . . . . . . . . . . . . . . . . .  3
   2.  Purpose  . . . . . . . . . . . . . . . . . . . . . . . . . . .  3
   3.  Requirements . . . . . . . . . . . . . . . . . . . . . . . . .  4
   4.  Language . . . . . . . . . . . . . . . . . . . . . . . . . . .  4
     4.1.  General  . . . . . . . . . . . . . . . . . . . . . . . . .  4
     4.2.  Email Specific . . . . . . . . . . . . . . . . . . . . . .  5
     4.3.  ARF Specific . . . . . . . . . . . . . . . . . . . . . . .  5
   5.  Characteristics of a Feedback Reporting Advertisement  . . . .  5
     5.1.  Feedback Consumers . . . . . . . . . . . . . . . . . . . .  6
       5.1.1.  Feedback Consumer Policies . . . . . . . . . . . . . .  6
     5.2.  Feedback Generators  . . . . . . . . . . . . . . . . . . .  6
       5.2.1.  Feedback Generator Policies  . . . . . . . . . . . . .  7
     5.3.  Combining Generator and Consumer Tags in the Same
           Record . . . . . . . . . . . . . . . . . . . . . . . . . .  7
     5.4.  Note about URIs  . . . . . . . . . . . . . . . . . . . . .  7
     5.5.  Formal Definition  . . . . . . . . . . . . . . . . . . . .  7
   6.  Example Records for Various Use Cases  . . . . . . . . . . . .  8
     6.1.  Example Feedback Consumer Records  . . . . . . . . . . . .  8
     6.2.  Example Feedback Generator Records . . . . . . . . . . . .  8
   7.  Authentication of Reported Message . . . . . . . . . . . . . .  9
     7.1.  DKIM signatures  . . . . . . . . . . . . . . . . . . . . .  9
     7.2.  SPF authorized sender  . . . . . . . . . . . . . . . . . .  9
   8.  IANA Considerations  . . . . . . . . . . . . . . . . . . . . . 10
   9.  Security Considerations  . . . . . . . . . . . . . . . . . . . 10
     9.1.  Inherited from MARF-BASE . . . . . . . . . . . . . . . . . 10
     9.2.  These Need Fleshing Out  . . . . . . . . . . . . . . . . . 10
     9.3.  Privacy considerations . . . . . . . . . . . . . . . . . . 10
   10. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . 11
   11. Contributors . . . . . . . . . . . . . . . . . . . . . . . . . 11
   12. References . . . . . . . . . . . . . . . . . . . . . . . . . . 11
     12.1. Normative References . . . . . . . . . . . . . . . . . . . 11
     12.2. Informative References . . . . . . . . . . . . . . . . . . 12
   Appendix A.  Public Discussion, History and Support  . . . . . . . 13
   Appendix B.  Document History & Open Issues  . . . . . . . . . . . 13
     B.1.  draft-jdfalk-marf-reporting-discovery-00 . . . . . . . . . 13
     B.2.  draft-jdfalk-marf-reporting-discovery-01 . . . . . . . . . 13
     B.3.  draft-jdfalk-marf-reporting-discovery-02 . . . . . . . . . 14
     B.4.  draft-jdfalk-marf-reporting-discovery-03 . . . . . . . . . 14
   Author's Address . . . . . . . . . . . . . . . . . . . . . . . . . 14










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1.  Introduction

   As the spam problem continues to expand and potential solutions
   evolve, network operators are increasingly exchanging abuse reports
   among themselves and other parties.  While [MARF-BASE] defines the
   Abuse Reporting Format (ARF) for these reports, it assumes that the
   operators will use some undefined method to discover each other and
   enter into any necessary agreements.

   The advertisement method defined in this memo is intended to ease the
   process for potential ARF recipients to discover whether a particular
   ADministrative Management Domain (ADMD) has the facility and
   willingness to generate ARF reports, and for ARF generators to
   discover whether a particular ADMD is able and willing (and
   authorized) to receive ARF reports.

