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Re: [gnso-pednr-dt] Additional proposed recommendations
- To: "Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxx>, PEDNR <gnso-pednr-dt@xxxxxxxxx>
- Subject: Re: [gnso-pednr-dt] Additional proposed recommendations
- From: Alan Greenberg <alan.greenberg@xxxxxxxxx>
- Date: Fri, 12 Nov 2010 12:11:07 -0500
Michele, perhaps this is a new direction in
policy, although I suspect there are other
examples if we look for them. Regardless, the
concept of "exceptions" was to address the
regular comments from registrars that
"one-size-fits-all" solutions will generate real
operational and business problems.
As a simple example, consider the case of the
Brazilian registrar that didn't want to
darken/redirect traffic soon after expiration. He
said they would ultimately do that if other means
of waking up the registrant did not work, but
first they wanted to be able to take those other
means. So we are certainly not going to mandate
by policy that you every registrar smakes phone
calls or sends registered letters to alert the
registrant, but if someone wants to do that
instead of darkening/redirecting the domain, the
exception process will allow them to do that. It
would not give them an exception from the intent
of the policy, but from the particular
implementation prescribed as the default. A
completely impractical and unwieldy alternative
would be for the policy to list 10 (or whatever)
different method of achieving the end. But no one
wants to do that, nor would it be effective.
Alan
At 12/11/2010 08:50 AM, Michele Neylon :: Blacknight wrote:
Alan
Your email confused me
Either you are advocating a policy change or you aren't.
The "exceptions allowed" concept seems to break that badly
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
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.
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)
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
On 9 Nov 2010, at 15:34, Alan Greenberg wrote:
>
> 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).
>
> These recommendations are all in line with
the non-registrar WG survey results and also
with the outcomes of the user survey.
>
> 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.
>
> Consensus Policies - Registrars
>
> = 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.
I'm not sure that's factually correct
If it is please provide links to tangible data
> 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.>
>
> = 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.>
Rejected.
Either everyone does it or nobody does it.
You can't expect it to be a policy for some and not for others
>
> = 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]
>
> = At least one notification must be sent
to the registrant after expiration. {The timing
to be specified.} [Exceptions allowed]
>
> = 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.
We have no way of knowing this until we send the
notification and we probably can't really do anything about it anyway ..
>
> = 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).
Redundant. You already specified that notifications be "sent"
>
> = 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.
Disagree
The key thing is that we send them in a "sane"
manner. Forcing us to specify exactly how could have secondary consequences
>
> = 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.>
>
> = All non-web services must cease to
function within 3-5 days after expiration. [Exceptions allowed]
>
> = 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.
>
> = 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
That is not practically possible.
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
Unless of course you want us all to start
charging say $10k / year for a .com ?
> and when pre-and post-expiration renewal
notices are provided. <Rationale: This is
comparable to the current requirement regarding RGP redemption pricing.>
No it isn't
>
> = 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.>
While I'd personally love to see this at some
point, it's probably best left to a more comprehensive review of WHOIS.
I can't see this being supported by registries or registrars
>
> = 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]
Again with the exceptions
Either we all have to do something or we don't
The alternative is that you admit that we're all
adults and are capable of adopting "best practices" ..
>
> = All Registrars must offer the RGP for
gTLDs where the Registry offers it.
>
> = 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.
We already are under the 2009 RAA
>
>
> Registrar Exceptions
>
> 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.
No.
>
>
> Consensus Policy - Registries
>
> = 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).
>
> = Modify WHOIS to clearly indicate
whether a domain has been renewed from a
registrant:registrar point of view. <With caveat as noted above.>
>
>
> Registrar Best Practices
>
> This could perhaps be implemented in one of two ways.
>
> a. The Registrar community can develop these
Best Practices including some methodology which
will give registrars an incentive to implement them if applicable. or
Why would we give ourselves incentives?
Sorry - I don't follow that
>
> b. ICANN can develop these Best Practices and
provide a financial incentive to registrars who follow them.
>
> These are not meant to be verbatim Best
Practices but will serve as a basis for their full development.
>
> = Issue a warning if contact addresses
use the domain being registered / renewed / updated.
Technically difficult if not impossible to implement
>
> = Expiration-related provisions of
registration agreement clear and understandable
by a non-lawyer, non-domain-professional.
>
> = 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.
And if they don't acknowledge it what then?
>
> = Request at least two different modes of
contact information (example: e-mail and SMS)
with explanation why two are needed.
Technically problematic and impossible to
implement across all registrars and other channels
>
>
> Other issues to consider:
>
> = Renaming the Autorenew Grace Period to
make it clear that it is not the Automatic
Renewal option offered by some Registrars to registrants.
>
>
Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Brand Protection
ICANN Accredited Registrar
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