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

  • To: "James M. Bladel" <jbladel@xxxxxxxxxxx>
  • Subject: RE: [gnso-pednr-dt] PEDNR: A proposed path forward
  • From: Alan Greenberg <alan.greenberg@xxxxxxxxx>
  • Date: Tue, 2 Nov 2010 16:26:29 -0400

James, as mentioned on the call, I didn't read this proposal as a new period but as a replacement for the one we have been talking about. That pus it in a different light.

Regarding the 30-75, prior to the practice of transferring/auctioning names (but after the EDDP), a name would either be renewed or deleted. It could be deleted by the registrar immediately after expiration, but under EDDP, it could not be held for more than 45 days following expiration. Once deleted, it would go into RGP for 30 days. So a registrant had a total between 30 days (if the registrar deleted immediately) and 75 days (if the registrar held onto the name for the full 45 days).

Alan

At 02/11/2010 01:55 PM, James M. Bladel wrote:
Alan and Team:

I'm not clear on the "30-75 days" example given below. Currently, there is nothing in consensus policy to prevent a registrar from deleting a name -immediately- upon expiration. So offering a 5-day window backed by policy is indeed significant.

And let's keep in mind that the intention behind this proposed grace period is to allow for mis-communication, billing errors, differing holiday calendars, etc. Anything greater than 5 days and we are, in effect, requiring registrars to offer free services and disregarding the responsibilities of the Registrant. Most registrars would likely opt for immediate deletion to avoid these extra costs.

Looking forward to our call.

J.

-------- Original Message --------
Subject: Re: [gnso-pednr-dt] PEDNR: A proposed path forward
From: Alan Greenberg <<mailto:alan.greenberg@xxxxxxxxx>alan.greenberg@xxxxxxxxx>
Date: Tue, November 02, 2010 12:48 pm
To: "James M. Bladel" <<mailto:jbladel@xxxxxxxxxxx>jbladel@xxxxxxxxxxx>, "PEDNR "
<<mailto:gnso-pednr-dt@xxxxxxxxx>gnso-pednr-dt@xxxxxxxxx>

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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