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Re: [gnso-pednr-dt] PEDNR: A proposed path forward

  • To: "James M. Bladel" <jbladel@xxxxxxxxxxx>, "PEDNR " <gnso-pednr-dt@xxxxxxxxx>
  • Subject: Re: [gnso-pednr-dt] PEDNR: A proposed path forward
  • From: Alan Greenberg <alan.greenberg@xxxxxxxxx>
  • Date: Tue, 2 Nov 2010 13:48:18 -0400


James, thanks for getting this going. There is some good stuff here, but as you can surely imagine, in my view it does not really go far enough. I will make a few comments below, but more will come.

Alan

At 01/11/2010 03:12 PM, James M. Bladel wrote:

Good afternoon, everyone.


With our review of community feedback complete, several of us on the WG
have been working to synthesize all the various positions and opinions
expressed on PEDNR into a compromise proposal.


The objectives of putting this forward are:

(1)  Provide additional safeguards for registrants to guard against the
inadvertent loss of registrations, secured by Consensus Policy.
(2)  Provide some consistency in the registrant's experience with
expiring names.
(3)  Accomplish (1) and (3) in a manner that does not unnecessarily
disrupt the numerous commercial and non-commercial activities in our
industry.

With these in mind, we submit the following slate of proposals for your
consideration.


Grace Period (Secured by Consensus Policy)
-------------------------------------------
Guaranteed five-day registrar grace period (what to call it will need to
be determined so as to avoid confusion with similarly named periods)
following expiration.  Only the RAE can recover/renew name during this
period.  While the name will not go to auction during this period, it
could be explicitly deleted by the Registrar, which commences the RGP.

Before registrars began the practice of transferring and auctioning domains at expiration, all registrants had a 30-75 day period within which to recover their expired name. Typically it was 60. This WG has decided not to question the registrar right/ability to do this (which does earn a lot of money for some), but that is no reason to reduce the time that a registrant has to recover. That is where the 30 came from, since it was the absolute minimum before. And that required deleting the name on day 1 of expiration, a practice that few registrars had.

So, my question to counter Jeff's is not why more time, but rather why is it that registrars feel that REDUCING the amount of time by a factor of 6 to 15 times is reasonable.

I do appreciate that this proposal says that registrars will delay beginning auctions until the period has expired. It is a nice idea. But this is not really of importance from the point of view of our charter, which is considering whether the name is recoverable. Some registrars have a practice of starting auctions very early, but the terms are t hat if a RAE comes in and says they want it back, the auction/sale is cancelled or reversed.

Renewal notices (Secured by Consensus Policy)
---------------------------------------------
Requirement to send (by a method at each registrar's discretion) a
minimum of one renewal notice to registrant no later than 10 days prior
to expiry, and a second notice the day prior to the expiry date
notifying the RAE that the 5-day registrar grace period will begin the
following day.

This is basically in line with what we have discussed before, but I would like to understand why the first notice may come so late, given the statements that have been made about monthly bill processing and the time it may take for a registrant to process a payment.

 Whois
-----
No changes to Whois recommended.

This was one of the few things that we had almost complete consensus on, so I am a bit surprised that it is now off the table. I do recognize that it is one of the few things that we have been talking about that would require a significant work effort on behalf of all registrars and registries, but I think that taking it off the table (as opposed to a long phase-in time) is premature.



Community Education
-------------------
Registrars:
Best practice recommendation: A registrar will design and host a
neutral-content site with important information about how to properly
steward a domain name and prevent unintended loss.
Registrar should provide on its web site, and send to registrant in
separate e-mail to registrant immediately following initial
registration, a set of instructions for keeping domain name records
current and for lessening the chance of mistakenly allowing the name to
expire.

No problem here.


ALAC:
Budget time/money/resources to public education campaign to encourage
renewals and prevent unwanted loss of a name.

Not sure this fits as an ALAC task (all the more so because we HAVE no money and minimal non-volunteer resources) but certainly ICANN with involvement of ALAC is reasonable.

As I said, more to come, since there are a number of issues that have been omitted completely (such as web sites going dark or redirected), but that will wait.

Alan





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