   While written primarily for initial discovery and configuration of
   feedback relationships, it is expected that these advertisements will
   also be useful for updating participants when parameters have
   changed.

   Further, while this document only defines a DNS TXT record to contain
   these advertisements, other methods may be defined in the future.

   This document only defines the process for advertisement and
   discovery of feedback recipients.  Determination of when it is
   appropriate to send feedback or how trust may be established between
   report generators and report consumers is outside the scope of this
   document.  It is assumed that best practices will continue to evolve
   over time, and will be codified in future documents.


2.  Purpose

   The reports defined in [MARF-BASE] are intended to inform mail
   operators about:
   o  email abuse originating from their networks;
   o  potential issues with the perceived quality of outbound mail, such
      as email service providers sending mail that attracts the
      attention of automated abuse detection systems.
   To support these purposes, this document addresses three primary use
   cases:
   o  Any ADMD may advertise its willingness to receive reports from the
      internet at large, given particular criteria included in or
      referenced by the advertisement;
   o  Any ADMD may advertise their willingness to provide reports to the
      Internet at large, given particular criteria included in or
      referenced by the advertisement;



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   Further, an ADMD which is generating reports may query the
   advertisement of an ADMD that wishes to receive reports, in order to
   confirm that an out-of-band request to receive reports is legitimate
   and/or to determine if any of the characteristics of the request have
   changed.

   This specification inherits from [MARF-BASE] that it is intended
   specifically for communications among providers regarding email abuse
   and related issues, and SHOULD NOT be used for other reports unless
   those feedback-types specifically mention this document.  For
   example, the [DKIM-REPORTING] extension includes its own ARF
   recipient discovery method that should not be confused with the
   method defined in this memo.


3.  Requirements

   The advertisement and discovery process must be easily accessible to
   the software involved in providing email service, preferably using
   concepts and technologies an email operator can be assumed to be
   familiar with.  Thus, following the examples of [DKIM] and
   [DKIM-REPORTING], the advertisement is in the form of a [DNS] TXT
   record.  While this may provide challenges for offline processing,
   this is outweighed by the advantages of security and maintainability.

   In order to reflect current usage, advertisements must also provide
   the ability to reference complex "terms of service" or other
   documents outside of the scope of a simple discovery method.  This is
   accomplished through the inclusion of a URI.

   And finally, the advertisement must be readable by humans (assuming
   they have access to this RFC) as well as software specifically
   written for the purpose.


4.  Language

   This section defines various terms used throughout this document.

4.1.  General

   The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT",
   "SHOULD", "SHOULD NOT", "RECOMMENDED", "MAY", and "OPTIONAL" in this
   document are to be interpreted as described in [KEYWORDS].







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4.2.  Email Specific

   [EMAIL-ARCH] introduces several terms and concepts that are used in
   this memo, and thus readers are advised to become familiar with it as
   well.

4.3.  ARF Specific

   [MARF-BASE] introduces terms and concepts that are necessary for a
   full understanding of this memo, and thus readers are advised to read
   it before continuing.


5.  Characteristics of a Feedback Reporting Advertisement

   An advertisement of willingness to generate or receive feedback is
   accomplished by publishing a TXT record in the [DNS] using the name
   '_report' within the given DNS domain.

   This record will contain a sequence of "tag=value" pairs, separated
   by semicolons.  The tags and possible values are described in the
   next two sections, followed by the precise ABNF grammar.

   In the case of a feedback consumer, the advertisement should be
   published in the DNS domain matching the [DKIM] 'd=' value used on
   outgoing signatures, and/or in the DNS domain matching the one
   present in the [SMTP] MAIL commands it issues when sending mail,
   and/or in the DNS domain referenced by the DNS PTR record (sometimes
   called "reverse DNS") of the IP address of the border MTA used to
   transfer the message.

   In the case of a feedback generator, to inquire whether or not an
   ADMD wishes to receive feedback reports, the DNS domain to which the
   report should be sent is determined (using a mechanism at the
   discretion of the generator) and then a TXT record query to the above
   name is issued.  For example, if a report generator wishes to
   generate a report about a message bearing DNS domain 'example.com',
   the generator would issue a TXT record query for
   `_report.example.com'.

