Comment in Support of Motion by NeuStar

["Neuman, Jeff" <Jeff.Neuman@xxxxxxxxxx>]

NeuStar, Inc., the registry operator for the .BIZ top-level domain,
submits this comment in response to the proposed GNSO motion on Domain
Tasting set forth at
http://gnso.icann.org/issues/domain-tasting/dnt-motion-6mar08.shtml
("Motion").  NeuStar submits this on behalf of itself and not on behalf
of the gTLD Registries Constituency.

NeuStar is in favor of the proposed Motion.  As most of you know,
NeuStar has submitted its own proposal aimed at curbing what it
perceives as abuses of the Add-Grace Period through the Registry
Services Evaluation Process on February 5, 2008 ("NeuStar Service" found
at
http://www.icann.org/registries/rsep/biz-proposal-full-version-05feb08.p
df).  The NeuStar Service, which is essentially the same as what is
being proposed in the Motion, is currently nearing the end of its own
public comment period and NeuStar looks forward to having its service
approved by the ICANN Board by the end of this month.

NeuStar would like to make two additional points that must be kept in
mind when discussing the implementation of the Motion.  First, ICANN
must recognize that every registry is different internally, even the
ones that externally appear to operate similarly.  For example, the
registry, billing and support systems for each TLD registry, although
performing similar functions, have their own nuances.  Therefore, the
method of implementation of the Motion must provide the flexibility to
take into consideration these internal differences.  This fact is
recognized in the subtle differences between the NeuStar Service and the
service proposed by Afilias, although the substance of both proposals is
virtually the same.

The second, and more important point, is that if this Motion does become
a consensus policy, ICANN must not be allowed to implement its own
proposal for a $.20 fee (or other fee) on all domain names, even those
deleted during the AGP.  If NeuStar's Service is implemented, and/or
this Motion becomes a Consensus Policy, then domain name tasting in .biz
and the other TLDs, we believe, will be eliminated.  That being the
case, then the only names deleted during the AGP, will be those names
deleted for proper reasons, namely, to protect consumers, prevent fraud,
and the other legitimate reasons that have been expressed to date by the
ICANN registrars.  We believe charging any fee on these legitimate,
non-abusive deletions would be an unnecessary and unjustified tax on
registrants.  We strongly urge the ICANN Board to reconsider its
proposed imposition of such a tax in light of this new Motion if and
when it becomes a Consensus Policy.

Jeffrey J. Neuman, Esq. 
Sr. Director, Law, Advanced Services  & 

Business Development 

NeuStar, Inc. 
Loudoun Tech Center 
46000 Center Oak Plaza 
Sterling, VA 20166 
e-mail: Jeff.Neuman@xxxxxxxxxx <mailto:Jeff.Neuman@xxxxxxxxxx>