[gnso-irtp-b-jun09] Feedback on Charter Question E

[Marika Konings <marika.konings@xxxxxxxxx>]

Dear All,

As discussed during our last meeting, I checked with my colleagues from the 
Compliance and Legal Department in relation to Charter Question E and here is 
some feedback I have received:


 1.  Lack of definition of  “readily accessible and reasonable means” – what is 
reasonable will depend on registrar practices and designated security level of 
a particular domain. Hence it is difficult to set or apply a standard or 
definition to all.
 2.  Denial reason #7 – this seems superfluous as a ground for denying a 
transfer request. If a domain is in “lock status”, the registry cannot initiate 
a transfer request (so there will not be a ground for denial based on #7). As 
such, this might be best deleted as a valid reason for denial under section 3 
of the IRTP.
 3.  It would be helpful if the IRTP provides (by adding a new section) some 
clarity on when and how domains may be locked or unlocked.
 4.  It would be helpful if registrars are required to publish on their website 
their security policy (terms and conditions upon which it locks domains), which 
must be consistent with bullet point 3 above, if it becomes available. This 
will hopefully more prominent or noticeable for registrants and others (than 
“buried” in the registration agreement).
 5.  With regard to complaints received by ICANN, normally the issue was about 
problems in retrieving or obtaining “AuthoInfo Code” in a situation where the 
domain in question was in “lock status”.

If you have any questions, please let me know.

With best regards,

Marika