   Feedback generators SHOULD NOT send reports to ADMDs that are not in
   any way responsible for the reported message, for both security and
   efficiency reasons.  Responsibility can be ascertained as described
   in Section 7, and by applying local policy.

   In the case of a feedback generator who wishes to advertise that
   reports are available, the TXT record is placed by the DNS domain at
   which they receive mail.  For example, to advertise reports regarding



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   mail received at example.net, the advertisement is placed in
   _report.example.net.

5.1.  Feedback Consumers

   A "Feedback Consumer" is an entity which wishes to receive feedback.
   In most cases, the Feedback Consumer will be within the same ADMD as
   the identifier (domain name or IP address) used to determine the
   source of a message.

   r  the address to which reports should be sent.  Required; no
      default.  This address MUST be able to respond to an emailed
      subscription verification request; see Security Considerations
      below.
   rf the format of the report requested; currently only "ARF"
      ([MARF-BASE]) is supported.  Optional; defaults to ARF.
   ri requested report interval; may not be supported by all
      implementors.  Optional; if omitted, all reports may be sent.
   rt colon-separated list of ARF ([MARF-BASE]) feedback types for which
      reports are requested.  Optional; if omitted, all report types may
      be sent.
   re email address of a person or role account responsible for handling
      any issues related to receiving reports.  Optional, but SHOULD be
      defined; defaults to postmaster@ the DNS domain.
   rp stated policy, as listed below.  Optional; defaults to "o".
   ru URI for additional contact information.  Optional, but SHOULD be
      defined; there is no default value.

5.1.1.  Feedback Consumer Policies

   Policies are listed in the "rp" tag, described above.
   o  open to reports from all sources.  This is the default.
   c  closed; no reports are requested.  This option is intended for
      testing purposes, or for feedback arrangements which have been set
      up using methods outside of the scope of this document.

5.2.  Feedback Generators

   A "Feedback Generator" is an entity which generates feedback reports.
   Often, the Feedback Generator is within the same ADMD as the mail
   server which received the message.

   gf the format of reports offered; currently only "ARF" ([MARF-BASE])
      is supported.  Optional; defaults to "ARF".







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   gt colon-separated list of ARF ([MARF-BASE]) feedback types for which
      reports are available.  (Optional; if omitted, any report types
      may be generated.)
   ge email address of a person (or role account) responsible for
      handling any issues related to receiving reports.  Optional, but
      SHOULD be defined; defaults to postmaster@ the DNS domain.
   gp stated policy, as listed below.  Optional; defaults to "o".
   gu URI for additional information.  This field SHOULD be defined for
      a policy of "o" or "c", and MUST be defined when the policy is
      "r".  Otherwise, the field is optional; there is no default.

5.2.1.  Feedback Generator Policies

   Policies are listed in the "gp" tag, described above.

   o  open to providing reports to any consumer.  This option is the
      default policy.
   r  open to providing reports only after the prospective consumer has
      completed an application process, which may be found at the URI
      defined by the "gu" tag above.
   c  closed; no reports are available.  This option is intended for
      testing purposes, or for feedback arrangements which have been set
      up using methods outside of the scope of this document.

5.3.  Combining Generator and Consumer Tags in the Same Record

   It is common for a Feedback Generator to also act as a Feedback
   Consumer.  When this happens, they MAY include both types of tags in
   the same TXT record.

   When parsing these records, implementors MUST accept both types of
   tags in the same record, and MUST NOT expect the tags to appear in
   any particular order.  Implementors MUST ignore any unfamiliar tags
   or other unexpected text.

5.4.  Note about URIs

   While this memo assumes that advertisements will contain http:// or
   similar URIs, implementors should be aware that the URI-related
   fields can carry many different types of data depending on the URI
   scheme used.  For more information, please consult the URI Schemes
   registry maintained by IANA.

