Comment

[Danny Younger <dannyyounger@xxxxxxxxx>]

With regard to Denial Reason #9, I take issue with the clause "or transfer to 
the Registrar of Record" included therein.

In the first instance, this clause is out of scope as the clarifications 
requested were only to pertain to inter-registrar transfers.

In the second place, the clause serves to validate the unacceptable practice 
known as the Registrar Direct Transfer, i.e.  "Should you
choose not to renew your domain name during any applicable grace period, you 
agree that we may, in our sole discretion, renew and transfer the domain name 
to a third party on your behalf (such a transaction is hereinafter referred to 
as a "Direct Transfer")."

Third, the clause is anticompetitive.  With this language, the following 
scenario would unfold:

1.  a registrant doesn't renew his domain name and the domain is transfered to 
the registrar of record
2.  The registrar auctions the domain to a third party
3.  The third-party is prevented from readily transferring the registration to 
another registrar because of the 60-day lock. This practice serves to keep most 
Direct Transfers at the incumbent registrar (as such impeding free competition 
for domain name registration services).