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RE: [gnso-irtp-pdp-jun08] RE: Issue III

  • To: "'James M. Bladel'" <jbladel@xxxxxxxxxxx>, "'Mike O'Connor'" <mike@xxxxxxxxxx>
  • Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III
  • From: "Michael Collins" <michael@xxxxxxxxxxxxxxxxxxxx>
  • Date: Wed, 27 Aug 2008 14:35:29 -0400

James,

 

Agreed that a registrar could already offer a custom service to handle all of 
the tedium associated with batch transfers. However, it is within our charter 
to consider whether registrars could use a partial bulk transfer to more 
efficiently provide this type of service to customers thereby avoiding 
unnecessary tedium. 

 

I agree with James again that we have to be careful to distinguish between 
policy development and product development and embrace his theme of diversity. 
There is probably limited customer demand for bulk transfers. Given the choice, 
most registrars will not offer such a service to customers. We probably do not 
want to force a policy on registrars that requires them to implement a bulk 
transfer service to registrants, but we could try to accommodate registrars 
that tend to specialize in services to customers with many domains. These 
registrars might choose to offer a bulk transfer service to their customers. If 
we are going to consider a policy allowing partial bulk transfers, instead of 
arbitrarily limiting the reasons for partial bulk transfers (i.e. the NeuLevel 
registry service), we should consider how to further enable niche or boutique 
registrars to be innovative and develop new offerings to registrants. It is 
especially true during the research/inquiry phase of our work that we should be 
open to discussions of new services to registrants that registrars might choose 
to offer.

 

I do not know of a reason to change the fee structure for partial bulk 
transfers as compared to existing fee structure for bulk transfers, but am open 
to discussions of more appropriate fees. I havenât been on enough workgroups 
to know, are we able to consider fees; is that in our charter? Even if 
registrars are not charged a fee for a partial bulk transfer as is the case 
today with some bulk transfers, a registrar is not required to offer the 
service to its customers for free. The marketplace can determine the demand for 
the service and the price that customers are willing to pay.

 

Best regards,

Michael Collins

 <http://www.internetcommerce.org/> Internet Commerce Association

+1. 202 657 4570

+1. 407 242 9009 mobile

 

From: owner-gnso-irtp-pdp-jun08@xxxxxxxxx 
[mailto:owner-gnso-irtp-pdp-jun08@xxxxxxxxx] On Behalf Of James M. Bladel
Sent: Wednesday, August 27, 2008 11:50 AM
To: Mike O'Connor
Cc: Gnso-irtp-pdp-jun08@xxxxxxxxx
Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III

 

Mike and Group:

To my knowledge, there is nothing in the existing policy that would  _prevent_  
the registrant-initiated transfer you have described.  

For instance, a (hypothetical?) registrar (or non-registrar entity) could 
tailor a service program to act as an agent/proxy on your behalf, and handle 
all of the tedium associated with the "batch" transfer in your first paragraph. 
 And, since some registries (Barbara can help here...?) offer a pro-rated 
monthly renewal rate, they could also develop a "synchronization service" to 
purchase monthly registrations until all domains reached a preferred renewal 
date.

Aside from a few large, full-service shops, registrars come in all shapes and 
sizes and have targeted service offerings to a variety of market segments.  The 
existing environment encourages niche or boutique registrars to be innovative 
and develop new offerings, and I think the industry as a whole benefits from 
registrar diversity.  If there are no registrars that satisfactorily offer a 
desired service, then that should be thought of as an identified business 
opportunity, rather than a call for policy.

In my opinion, we need to be cautious about anything that might blur the 
boundaries between Policy development and Product development.  Ideas that are 
written into ICANN policy will become SOP for all registrars, regardless of 
scale, market, or business model considerations.  This will restrict the 
boundaries of innovation, and over time move towards a commoditized and 
homogeneous registrar environment.

J.






