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

["Steele, Barbara" <BSteele@xxxxxxxxxxxx>]

Mike and James,
I agree with James that there is nothing to preclude a registrar from offering 
bulk transfer services to their registrants today.  I also agree that the 
policy should not require all registrars to offer this type of service.  From a 
registry perspective, the capability already exists to be able to bulk transfer 
domain names.  I think that we will all have a better idea of whether or not 
the IRTP should specifically include provisions relating to partial bulk 
transfers once we have the feedback gained from the various constituency 
statements.
 
 
-------------------------------------------------------
Barbara Steele
Compliance Officer
VeriSign Information Services
bsteele@xxxxxxxxxxxx <blocked::mailto:bsteele@xxxxxxxxxxxx> 
Direct: 703.948.3343
Mobile: 703.622.1071
Fax:  703.421.4873
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.

 

________________________________

From: owner-gnso-irtp-pdp-jun08@xxxxxxxxx 
[mailto:owner-gnso-irtp-pdp-jun08@xxxxxxxxx] On Behalf Of Mike Rodenbaugh
Sent: Thursday, August 28, 2008 1:37 AM
To: 'James M. Bladel'; 'IRTP-A '
Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III


James,
 
I do not think we need or ought to compel all registrars to offer identical 
services.  But there should be a baseline service level, so that large 
portfolio owners do not have to transfer one domain at a time, but instead have 
access to the same bulk transfer tools and efficiencies as registrars would 
afford themselves.  Some registrars have taken advantage of the IRTP in this 
fashion to make it difficult to transfer names away, and yet the IRTP is 
supposed to make it as easy as possible for registrants to transfer their 
domains securely and at will.
 
Thanks,
MIke

________________________________

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 5:05 PM
To: IRTP-A 
Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III


Mike:

I can see how one might arrive at that conclusion, but remember that Go Daddy 
(and probably others) are already offering effective bulk transfer services to 
their customers now, under the existing IRTP.  

This then becomes a question of creating or modifying policy to compel all 
registrars to offer identical services, regardless of the degree of fit with 
their individual business models. I'll defer the registry portion of your 
question to Barbara...

Thanks--

J.




        -------- Original Message --------
        Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III
        From: "Mike Rodenbaugh" <icann@xxxxxxxxxxxxxx>
        Date: Wed, August 27, 2008 6:32 pm
        To: <Gnso-irtp-pdp-jun08@xxxxxxxxx>
        
        
        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?
         
        Thanks,
        Mike

________________________________

        From: owner-gnso-irtp-pdp-jun08@xxxxxxxxx 
[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
        Cc: Gnso-irtp-pdp-jun08@xxxxxxxxx
        Subject: RE: [gnso-irtp-pdp-jun08] RE: Issue III
        
        
        All,
        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)). 

         
         
        -------------------------------------------------------
        Barbara Steele
        Compliance Officer
        VeriSign Information Services
        bsteele@xxxxxxxxxxxx <blocked::mailto:bsteele@xxxxxxxxxxxx> 
        Direct: 703.948.3343
        Mobile: 703.622.1071
        Fax:  703.421.4873
        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.

         

________________________________

        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 Géry'" <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
                >
                
><http://www.winston.com/index.cfm?contentID=24&itemID=15281>bio 
                >| 
                ><http://www.winston.com/sitefiles/wsvcard/15281.vcf>vcard 
                >| <mailto:MTrachtenberg@xxxxxxxxxxx 
<https://email.secureserver.net/pcompose.php#Compose> >email | www.winston.com
                >
                >
                >[]
                >
                >
                >
                >
                >
                >
                >
                >
                >----------
                >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 Géry
                >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 (...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.
                >
                >Best regards,
                >Michael Collins
                ><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 author.
                
>******************************************************************************
                >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.
                >