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RE: [gnso-pednr-dt] Additional proposed recommendations
- To: "Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxx>
- Subject: RE: [gnso-pednr-dt] Additional proposed recommendations
- From: "James M. Bladel" <jbladel@xxxxxxxxxxx>
- Date: Fri, 12 Nov 2010 07:06:15 -0700
<html><body><span style="font-family:Arial; color:#000000;
font-size:10pt;"><div>I'm concerned that we are allowing the Perfect to become
the enemy of the Good. </div><div><br></div><div>Many of us have the
stated goal of moving this PDP to some sort of meaningful conclusion, with
tangible outcomes to show for our work. I'm convinced that the original
proposal does this, while also providing an opportunity to
study/measure/quantify the issue further and leaving the door open to future
work.<br></div><div><br></div><div>But if we continue to bolt on new proposals,
I'm concerned that the consensus we've worked to build will evaporate, and we
will be working on this for another 12-18 months, with no assurances that the
result will be any better than what we have on the table
now.</div><div><br></div><div>Just my thoughts before the weekend.
</div><div><br></div><div>J.</div><div><br></div>
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-------- Original Message --------<br>
Subject: Re: [gnso-pednr-dt] Additional proposed recommendations<br>
From: "Michele Neylon :: Blacknight" <<a
href="mailto:michele@xxxxxxxxxxxxx";>michele@xxxxxxxxxxxxx</a>><br>
Date: Fri, November 12, 2010 7:50 am<br>
To: PEDNR <<a
href="mailto:gnso-pednr-dt@xxxxxxxxx";>gnso-pednr-dt@xxxxxxxxx</a>><br>
<br>
<br>
Alan<br>
<br>
Your email confused me<br>
<br>
Either you are advocating a policy change or you aren't.<br>
<br>
The "exceptions allowed" concept seems to break that badly<br>
<br>
With respect to the specific items you mentioned, I'm sure others will have
comments of their own, so I'll just limit myself to the ones that I have clear
reactions to<br>
<br>
To start with this entire PDP has been run on the basis of there being a
problem, however there is little or no factual evidence of there being one.<br>
<br>
Any "cases" that people seem to be able to find to point to are related to
registrants not paying for renewals (either intentionally or otherwise)<br>
<br>
In the IRTP WG, for example, we were able to work with actual data from ICANN's
compliance team who had collated a spreadsheet itemising and classifying actual
complaints submitted by the public<br>
<br>
<br>
<br>
On 9 Nov 2010, at 15:34, Alan Greenberg wrote:<br>
<br>
> <br>
> To the possible list of recommendations, I would like to add the
following. Although I have consulted with a number of people on this, and have
general support, I am submitting this on my own behalf (and clearly not wearing
the Chair hat).<br>
> <br>
> These recommendations are all in line with the non-registrar WG survey
results and also with the outcomes of the user survey.<br>
> <br>
> With one exception to be noted, based on the results of the registrar
survey we did at the start of the PDP, the recommendations should not require
significant changes in business processes or massive changes to their
procedures (at least as far as I understand). Some of these replicate (perhaps
with an added twist) what was in the proposal tabled by James. It does
introduce a new ICANN process.<br>
> <br>
> Consensus Policies - Registrars<br>
> <br>
> = Registrar must allow recovery of domain name by the registrant of
record prior to expiration (RAE) for at least a period of thirty (30) days
after expiration or until the name is deleted, whichever comes first.
<Rationale: Before the registrars started transferring and auctioning
domains at expiration, all registrants had a 30-75 day period within which to
recover. Typically it was 60.<br>
<br>
I'm not sure that's factually correct<br>
<br>
If it is please provide links to tangible data<br>
<br>
<br>
<br>
> This WG has decided not to question their right 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. Note that this version of the
guaranteed period does NOT place restrictions on Registrars about when they may
begin a sale/auction, but does restrict when they can finalize it. This is in
line with the current practices described by registrars under which I believe
all registrars surveyed gave registrants at least 30 days to recover.><br>
> <br>
> = Registrar must send at least two renewal notifications alerting the
registrant to the upcoming expiration. [Exceptions allowed - see below] <As
per James' proposal but allowing exceptions.><br>
<br>
Rejected.<br>
Either everyone does it or nobody does it.<br>
<br>
You can't expect it to be a policy for some and not for others <br>
<br>
<br>
> <br>
> = If only two renewal notifications are sent, one must be sent one month
prior to expiration (±4 days) and one must be sent one week prior to expiration
(±3 days). If more that two alert notifications are sent, the timing of two of
them must be comparable to the timings specified. [Exceptions allowed]<br>
> <br>
> = At least one notification must be sent to the registrant after
expiration. {The timing to be specified.} [Exceptions allowed]<br>
> <br>
> = If notifications are normally sent to a point of contact using the
domain in question, and delivery had been interrupted by post-expiration
actions, post-expiration notifications must be sent to some other contact point
associated with the registrant if one exists.<br>
<br>
We have no way of knowing this until we send the notification and we probably
can't really do anything about it anyway .. <br>
> <br>
> = Notifications must include "push" methods in addition to any "pull"
methods - not solely be via methods that require logging into the registrar's
system to retrieve them (ie the Registrar's Domain Management Panel).<br>
<br>
Redundant. You already specified that notifications be "sent"<br>
<br>
> <br>
> = The registration agreement and registrar web site (if one is used) must
clearly indicate what methods will be used to deliver pre- and post-expiration
notifications.<br>
<br>
Disagree<br>
The key thing is that we send them in a "sane" manner. Forcing us to specify
exactly how could have secondary consequences<br>
<br>
> <br>
> = Web site or sites reached via the domain name must not longer be
reachable through the use of the domain name within 3-5 days after expiration.
