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  • To: comments-proposed-raa-07mar13@xxxxxxxxx
  • Subject:
  • From: Benjamin Kerensa <bkerensa@xxxxxxxxxx>
  • Date: Wed, 13 Mar 2013 13:57:34 -0700

ICANN and Registrar Negotiating Team,

I think the "Proposed 2013 Registrar Accreditation Agreement (RAA)"
does not go far enough in a number of aspects which I outline below:

WHOIS Accuracy

I do not feel the RAA does enough to ensure that registrars are
enforcing ICANN WHOIS policy and in fact it has been my experience
over the years that registrars often are unfamiliar with the WHOIS
compliance process and that complaints via Internic very rarely bring
a domain name into compliance.

I think language should be added to the RAA WHOIS Accuracy portion
that requires all registrars to list a point of contact at their
company who can handle WHOIS compliance issues and further their
should be some automated form at every registrar site to allow receipt
of complaints in addition to the already existing Internic tool.

Registrars Seizing/Selling WHOIS Non-Compliant Domain Names

I think the RAA needs language to ensure that when a individual files
a WHOIS complaint and the registrar takes action that they not seize
the domain from the original registrant and then re-sell it for their
own profit. I think it needs to be clear that registrars need to
delete domains whenever they fail to be brought into compliance by the
registrant. Just a few months back I had a complaint in with GoDaddy
on a domain name which they redirected and eventually seized from the
registrant and then put up for auction instead of putting it into
pendingDelete state.


Benjamin Kerensa
"I am what I am because of who we all are" - Ubuntu

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