5.5.  Formal Definition

   The formal definition using [ABNF] is TBD.





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6.  Example Records for Various Use Cases

   While (in the author's mind) these examples address many of the most
   common use cases, implementers MUST NOT assume that only these
   configurations will ever be seen on the real live internet.

6.1.  Example Feedback Consumer Records

   Perhaps the most common scenario today is where a sender of bulk
   commercial email wishes to receive any complaints about messages
   originating from the servers under their control.  These servers are
   identified by IP address or range.  The PTR record for one of the IP
   addresses in question is "outmail5.example.com", so the advertisement
   could be:

   _report.outmail5.example.com TXT "r=complaints@example.com; rf=ARF;
   rt=abuse,fraud,virus,other; re=isprelations@example.com;"

   This would need to be repeated for each PTR record, perhaps
   outmail1.example.com through outmail7.example.com.  (NOTE: per [DNS],
   you cannot have both PTR and TXT associated with the same DNS record.
   Instead, the TXT record is associated with the _destination_ of the
   PTR pointer.)

   Or, if they sign all of their outbound mail with a [DKIM] d= string
   of "example.com", they could place the same advertisement in a TXT
   record at _report.example.com.

   example.com TXT "r=complaints@example.com; rf=ARF;
   rt=abuse,fraud,virus,other; re=isprelations@example.com;"

   Another common scenario is of a mailbox or access provider who wishes
   to receive complaints about mail sent by their users.  That record
   would be very similar, and would again be applied to PTR and/or d=
   domains:

   example.com TXT "r=abuse@example.net; rf=ARF; rt=abuse,fraud,virus;
   re=postmaster@example.net;"

6.2.  Example Feedback Generator Records

   The most common scenario today is where a large mailbox provider
   offers feedback to qualified Feedback Consumers who have filled out
   an application form.  While the full application process cannot be
   adequately represented inside of a single DNS record, the "gp" and
   "gu" fields permit advertisement of this policy:

   example.net TXT "gf=ARF; gt=abuse; ge=postmaster@example.net; gp=r;



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   gu=http://postmaster.example.net/fbl/"

   However, it is rare for a Feedback Generator -- most often a mailbox
   provider or similar service -- to not also be a Feedback Consumer.
   If they wish to place an advertisement using the PTR method, there is
   usually no conflict.  However, if their outbound mail is signed with
   [DKIM] and the d= value is the same domain at which they receive
   mail, then the advertisement will need to contain both generator and
   consumer tags:

   example.net TXT "gf=ARF; gt=abuse; ge=postmaster@example.net; gp=r;
   gu=http://postmaster.example.net/fbl/"; rf=ARF;
   r=abuse+arf@example.net; rt=abuse,fraud,other;
   re=postmaster@example.net;"

   Or, they MAY split the Generator and Consumer tags into separate TXT
   records under the same domain.

   Were a Feedback Generator to only offer authentication results, they
   could advertise thusly:

   "gf=ARF; gt=auth; ge=postmaster@example.net; gp=o;
   gu=http://postmaster.example.net/auth/"


7.  Authentication of Reported Message

   [AUTH-METHODS] and its extensions define a number of authentication
   methods that allow the recipient of a message to determine which ADMD
   is responsible for the message.  A Report Generator MUST utilize one
   or more of these methods to ensure that reports are being sent to a
   Report Consumer within the correct ADMD, and furthermore it is
   RECOMMENDED that the Report Consumer utilize these same methods to
   ensure that a message reported to them was indeed sent by who they
   think it was sent by.  For example:

7.1.  DKIM signatures

   Any valid DKIM signature in the reported message provides a domain
   name, either the signature "d" tag, or the domain-part of the
   signature "i" tag.

7.2.  SPF authorized sender

   When the check_host() function described in [SPF] results in a "pass"
   for the envelope sender, the domain part of that address.  Otherwise,
   if a "pass" is obtained for the HELO/EHLO name, that domain name is
   used.



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8.  IANA Considerations

   This memo will create an IANA registry of MARF discovery record tags
   and their legal values and defining documents; this section is yet to
   be written.


