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Iranian users:
Like millions of other compatriots, I am completely opposed to the implementation of the cyberspace protection plan.  Unfortunately, this plan was approved on the morning of 05/07/1400 behind closed doors and in the absence of about 70 representatives.  Undoubtedly, if this plan is implemented, business, daily life, career path and future will affect us all.  Certainly creating restrictions is not a good way to solve problems in cyberspace.  The people of Iran today, with the advancement of science and the creation of a serious role for cyberspace in the life of every person, want free access to this space.  Please do not be passive about this.

One of the articles that raised public concern about the cyberspace protection plan was Article 11 of the plan, the number of which has been changed to 12 with almost no change in content. This article stipulates that the supply and operation of basic services in cyberspace is subject to compliance with the laws of the country, obtaining a license to operate effective services of domestic and foreign applications.

The Shhraranyvz –  part of a project entitled “Protecting the rights of cyberspace users and applications based service” that concern many people and experts over the past few weeks have recently been modified.

Although the proponents of this plan have tried to alleviate the pressure of existing criticism with the changes that have been made, the main material that has caused public concern remains strong. This concern is so serious that the Cultural Commission of the Parliament has dedicated its session yesterday and today to fully “explain the draft of the plan to protect the rights of users and basic services of cyberspace in the presence of officials and experts of the Research Center.”

Change of responsibility

One of the items of public concern was Article 11 of the draft, which has been changed to 12 with almost no change in content. This article stipulates that the supply and operation of basic services in cyberspace is subject to compliance with the laws of the country, registration in the portal of basic services and obtaining a license to operate effective services of domestic and foreign applications.

However, Note 1 remains in force, stating that “the supply and operation of effective external application services requires the introduction of a legal representative and the acceptance of the Commission’s notification obligations.”

Therefore, the question of how to establish representation by the world’s technology companies, despite sanctions and non-compliance with the FATF, still remains. However, in Note 2 of this article, the responsibility assigned to the “Information Technology Organization” is now defined in the scope of responsibilities of the “Radio Regulatory Authority”.

Delayed filtering

In the previous plan, if the basic external application services (messengers and social networks, search engines and browsers, email services, maps and routers, cloud services, etc.) did not comply with the declared conditions, they would be filtered according to Article 27 of the previous plan. However, according to Note 2 of Article 28 of this amendment, foreign basic services that have been effective before the adoption of this law at the discretion of the Commission as examples of basic services are obliged to fulfill the obligations set forth in Article 12 within 40 months after the entry into force of this law. Take action.

Otherwise, the application of paragraph “c” of this article (filtering) is not necessary for them until a suitable internal or external alternative is provided (at the discretion of the Commission) or one year after the entry into force of this law. If the obligations are not fulfilled by the basic application services within the specified time, the Ministry of Communications and Information Technology is obliged to create alternative application services for them within 80 months.

But the point of this section is that although it seems that until the release of alternative platforms based on the time specified in this note, basic application services such as Instagram will not be filtered, but right now, proponents of the project say, “We have 5 alternatives.” “One of them is Rubino with 32 million daily active users.” Therefore, it seems that the time provided in the new changes is a formality, and with the introduction of any alternative to Instagram, WhatsApp or even Google search, these services can be completely filtered immediately after 40 months from the approval of this plan. In addition, the one-year restriction mentioned in this note has established the filtering of foreign platforms after one year from the approval of this plan.

This comment does not mention how businesses can convince their foreign customers to use Iranian platforms if alternatives and filtering are provided, such as Instagram, and who is responsible for their losses through extensive filtering.

Delete the title of smuggled goods

In the previous plan, there were articles (Article 23) according to which the import of electronic and intelligent equipment that had installed unlicensed external basic services by default or could not install the default effective licensed domestic basic services was prohibited and subject to regulations. Trafficking in permitted goods was conditionally subject to Article 13 of the Law on Combating Commodity and Currency Smuggling.

According to Article 24 of the amendment, “the Commission may increase by 35% the entry fees for intelligent electronic equipment which has installed unlicensed foreign utility services by default.” “It can also reduce these costs to the same ceiling for intelligent electronic equipment that has installed authorized basic services by default.”

This actually means an increase in the price of phones, tablets and laptops that, for example, Google (if you do not comply with Article 12) are installed by default. (Source: Hamshahri newspaper)

Organizations and businesses protest against the plan to protect the duct space

The Tehran Province Computer Guild Organization called on the president-elect to stop the plan and conduct a comprehensive review “in an expert and expedient manner.”

Addressing President-elect Ebrahim Ra’isi, members of the Nasr Organization’s board of directors acknowledged that the “Protection of Cyberspace Users’ Rights” plan would distort space for cyberspace users and businesses, and now a strange urge to pass it hastily before the government takes office. There is new.

In its letter, Nasr emphasizes that so far, widespread concerns have been expressed by “activists and sympathizers of the system, including private sector experts, government officials, members of parliament and the judiciary, and IT experts about the major flaws of the plan” and the challenges and harms ahead. Finding and hiding it has also been discussed from economic, social, cultural and political aspects; However, very few amendments have been made to the plan, which in turn have led to an “increase in ownership and the imposition of unnecessary costs on the treasury.”

