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Google Australia Level 18, Tower 1 Darling Park 201 Sussex Street Sydney NSW 2000

Tel: 02 9374-4000 Fax: 02 9374-4001 www.google.com.au

Google submits that the Declaration should not be so prescriptive that an unintended breach of a ‘procedural’ requirement of the Declaration would result in a CSP breaching a designated content/hosting service provider rule even in circumstances where the CSP’s access control system had effectively prevented children from accessing offending material.

Google is appreciative of the opportunity to submit these detailed comments to ACMA’s draft RAS Declaration. Google’s conclusions are summarized in the Executive Summary earlier in this submission.

Google would be pleased to discuss any aspect of this submission with ACMA or to provide any further information that may assist ACMA in its deliberations. If I can assist you in any way, please contact me on carolyndalton@google.com or telephones (02) 9374 4482 or 0402 791 031.

Yours sincerely

Carolyn Dalton Senior Policy Counsel, Australia and New Zealand Google

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