[Exceptions allowed] <Note that this and the next item alter the intent of
the Autorenew Grace Period, but it is exactly what most Registrars do today,
and there seems to be widespread belief that this is the only relatively
fail-safe method of catching the RAE's attention. The exception process will
allow Registrars with other business models and other notification methods to
carry on their businesses without change.><br>
> <br>
> = All non-web services must cease to function within 3-5 days after
expiration. [Exceptions allowed]<br>
> <br>
> = If registrar allows any web access to the domain name after the
"disable" date, the page shown must explicitly say that the domain has expired
and give instructions to the RAE on how to recover the domain.<br>
> <br>
> = The price charged for post-expiration recovery must be explicitly
stated in the registration agreement or on the Registrar's web site (if any).
This price must also be provided to the RAE at registration time<br>
<br>
That is not practically possible.<br>
<br>
If you register a domain today for 10 years there is no way that the registrar
can know what the registry is going to be charging them to renew the domain in
10 years time. It is wholly unreasonable, impractical and impossible to expect
registrars to be locked into providing pricing at day 0 that is valid at day
3650<br>
<br>
Unless of course you want us all to start charging say $10k / year for a .com
?<br>
<br>
<br>
<br>
> and when pre-and post-expiration renewal notices are provided.
<Rationale: This is comparable to the current requirement regarding RGP
redemption pricing.><br>
<br>
No it isn't<br>
<br>
> <br>
> = Modify WHOIS to clearly indicate whether a domain has been renewed from
a registrant:registrar point of view. Specifically, it should clearly identify
a domain in the Auto Renew Grace Period which has not been explicitly renewed
by the registrant <This proposal is the one that would require significant
effort on behalf of all registrars and registries. If adopted, it would require
significant phase-in time which should not impact the schedule of the other
items.><br>
<br>
While I'd personally love to see this at some point, it's probably best left to
a more comprehensive review of WHOIS.<br>
I can't see this being supported by registries or registrars <br>
<br>
> <br>
> = In the event that ICANN gives reasonable notice to Registrar that ICANN
has published web content providing educational materials with respect to
registrant responsibilities and the gTLD domain life-cycle, and such content is
developed in consultation with Registrars, Registrars who have a web presence
must point to it. [Exceptions allowed]<br>
<br>
Again with the exceptions<br>
<br>
Either we all have to do something or we don't<br>
<br>
The alternative is that you admit that we're all adults and are capable of
adopting "best practices" .. <br>
<br>
> <br>
> = All Registrars must offer the RGP for gTLDs where the Registry offers
it.<br>
<br>
> <br>
> = All RAA provisions applicable to Registrars dealing with
registrar-registrant interactions must be carried out by either the registrar
or, at their option, by a reseller. In the latter case, Registrars are still
responsible for any breaches.<br>
<br>
We already are under the 2009 RAA<br>
<br>
<br>
> <br>
> <br>
> Registrar Exceptions<br>
> <br>
> For all provisions where Exceptions are allowed, the Registrar may submit
a request to ICANN to substitute some other mechanism instead of the one(s)
specified, and must demonstrate how this alternative mechanism will provide at
least the same protection while better fitting to the Registrar's business
model or services. Such requests will be reviewed by an impartial panel
(similar to that provided with the Registry RSTEP process, or perhaps even the
same panel) and shall be acted upon in a timely manner by ICANN.<br>
<br>
No.<br>
<br>
<br>
> <br>
> <br>
> Consensus Policy - Registries<br>
> <br>
> = All unsponsored gTLD Registries shall offer the RGP. For currently
existing gTLDs that do not currently offer the RGP, a transition period shall
be allowed. All new gTLDs must offer the RGP. There could be an automatic
exemption for TLDs that do not sell domains at all (what has been referred to
in the VI group as SRSU).<br>
> <br>
> = Modify WHOIS to clearly indicate whether a domain has been renewed from
a registrant:registrar point of view. <With caveat as noted above.><br>
> <br>
> <br>
> Registrar Best Practices<br>
> <br>
> This could perhaps be implemented in one of two ways.<br>
> <br>
> a. The Registrar community can develop these Best Practices including some
methodology which will give registrars an incentive to implement them if
applicable. or<br>
<br>
Why would we give ourselves incentives?<br>
<br>
Sorry - I don't follow that<br>
<br>
> <br>
> b. ICANN can develop these Best Practices and provide a financial
incentive to registrars who follow them.<br>
> <br>
> These are not meant to be verbatim Best Practices but will serve as a
basis for their full development.<br>
> <br>
> = Issue a warning if contact addresses use the domain being registered /
renewed / updated.<br>
<br>
Technically difficult if not impossible to implement<br>
> <br>
> = Expiration-related provisions of registration agreement clear and
understandable by a non-lawyer, non-domain-professional.<br>
> <br>
> = Provide notification of impact of not having sufficient accurate
contact information at time of registration, renewal, ICANN-mandated Whois
update notice. Require positive acknowledgement if via web.<br>
<br>
And if they don't acknowledge it what then?<br>
<br>
> <br>
> = Request at least two different modes of contact information (example:
e-mail and SMS) with explanation why two are needed.<br>
<br>
Technically problematic and impossible to implement across all registrars and
other channels<br>
<br>
> <br>
> <br>
> Other issues to consider:<br>
> <br>
> = Renaming the Autorenew Grace Period to make it clear that it is not the
Automatic Renewal option offered by some Registrars to registrants.<br>
> <br>
> <br>
<br>
Mr Michele Neylon<br>
Blacknight Solutions<br>
Hosting & Colocation, Brand Protection<br>
ICANN Accredited Registrar<br>
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<br>
</div>
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