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Re: [gnso-impl-irtpc-rt] Reminder: Comments on Change of Registrant/Transfer Policy - due Thursday 12 March

  • To: Caitlin Tubergen <caitlin.tubergen@xxxxxxxxx>, "gnso-impl-irtpc-rt@xxxxxxxxx" <gnso-impl-irtpc-rt@xxxxxxxxx>
  • Subject: Re: [gnso-impl-irtpc-rt] Reminder: Comments on Change of Registrant/Transfer Policy - due Thursday 12 March
  • From: "James M. Bladel" <jbladel@xxxxxxxxxxx>
  • Date: Wed, 11 Mar 2015 19:51:25 +0000

Hi Caitlin and Team:

First, I should apologize for missing the last 2 calls.  I have had frequent 
schedule conflicts with this group, including an "off the grid" vacation last 
week.  So please accept my apologies if these edits/comments appear to be "last 

Next, I have noted a few changes to this draft (attached).  Here are the 

  *   I think we should call Section II. "Inter-Registrant Transfer (Change of 
Registrant)" to keep it consistent with Section I. "Inter-Registrar Transfer".
  *   Also, I think we should allow for non-material changes to Registrant 
information to include "equivalent" data, such as changing "Inc." to 
"Incorporated" or "Mike" to "Michael."  I welcome ideas form the group on how 
to define this (or set some boundaries).
  *   I'm still unclear whehter or not the Registrar has the right to refuse a 
Change of Registrant.  What if there is some reason that the Registrar cannot 
legally serve or enter in to an agreement with the new Registrant? For example, 
in the US we cannot serve Registrants in Cuba or North Korea.  Similarly, the 
US and several other nations have levied sanctions against individuals and 
organizations in Crimea. I would hate to see this policy used as a backdoor to 
compel Registrars to violate local law. Finally, there is the case where a 
Registrar has simply banned a particular Registrant from using their services. 
This right to refuse service should be maintained in the new policy.
  *   Speaking of the Registration Agreement, I do not see where in the Draft 
Process (Sec. II(3)) where the Registrar presents this agreement to the new 
Registrant, and obtain their explicit acceptance. This is required buy the RAA 
(Sec. 3.7.7).



From: Caitlin Tubergen 
Date: Wednesday, March 11, 2015 at 13:40
To: "gnso-impl-irtpc-rt@xxxxxxxxx<mailto:gnso-impl-irtpc-rt@xxxxxxxxx>" 
Subject: [gnso-impl-irtpc-rt] Reminder: Comments on Change of 
Registrant/Transfer Policy - due Thursday 12 March

Hi All,

Please note that the deadline for the Implementation Review Team to provide 
comments on the attached draft COR policy is tomorrow, Thursday, 12 March.

If you are unable to provide feedback by that time, you are welcome to submit 
any comments during the public comment period.

Thank you.

Kind regards,


[mailto:owner-gnso-impl-irtpc-rt@xxxxxxxxx] On Behalf Of Caitlin Tubergen
Sent: Thursday, March 05, 2015 10:19 PM
To: gnso-impl-irtpc-rt@xxxxxxxxx<mailto:gnso-impl-irtpc-rt@xxxxxxxxx>; Theo 
Subject: [gnso-impl-irtpc-rt] For your review: Change of Registrant/Transfer 
Policy - by Thursday 12 March

Hi All,

Thank you to everyone who participated in the call today.  For those of you who 
were unable to attend, please find a link to the recording here: 

During the call, we discussed the outstanding issue from our last call, which 
was the issue of third party privacy/proxy providers and the potential 
challenge of transmitting the change of registrant credential to the underlying 
registrant.  The members of the IRT that were on the call with okay with the 
proposed solution, which you will find in footnote 1.

The P/P issue was the last outstanding issue to discuss before we post the 
draft policy for public comment.

I have attached the draft policy for your final review.  You will note that 
this is the hybrid "Transfer Policy," which will go out for public comment.  
The Transfer Policy has two sections: the IRTP in section I, and the Change of 
Registrant in section II.  The hybrid policy was recommended by the WG. As you 
may remember, we had already worked through recommendation 2, the time limiting 
of FOAs, before we began discussing the Change of Registrant function.

If you have any final questions or comments on the draft policy, please submit 
them to me by Thursday, 12 March.

Thank you!

Kind regards,


Attachment: Transfer Policy--Bladel Edits.docx
Description: Transfer Policy--Bladel Edits.docx

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