-------- Original Message --------
Subject: Re: [gnso-irtp-pdp-jun08] RE: Issue III
From: "Mike O'Connor" <mike@xxxxxxxxxx>
Date: Wed, August 27, 2008 10:16 am
To: "Trachtenberg, Marc H." <MTrachtenberg@xxxxxxxxxxx>, "'Glen
de Saint GÃry'" <Glen@xxxxxxxxx>, 
"Gnso-irtp-pdp-jun08@xxxxxxxxx" <Gnso-irtp-pdp-jun08@xxxxxxxxx>


Yep, I agree. My position on transfers is that 
I'd like a way for registrants to 
consistently/securely move a group of names from 
one registrar to another in a group, rather than 
one at a time (which is an inconvenience that 
losing registrars sometimes use as a barrier to 
losing domains). Here are places where I see some wiggle room;

- I agree that it's not fair that registrants get 
to do this "for free" -- if there's a way to 
impose a fair fee structure, I'd support it.

- One of the problems that crops up for 
registrants is that renewal dates are scattered 
across the year -- it would be nifty if there was 
some way to some kind of pro-rated refund of 
registration-fees from the losing registrar. I 
know, a logistical nightmare, but a fella can 
dream. And maybe this could be implemented over 
some period of time to limit impact on registrar operations.

- A hybrid approach to this could be to provide a 
mechanism whereby a registrant could "queue up" a 
group of domains for an automated transfer at renewal time.

- At any rate, it may be that I'm trying to 
shoehorn too much into "partial bulk 
transfers". Might it make sense to set up *two* 
kinds of partial bulk transfers, one for 
registrar-initiated ones and another for 
registrant-initiated ones? That way we could 
fashion the rules to match the circumstances better.

mikey

At 11:51 AM 8/26/2008, Trachtenberg, Marc H. wrote:
>I think first we need to define "partial-bulk 
>transfer." In other words, do we mean only 
>registrar-initiated transfers? How many domain 
>names are the minimum for a "partial-bulk 
>transfer"? Are these transfers that are not treated as renewals?
>
>
>Marc H. Trachtenberg
>
>Winston & Strawn LLP
>35 West Wacker Drive
>Chicago, IL 60601-9703
>T: +1 (312) 558-7964
>F: +1 (312) 558-5700
>C: +1 (773) 677-3305
>
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>| <mailto:MTrachtenberg@xxxxxxxxxxx 
><https://email.secureserver.net/pcompose.php#Compose> >email | www.winston.com
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>
>----------
>From: owner-gnso-irtp-pdp-jun08@xxxxxxxxx 
>[mailto:owner-gnso-irtp-pdp-jun08@xxxxxxxxx 
><https://email.secureserver.net/pcompose.php#Compose> ] On Behalf Of Glen de 
>Saint GÃry
>Sent: Tuesday, August 26, 2008 11:07 AM
>To: Gnso-irtp-pdp-jun08@xxxxxxxxx
>Subject: [gnso-irtp-pdp-jun08] Issue III
>
>
>Since we are in an information gathering phase 
>of our work, we should leave the use cases open 
>for public comment. If we decide to recommend 
>partial bulk transfers, we could do so without 
>the restrictions imposed by the NueLevel 
>Registry Service (âby means of a stock or asset 
>purchase, merger or similar transactionâ). This 
>would permit registrars to make their own 
>business decisions about whether to offer 
>partial bulk transfers to their customers 
>(registrants). However, voluntary bulk transfers 
>may not be the answer for registrants because it 
>requires the cooperation of the losing and 
>gaining registrar and I do not anticipate that 
>losing registrars will be easily motivated to 
>participate. In the information gathering phase, 
>can we open for discussion, partial bulk 
>transfers that do not require losing registrar 
>cooperation? This would be a great help for 
>owners of domain portfolios (registrants) 
>especially those who frequently acquire domains 
>by purchasing portfolios or business acquisition.
>
>Completely separate from the bulk transfers 
>issue, the collective primary purpose of all of 
>the inter-registrar PDPs is to make registrar 
>transfers easier and more dependable for 
>registrants without sacrificing security. There 
>are many complaints by registrants that some 
>registrars make it tedious and difficult to 
>transfer out. It may be outside the scope of 
>this workgroup, but another work group (C) will 
>soon deal with unlocking domains. This issue 
>should be expanded to easily obtained 
>authorization codes because unlocking domains 
>and providing auth codes are two required tasks 
>for inter-registrar transfers that losing 
>registrars can use to make transfers extremely tedious.
>
>Best regards,
>Michael Collins
><http://www.internetcommerce.org/>Internet Commerce Association
>+1. 202 657 4570
>
>
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