[gnso-irtp-pdp-jun08] issue 1

["Michael Collins" <michael@xxxxxxxxxxxxxxxxxxxx>]

Hi all,

 

I would like to add the following text to issue 1 to address my concern about 
doing anything to make transfers more difficult for registrants.

 

360  Those registrars participating in the Working Group confirmed that 
normally the Gaining

361 Registrar sends the confirmation of a transfer to the admin contact since 
that is the

362 contact that they have on file. It could be considered to make it a 
requirement, instead of

363 optional, that the Registrar of Record confirms the transfer with the 
Registrant (instead of

364 the admin contact). This would add another approval into the process that 
could enable a losing registrar to delay or prevent a transfer. When combined 
with other transfer process items that a losing registrar controls and can use 
to cause difficulties and delay, registrar lock removal and auth code 
retrieval, adding a requirement for the loosing registrar to confirm the 
transfer has the potential of causing insurmountable difficulty and delay for 
registrants especially when trying to transfer a large domain name portfolio. 
However, but it would

365 resolve the problem of Registrant e-mail not being publically available and 
it would

366 resolve the problem of domain transfers being authorized by the admin 
contact without

367 the Registrant’s consent. 

 

As for as expressing a solution preference for issue one: I would strongly 
prefer that we ask ICANN to require a secure means (i.e. EPP or IRIS) for 
registrars or registries depending upon whether a registry is thick or thin to 
provide gaining registrars with the registrant email address. Gaining 
registrars should be required to send a transfer authorization request 
exclusively to the registrant and receive an affirmative response before 
initiating an inter-registrar transfer with the registry.

 

If we do not have the authority to make this request or if this is not 
technically feasible for some reason that I cannot understand, we should 
suggest a change in policy to allow both the registrant and the admin contact 
to have the authority to initiate and approve inter-registrar transfers without 
any overruling registrant authority. Thus a registrant could not dispute a 
transfer approved by admin contact.

 

Best regards,

Michael Collins

Executive Director

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

+1. 202 657 4570

+1. 407 242 9009 mobile