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[gnso-irtpc] Comments on the post-transfer 60-day lock

  • To: IRTPC Working Group <gnso-irtpc@xxxxxxxxx>
  • Subject: [gnso-irtpc] Comments on the post-transfer 60-day lock
  • From: "Mike O'Connor" <mike@xxxxxxxxxx>
  • Date: Tue, 22 May 2012 13:58:47 -0500

hi all,

as noted on the call, the first-draft of the Change of Registrant process has, 
as its concluding step, the requirement that the "registrar places a lock on 
the domain to prevent Inter-Registrar Transfers of the domain for 60 days."

here's an explanation and a rationale;

an underlying premise of the proposed Change of Registrant process is that it 
takes place within a single registrar.  let's take a look at some use-cases;

Case 1 -- the highest number of changes will most likely be updating the 
information about the controlling entity rather than actually changing control, 
so both "sides" of the transaction will be the same entity and thus there is no 
need for a change of registrar.  or if there is, there certainly won't be a 
need for *two* changes of registrar within 60 days of each other.  Impact is 

Case 2 -- the next most common case will be the transfer of control where the 
Gaining Registrant is a "typical" registrant -- i.e. people or corporations who 
want to use the names they acquire in the course of their day-to-day affairs.  
again, if there's a need to change registrars it will only happen once and the 
proposed lock will cause no problem as long as they do the Inter Registrar 
Transfer first, and then the Change of Registrant.  Impact is zero.

Case 3 -- the next most common case is the one where domain-investors make 
several Change of Control (buy/sell) transactions in short period of time -- 
"flipping" the domains.  Note that this proposal anticipates *unlimited* Change 
of Registrant transactions in a given time period -- as long as they stay 
within the same registrar (who can presumably resolve any fraudulent or 
disputed transfers directly).  So a high-volume, high-frequency domain-trader 
will face no constraints as long as the transactions are within a given 
registrar.  Impact is zero.

Case 4 -- the contentious use-case is the one where domain-investors (and the 
registrars that serve them) want to be able to transact Change of Registrant 
AND Inter-Registrar Transfer more frequently than 60 days.  That scenario would 
be blocked, but see below for a work-around.  Impact is moderately negative, an 
inconvenience, for the very small proportion of total registrants who wish to 
transfer a domain across two or more registrars in 60 days or less.  

Case 5 -- presumably the least-frequent case is the one in which a domain name 
is hijacked and rapidly transferred across several registrants and/or 
registrars in order to reduce the chances of successful recovery by the 
legitimate registrant and their registrar.  Impact is extremely positive, 
perhaps preventing a catastrophic and business-threatening loss, for the small 
proportion of total registrants that are victims of this kind of attack.

so in summary, 

-- there is no impact in an overwhelming majority of cases, 

-- a moderately negative ease-of-use impact on a small proportion of 
domain-investor transactions, and 

-- an extremely positive impact on an equally small number of registrants who 
avoid catastrophic harm.  

i would further propose that there are ways that cooperating Registrars could 
provide reduce the negative ease-of-use problem for their domain-investors by 
providing the appearance of rapid inter-registrar mobility for their customers 
within the language as it is proposed (by building and offering registrar-proxy 
agreements and services).  i would also propose that we are now getting down to 
a very narrow population.  we run the risk of addressing the ease-of-use needs 
of a very few, while missing the opportunity to address the security needs of 
the many (including the vast majority of domain-investors who will only need to 
change registrars once).

that's why i favor the 60 day lock provision.


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