RE: [gnso-irtp-pdp-jun08] RE: Issue III
- To: <Gnso-irtp-pdp-jun08@xxxxxxxxx>
- Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III
- From: "Mike Rodenbaugh" <icann@xxxxxxxxxxxxxx>
- Date: Wed, 27 Aug 2008 16:32:48 -0700
Seems like the Registry and Registrar reps in this WG would like to make it
easy for registrars to transfer bulk lists of names among themselves for
their convenience, but do not want to have to offer that same convenience to
registrants who wish to bulk transfer a list of names for their convenience.
Or am I missing something?
[mailto:owner-gnso-irtp-pdp-jun08@xxxxxxxxx] On Behalf Of Steele, Barbara
Sent: Wednesday, August 27, 2008 3:35 PM
To: James M. Bladel; Mike O'Connor
Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III
I agree with James that we do need to be very cautious about blurring the
lines between policy development and product development. I also agree that
we should narrow the scope to exclude "registrant-initiated" transactions.
That is not to say that registrars would be limited in developing an
offering that would be available to their registrants to manage their
domains including the transfer of their portfolio from one registrar to
another but that process should fall outside of the IRTP.
I am hopeful that I can help to clarify how the bulk transfer process
currently works. When a registry executes a bulk transfer under the
existing policy, the registries receive approval from ICANN to use the 'bulk
transfer tool' to transfer all domains under the management of one ICANN
accredited registrar to another designated ICANN accredited registrar. When
VeriSign receives these notices, we contact both the gaining registrar and
the losing registrar to coordinate a time when we will be completing the
transfer. As discussed in our calls, a script is run that, in essence, only
changes the registrar of record for the domain names - the expiration date
is not changed nor is a registration fee assessed. I have provided the
language relating to ICANN approved transfers below for reference.
B. ICANN-Approved Transfers
Transfer of the sponsorship of all the registrations sponsored by one
Registrar as the result of (i) acquisition of that Registrar or its assets
by another Registrar, or (ii) lack of accreditation of that Registrar or
lack of its authorization with the Registry Operator, may be made according
to the following procedure:
(a) The gaining Registrar must be accredited by ICANN for the Registry TLD
and must have in effect a Registry-Registrar Agreement with Registry
Operator for the Registry TLD.
(b) ICANN must certify in writing to Registry Operator that the transfer
would promote the community interest, such as the interest in stability that
may be threatened by the actual or imminent business failure of a Registrar.
Upon satisfaction of these two conditions, Registry Operator will make the
necessary one-time changes in the Registry database for no charge, for
transfers involving 50,000 name registrations or fewer. If the transfer
involves registrations of more than 50,000 names, Registry Operator will
charge the gaining Registrar a one-time flat fee of US$ 50,000.
I would anticipate that a similar process would be followed in a 'voluntary
partial bulk transfer' request with the exception that the request would not
be received from ICANN, but instead, from one of the registrars. Therefore,
the registries would receive the request to initiate a voluntary partial
bulk transfer from a registrar and, provided all requirements are met, the
registry would execute the command to move the designated domain names from
the losing registrar to the gaining registrar (without further intervention
by the registrars and without moving the expiration dates of the domain
names forward or assessing the standard registration fee to the gaining
registrar). To the extent that the WG finds that it does make sense to
include a provision to address 'voluntary partial bulk transfer' requests
within the IRTP, the details surrounding the minimum requirements for
submission of requests would need to be addressed. Much work would need to
be done by the WG to define the requirements, fee structure, etc. In my
opinion, the requirements should be limited to those relating to registry
and registrar responsibilities. How various registrars decide to develop
products (and establish their fee structure that they would charge for the
service to their registrants), as well as market the product to their
registrants, should be left up to the individual registrars.
In response, to James' comment: "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.", I believe that he is
actually thinking of the Sync command that is already available. VeriSign
does make this command available to all of the registrars affiliated with us
but it is up to the registrar as to whether or not they make it available to
registrants. I would need to check to see if all registries offer this
service and am happy to do this but I believe that this service falls
outside of the scope of this working group.
I would recommend the following language for Issue III:
Issue III ? Whether the policy should incorporate provisions for handling
?voluntary partial bulk transfers? between registrars ? that is, transfers
involving a number of names but not the entire group of names [ REPLACE
"held by" with "under the management of"] the losing registrar.
* Should the policy incorporate provisions for handling ?voluntary
partial bulk transfers? between registrars? Please state the reasons and
use-cases for your answer.
* Are you aware of any [DELETE "voluntary"] provisions to facilitate
voluntary partial bulk transfers? If so, could you please provide further
details on those provisions (apart from those already identified in the
issues paper ? NeuLevel (.biz), Nominet (.uk)).
VeriSign Information Services
21345 Ridgetop Circle
Dulles, VA 20166
Notice to Recipient: This e-mail contains confidential, proprietary and/or
Registry Sensitive information intended solely for the recipient and, thus
may not be retransmitted, reproduced or disclosed without the prior written
consent of VeriSign Naming and Directory Services. If you have received
this e-mail message in error, please notify the sender immediately by
telephone or reply e-mail and destroy the original message without making a
copy. Thank you.
[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
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.
-------- 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 Géry'" <Glen@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.
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
<https://email.secureserver.net/pcompose.php#Compose> @winston.com>email |
<https://email.secureserver.net/pcompose.php#Compose> @icann.org] On Behalf
Of Glen de Saint Géry
>Sent: Tuesday, August 26, 2008 11:07 AM
>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 (?by means of a stock or asset
>purchase, merger or similar transaction?). 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.
><http://www.internetcommerce.org/>Internet Commerce Association
>+1. 202 657 4570
>No virus found in this incoming message.
>Checked by AVG - http://www.avg.com
>Version: 8.0.138 / Virus Database: 270.6.9/1635
>- Release Date: 8/26/2008 7:29 AM
>The contents of this message may be privileged
>and confidential. Therefore, if this message has
>been received in error, please delete it without
>reading it. Your receipt of this message is not
>intended to waive any applicable privilege.
>Please do not disseminate this message without the permission of the
>Any tax advice contained in this email was not
>intended to be used, and cannot be used, by you
>(or any other taxpayer) to avoid penalties under
>the Internal Revenue Code of 1986, as amended.