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 Actions Need To Be Voluntary - Terms need to be defined
To: "draft-registrar-dp@xxxxxxxxx" <draft-registrar-dp@xxxxxxxxx>Subject: Actions Need To Be Voluntary - Terms need to be definedFrom: "Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxx>Date: Sat, 28 Feb 2009 17:29:34 +0000 
 Just reading over the this proposal I spotted one section that could be 
problematic:
"1.2.5. Action by a registrar that threatens or compromises the security or 
stability of the domain
name system."
It would seem more reasonable / logical that the "action" be defined as 
voluntary / knowingly. With the present wording it would be possible for an 
involuntary action to lead to this clause being invoked, which wouldn't be 
reasonable in my view 
If a registrar were to accidentally cause a security issue it shouldn't be 
subject to the same level of censure as a voluntary act
There are multiple instances where the phrase "harm to registrants" is 
mentioned, but how exactly is that defined?
"5.3. A list of all disqualified individuals and entities will be published on 
ICANN's website, with the
date and term of disqualification."
Publishing the list is a good idea, but ICANN would need to be very careful in 
the wording of the rest of the document or it could leave itself open to 
accusations of defamation should a an individual or entity be disqualified in 
questionable circumstances ie. vague concepts like "harm to registrants" need 
to be more clearly defined.
--
Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Brand Protection
http://www.blacknight.com/
http://blog.blacknight.com/
Intl. +353 (0) 59  9183072
Locall: 1850 929 929
Direct Dial: +353 (0)59 9183090
Fax. +353 (0) 1 4811 763
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,Ireland  Company No.: 370845
 
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