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Comments from Andrew Allemann - Domain Name Wire

  • To: irtp-draft-report@xxxxxxxxx
  • Subject: Comments from Andrew Allemann - Domain Name Wire
  • From: Andrew Allemann <editor@xxxxxxxxxxxxxxxxxx>
  • Date: Mon, 27 Apr 2009 14:44:01 -0500

1. I think the deadline for inclusion in the final report should be extended.

2. IRT did a good job anticipating some of the concerns of abuse.  I
particularly support the inclusion of letting a domain owner respond
after the 14 day period to URS.  The person may simply be on vacation
or unavailable to respond in time.  However, I recommend extending the
normal response time to 30 days for domain owners.  There could be a
mechanism to decrease this time period for domain registrants that
routinely lose cases.

3. I suspect National Arbitration Forum and WIPO will be opposed to
URS because it will kill 90% of their business.  Cases that do make it
through will be more complicated and take more time.

4. The penalty for companies that abuse URS should be stronger.  It
should kick in after two losses and last at least two years.  There
should also be a safeguard to ensure that the same people don't try to
use URS under a different entity name while on suspension.

5. Other than the need to address privacy concerns, I don't see many
problems with a thick whois requirement.

6. Because the proposed changes are likely to ultimately affect
existing TLDs too, this process should be pulled out of the new TLD
process and opened to formal debate under the traditional process at

Andrew Allemann
Domain Name Wire

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