Re: [gnso-irtp-b-jun09] Issue E
To be clear. I do not suggest we ignore registrar initiated locks, only that they should be handled with different rules. Requiring a lock removal with 5 day notice may even conflict with other ICANN policy in some cases such as during fist 60 days of new registration. Maybe the best way to do that is to consider them in issue D. Maybe issue D is too restrictive since it only deals with registrant changes. This leaves other causes for registrar initiated lock such as UDRP notice unaddressed. Sent from my phone Michael Collins On Jul 27, 2010, at 9:16 AM, "Mike O'Connor" <mike@xxxxxxxxxx> wrote: hi all, here's a series of paragraphs to kick off the Issue E discussion. Denial Reason #7 (as currently writ)A domain name was already in "lock status" provided that the Registrar provides a readily accessible and reasonable means for the Registered Name Holder to remove the lock status.from the Initial ReportPrior to receipt of the transfer request, the domain name was locked pursuant to the Registrar’s published security policy or at the dire ction of the Registered Name Holder provided that the Registrar incl udes in its registration agreement the terms and conditions upon whi ch it locks domains and further that the Registrar provides a readil y accessible and reasonable means for the Registered Name Holder to remove the lock status. If the Registrar does not provide a means to allow a Registered Name Holder to remove the lock status themselves , then Registrar must facilitate removing the lock within 5 calendar days of receiving a request from the Registered Name Holder.unpacked version of the Initial Report language (just a few punctuation marks and carriage returns)Prior to receipt of the transfer request, the domain name was locked:-- pursuant to the Registrar’s published security policy or at the d irection of the Registered Name Holder, -- provided that the Registrar includes in its registration agreement the terms and conditions upon which it locks domains, and -- further that the Registrar provides a readily accessible and reasonable means for the Registered Name Holder to remove the lock status. If the Registrar does not provide a means to allow a Registered Name Holder to remove the lock status themselves, then Registrar must facilitate removing the lock within 5 calendar days of receiving a request from the Registered Name Holder.issues to puzzle through-- should we limit this only to locks imposed by Registered Name Holders? Michael Collins suggested this, but my recollection is that this policy is really aimed at both registrant-initiated AND registrar-initiated locks. so if we want, we can explore moving the treatment of registrar-initiated locks to Issue D, but i'll be grumpy about dropping it altogether.-- how can we address Paul's point that overly-detailed "published security policies" provide a roadmap to the criminals? my take is that this can be finessed by leaving the language as it's written -- which leaves Registrars a fair amount of latitude as to how detailed they make those published security policies.-- is the 5-day interval the right one? i don't have strong feelings about this -- but again, this might be made less complicated if we split the treatment of registrar-initiated and registrant-initiated locks.there's my first pass. have at it, peepul mikey - - - - - - - - - phone 651-647-6109 fax 866-280-2356 web http://www.haven2.comhandle OConnorStP (ID for public places like Twitter, Facebook, Google, etc.)
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