9.  Security Considerations

   The following security considerations apply when generating or
   processing a feedback report:

9.1.  Inherited from MARF-BASE

   All of the Security Considerations from [MARF-BASE] are inherited
   here.

9.2.  These Need Fleshing Out

   Subscription verification requests.

   [DNSSEC] SHOULD be used to ensure authenticity of all DNS requests
   and replies.

   Reference the data redaction discussion that will appear in an
   updated dkim-reporting draft soon.

   Feedback destination mailboxes are potentially sinks for private
   information, and should be secured accordingly.  The precise methods
   of securing mailbox files are outside of the scope of this document.

   Additional security considerations are likely, and TBD.

9.3.  Privacy considerations

   [Should these be moved to a BCP?]

   When recipients report received messages as spam, they deny any
   involvement with whoever may turn out to be responsible of authoring
   or forwarding that mail.  Users submit that spam to the community at
   large in the hope that a corrective action may be taken.  In that
   respect, the only privacy issue is to avoid to further divulge the
   email addresses of reporting users, or let them be profiled.
   Suitably redacted email addresses are an acceptable remedy.
   Responsible senders are advised to include opaque tokens as
   necessary, in order to reconstruct needed data.

   However, users may also err.  Unwanted smear may result in case a



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   message containing confidential data is erroneously reported as spam.
   Authentication and policies are concerned with avoiding such
   circumstances.  Recipients of special addresses at an ADMD that
   handled a given message could have intercepted the message when they
   signed or relayed it, if they wanted to, therefore it is less of a
   concern to forward abuse reports there.

   Contact addresses for a given domain name should bear such name as
   their domain parts.  Generators may treat non-conforming addresses
   with great suspicion, possibly avoiding to relay to them.


10.  Acknowledgements

   This document was heavily influenced by discussions on the topic
   within the IRTF Anti-Spam Research Group, collected at [ASRG-ABUSE].


11.  Contributors

   Many thanks to Murray Kucherawy, Alessandro Vesely, Todd Herr, Jacob
   Rideout, Derek Diget, Yakov Shafranovitch, Barry Leiba, Tim Draegen,
   and Michael Adkins for their suggestions and contributions.


12.  References

12.1.  Normative References

   [ABNF]     Crocker, D. and P. Overell, "Augmented BNF for Syntax
              Specifications: ABNF", RFC 5234, January 2008.

   [AUTH-METHODS]
              Kucherawy, M., "Message Header Field for Indicating
              Message Authentication Status", RFC 5451, April 2009.

   [DNS]      Mockapetris, P., "Domain Names -- Implementation and
              Specification", RFC 1035, November 1987.

   [KEYWORDS]
              Bradner, S., "Key words for use in RFCs to Indicate
              Requirement Levels", RFC 2119, March 1997.

   [MAILBOX-NAMES]
              Crocker, D., "MAILBOX NAMES FOR COMMON SERVICES, ROLES AND
              FUNCTIONS", RFC 2142, May 1997.

   [MARF-BASE]



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              Shafranovich, Y., Levine, J., and M. Kucherawy, "An
              Extensible Format for Email Feedback Reports", RFC TBD,
              April 2010.

   [SMTP]     Klensin, J., "Simple Mail Transfer Protocol", RFC 5321,
              October 2008.

   [SPF]      Wong, M. and W. Schlitt, "Sender Policy Framework (SPF)
              for Authorizing Use of Domains in E-Mail, Version 1",
              RFC 4408, April 2006.

12.2.  Informative References

   [ASRG-ABUSE]
              Anti-Spam Research Group (ASRG) of the Internet Research
              Task Force (IRTF), "Abuse Reporting Standards Subgroup of
              the ASRG", May 2005.

   [DKIM]     Allman, E., Callas, J., Delany, M., Libbey, M., Fenton,
              J., and M. Thomas, "DomainKeys Identified Mail (DKIM)
              Signatures", RFC 4871, May 2007.

