IRTP C Initial Report Feedback from Cronon AG

["Michael Shohat, Cronon AG" <mshohat@xxxxxxxxxx>]

Hi,

Regarding the recommendations and questions included in the IRTP C 
Initial report, Cronon AG submits the following input for consideration:
In general, processes should be kept as light and simple as possible, 
and registrant confirmation for domain procedures should only be 
required if absolutely necessary.
Registrars deal with many different registry policies, only some of 
which are gTLDs. Complicating procedures for gTLDs would add to the 
jungle of different policies already known from ccTLDs.
Moreover, "normal" registrants (non-domainer, non-technical end-users) 
usually don't understand registry policies and verification procedures 
and often ignore communications from registries and registrars. Ask 
EURid, nic.es and nic.at (to name just a few) which portion of their 
mails regarding trades are bounced or simply ignored. EURid is currently 
removing their confirmation requirement for trades for exactly that 
reason, and will shortly regard COR as a simple update - while ICANN is 
considering going in the opposite direction for gTLDs.
Regarding the recommendations in detail:

Recommendation #1 (adoption of change of registrant consensus policy):
Cronon supports the adoption of such a policy, however it should place 
as little technical burdens on registrars and registrants as possible. 
COR should be possible before as well as after IRTPs, and there should 
be no mutual locks, since this has been shown to confuse registrants and 
complicate registrar implementation unnecessarily.
Recommendation #2 (FOA time limit):
We support such limit and actually have one in place already. Time 
limits should be multiplications of whole months (30, 60, 90 days etc.), 
which are easier for registrants to understand and remember, as opposed 
to fractions of months (i.e. 45 days).
Recommendation #3 (enhanced pre-authorized SOA):
Our stand on this issue depends on the details to be elaborated at a 
later stage. But basically, we'd recommend to avoid exceptions to rules, 
if the rules are simple and make sense.
Recommendation #4 (Registrar's IANA ID in thick WHOIS):
Yes. There seems to be concensus on this in the WG as well.

Regarding the question "which updates constitute a change of 
ownership?", we are of the opinion that only changing the name or 
organization (any change to any part of the name) constitutes such COR. 
The legally relevant data on who owns a domain is the name of the owner. 
The primary contact (such as email) is only a means to get hold of that 
person, and should be available for simple update, since people 
frequently change their contact addresses and should be able to do so 
easily.
Kind regards,
Michael Shohat


--

Dr. Michael Shohat
Head of Registrar Services
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fax: +49 30 39802-222
email: mshohat@xxxxxxxxxx
website: www.cronon.net
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Cronon AG
Professional IT-Services
Pascalstrafle 10
D-10587 Berlin
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Chairman of Supervisory Board: René Wienholtz
Board of Directors: Christian Müller (Chairman),
Viktor Hinterleitner, Christoph Steffens
County Court: Berlin-Charlottenburg HRB 77957