In addition, the Nasr Organization has noted that some members of parliament intend to implement the plan on a trial basis in accordance with Article 85 of the Constitution, instead of presenting the plan in public (which can be easily followed by the public on the radio).

Members of the Board of Directors of Tehran Electronic Commerce Association, including the CEOs of Alibaba, Digitala, Cafe Bazaar, Divar, Balad, Aparat, Filimo, Snap and Lian, in a letter to Mohammad Baqer Qalibaf, Speaker of the Islamic Consultative Assembly, explaining the drawbacks of the “Protecting Users’ Rights” plan In cyberspace. “

Domestic businesses have published a text expressing their opposition to the plan to protect the rights of parliamentary users. This statement is in cooperation with Bazaar, Aparat, Abar Arvan, Divar, Filimo, Balad, Soton, Evand, Zarrin Pal, Targman, Teesland, Pakt, Kamwa, Piadeh, Bidberg, Comma, Alofood, Yektant, Celery, Trumpet, Cinematict, Sabavision, Tiwal, Flytio, Sazito, Alibaba, Jabama, Digiato, Badge, Official News, Ayatollah, Official, Address, Ivo, Shuttle, Namava, Padro, Quiz of Kings, ACE Monitor, Test, Iran, Spard, Shenoto, Zeitel, Simiarum, Digi Written by Shenoto, Pipping and Snap.

In letters to the Speaker and the future President, the Minister of Communications called for the reform of the plan to protect the rights of users in cyberspace, calling for the removal of the content of the Ministry of Communications.

According to the agenda of the Islamic Consultative Assembly, the plan to protect the rights of users in cyberspace was to be considered on August 25 at the request of some representatives. In fact, the deputies were to vote on whether the bill would be considered and approved in the open court of the parliament (in which case, it would be possible for the public to hear what the deputies said) or whether it would be implemented on a trial basis under Article 85 of the Constitution.

According to Article 85 of the Constitution, the Islamic Consultative Assembly can delegate the authority to review certain plans to specialized commissions, and if approved by the members of the said commission and at the discretion of the Assembly, the plan can be piloted for several years and its problems corrected. After much controversy over the review of the protection plan, officials and virtual businesses have also expressed their protests and opposition to it in recent days.

It seems that other members of parliament have also become sensitive to the announcement of numerous oppositions from people and businesses, and of course the formation of a campaign to oppose the plan to protect the rights of users. According to a picture posted on his Telegram channel by Jalil Rahimi Jahanabadi, a representative of the people of Torbat-e Jam, today the deputies voted in favor and against the way the conservation plan is being considered (in the commission or publicly). Accordingly, 14 delegates voted to review the draft in the commission and 40 delegates voted to review it in public so that they could express their views on it.

Separately, the head of the parliament’s social commission tweeted his opposition to considering a plan to protect cyberspace in the cultural commission. But Ismaili suggested that the conservation plan be considered by the Joint Social, Cultural and Judicial Commission. He wrote:

While emphasizing on the management and protection of the country’s devastated cyberspace, I propose the formation of a joint social, cultural and judicial commission for the important plan of “protection of cyberspace”. The implementation of Article 85 is not a plan of this importance and complexity, and I am against it.


Mojtaba Tavangar, a member of parliament and chairman of the parliament’s energy economics committee, also tweeted last night that the plan had nothing to do with the leadership’s demands for cyberspace and that there was no urgency in reviewing it. Tavangar wrote:

If the lot is in the servant’s letter, I will say tomorrow; This plan has nothing to do with the orders of the leadership to organize #virtual_space. It has no urgency, and the Guardian Council is likely to oppose it. I also ask my colleagues to oppose it and not fall into the trap set against the government of Mr. #Raisi.

Ehsan Khandouzi, a representative of the people of Tehran, also wrote on his Instagram account in opposition to the plan to protect cyberspace:

To reduce the risk and make the most of cyberspace capacity, there are far better smart ideas than the current House plan, which does less harm to businesses. I hope this plan will not be approved.

According to the spokesman of the parliament’s cultural commission, the criteria set out in the plan to support former users have been approved by the Supreme Council of Cyberspace, and now the parliament is seeking an executive guarantee for them:

Unfortunately, whenever there is talk of organizing cyberspace in the country, some people, knowingly or unknowingly, pay more attention to the margins and distance themselves from the essence of the issue. … Unfortunately, some people mean organizing to block, if in this plan the main focus is on organizing this space. About 14 times expert work has been done on this project. The plan is now drafted and does not focus on filtering at all. Our main focus is to organize and support local media, elites and experts in this field. On the other hand, we are looking for an executive guarantee for the existing 

Karzar link:

Sincerely, Hide Zero One

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Treadstone 71

@Treadstone71LLC Cyber intelligence, counterintelligence, Influence Operations, Cyber Operations, OSINT, Clandestine Cyber HUMINT, cyber intel and OSINT training and analysis, cyber psyops, strategic intelligence, Open-Source Intelligence collection, analytic writing, structured analytic techniques, Target Adversary Research, cyber counterintelligence, strategic intelligence analysis, estimative intelligence, forecasting intelligence, warning intelligence, threat intelligence
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