   [DKIM-REPORTING]
              Kucherawy, M., "Reporting of DKIM Verification Failures",
              April 2010, <http://tools.ietf.org/html/
              draft-ietf-marf-dkim-reporting>.

   [EMAIL-ARCH]
              Crocker, D., "Internet Mail Architecture", RFC 5598,
              July 2009.

   [HTTP]     Fielding, R., Gettys, J., Mogul, J., Frystyk, H.,
              Masinter, L., Leach, P., and T. Berners-Lee, "Hypertext
              Transfer Protocol -- HTTP/1.1", RFC 2616, June 1999.

   [IMAP]     Crispin, M., "INTERNET MESSAGE ACCESS PROTOCOL - VERSION
              4rev1", RFC 3501, March 2003.

   [MAIL]     Resnick, P., "Internet Message Format", RFC 5322,
              October 2008.

   [MIME]     Freed, N. and N. Borenstein, "Multipurpose Internet Mail
              Extensions (MIME) Part One: Format of Internet Message
              Bodies", RFC 2045, November 1996.

   [POP]      Myers, J. and M. Rose, "Post Office Protocol - Version 3",
              STD 53, May 1996.




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   [REPORT]   Vaudreuil, G., "The Multipart/Report Content Type for the
              Reporting of Mail System Administrative Messages",
              RFC 3462, January 2003.

   [SUBMISSION]
              Gellens, R. and J. Klensin, "Message Submission for Mail",
              RFC 4409, April 2006.

   [URI]      Berners-Lee, T., Fielding, R., and L. Masinter, "Uniform
              Resource Identifier (URI): Generic Syntax", RFC 3986,
              January 2005.


Appendix A.  Public Discussion, History and Support

   [REMOVE BEFORE PUBLICATION]

   Public discussion of this proposed specification is handled via the
   marf@ietf.org mailing list.  The list is open.  Access to
   subscription forms and to list archives can be found at
   http://www.ietf.org/mail-archive/web/marf/current/maillist.html


Appendix B.  Document History & Open Issues

   [REMOVE BEFORE PUBLICATION]

B.1.  draft-jdfalk-marf-reporting-discovery-00

   o  NEEDED: WG input, references cleanup, ABNF and other formal
      definitions, and probably lots of other stuff.
   o  QUESTION: should this include IODEF as a format?

B.2.  draft-jdfalk-marf-reporting-discovery-01

   o  Removed "MARF Working Group" until the MARF WG takes up the
      document.
   o  Changed from "Experimental" to "Standards Track".
   o  Various non-normative textual & formatting improvements, most
      importantly changing "hangtext" to "hangText" because xml2rfc is
      (surprisingly) case-sensitive.
   o  Added the PTR record as another place to look for advertisements
      published by ARF consumers.  (This may require additional
      clarifications later in the text.)
   o  Moved a few references from normative to informative.
   o  Questions & needs listed for version 00 remain valid.





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B.3.  draft-jdfalk-marf-reporting-discovery-02

   o  Added authentication-related and privacy considerations sections
      written by Alessandro Vesely.
   o  Questions & needs listed for versions 00 and 01 remain valid.

B.4.  draft-jdfalk-marf-reporting-discovery-03

   o  Removed references to end-user report submissions; those should be
      left for a separate document, and probably be discoverable in the
      same way as MUA settings.
   o  Rewrote some confusing parts.
   o  Added the examples section.
   o  QUESTION: should the advertisement be published somewhere other
      than DNS?
   o  Questions & needs listed for earlier versions remain valid.
   o  QUESTION: should this document include a description of how the
      complaint feedback signup process works today, and how this
      proposal would change it?  Or is that a separate Informational
      document?
   o  QUESTION: should the current Privacy Considerations section be
      moved to a separate BCP?


Author's Address

   J.D. Falk
   Return Path
   100 Mathilda Place, Suite 100
   Sunnyvale, CA  94086
   US

   Email: ietf@cybernothing.org
   URI:   http://www.returnpath.net/

















Falk                      Expires July 17, 2011                [Page 14]