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AGP comments

  • To: "agp-limits-policy@xxxxxxxxx" <agp-limits-policy@xxxxxxxxx>
  • Subject: AGP comments
  • From: "Lipkina, Natasha (hp.com)" <natasha.lipkina@xxxxxx>
  • Date: Thu, 20 Nov 2008 23:25:52 +0000

HP seconds attached CADNA's comments.


Although the add grace period ("AGP") was initially adopted to enable 
registrars to correct errors in the domain name application process, it is 
increasingly used by domainers to test, or "taste," the profitability of vast 
numbers of domain names.  As the GNSO Council noted in its Report to the ICANN 
Board - Recommendation for Domain Tasting, "there is a consensus that measures 
should be considered to reduce domain tasting and that the add grace period 
should not be exploited for tasting purposes."  
http://gnso.icann.org/issues/domain-tasting/domain-tasting-board-report-gnso-council-25apr08.pdf,
 at page 7.

In its Constituency Impact Statement regarding domain tasting, the Business 
Users Constituency noted that tasting is problematic for several reasons, 
including:

1.      The most active domain name tasters are concentrated within a small 
group of accredited registrars...The AGP provides domain name registrars with 
an unfair competitive advantage over all other potential registrants since they 
have the technological capability to quickly add, drop, and identify names of 
value without incurring any cost, whether on their own accounts or on behalf of 
their customers....A practice that allows for the testing and subsequent return 
of non-profitable purchases is unheard of in nearly every other marketplace.

2.      Domain tasting has led to an environment where tens of millions of 
domain names are caught up in the 5-day AGP at any given time. Because so many 
domain names are being added and dropped on a regular basis, domain name 
tasting has led to restricted choice as interested parties including individual 
registrants, small business, and corporations often find that the names they 
want are unavailable.

3.      ...[T]asters are registering names to monetize traffic via PPC 
advertising. The ...practice of domain name monetization is not illegal, 
but...the combination of tasting and monetization has created an Internet 
environment that is counterproductive to providing all users with relevant 
experiences, and conducive to rampant cybersquatting.

GNSO Final Report on Domain Tasting, http://gnso.icann.org/issues/domaintasting/
gnso-final-report-domain-tasting-04apr08.pdf, Annex 1.

According to the GNSO Final Report on Domain Tasting, the AGP Limits Policy is 
supported by the Intellectual Property Constituency, the Business Constituency, 
the Non-Commercial Users Constituency and the At Large Advisory Committee, and 
is not opposed by the ISP Constituency or the Registry Constituency.   
http://gnso.icann.org/issues/domaintasting/
gnso-final-report-domain-tasting-04apr08.pdf, page 15.


HP urges ICANN to implement the AGP Limits Policy at the earliest possible 
time, but in any event no later than March 1, 2009, the date proposed in the 
Draft AGP Limits Policy Implementation Notes.


Best regards


Natasha Lipkina
HP.com
Accessibility/Domain Naming Programs Manager
650-596-0752

Attachment: CADNA_Comments-AGP_Policy.pdf
Description: CADNA_Comments-AGP_Policy.pdf



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