Registrar Constituency Position on Inter-Registrar Transfer Policy Initial Report
January 30, 2009
Registrar Constituency Position on Inter-Registrar Transfer Policy Initial
Report
BACKGROUND
In January 2009, the Registrar Constituency ("RC") was asked to provide
feedback regarding the Inter-Registrar Transfer Policy ("IRTP") Initial Report.
This Position Paper captures the overall sentiment expressed by the RC Members
who provided feedback about this matter. Due to time constraints, however, no
formal vote regarding this Position Paper was taken.
RC POSITION
On October 3, 2008 the RC submitted its comments to ICANN regarding the three
issues that comprise Part A of the IRTP Policy Development Process. After
reviewing the IRTP Initial Report, the RC's current views remain largely the
same as they were in October regarding issue 1 and issue 2. Regarding issue 3,
however, the RC has revised its view in light of the conclusions reached in the
IRTP Initial Report.
1. Is there a way for registrars to make Registrant E-mail Address data
available to one another?
No viable secure implementation of this proposal has been advanced that would
enable a policy to require registrars to make Registrant E-mail Address data
available to one another.
Additionally, the RC believes that regulatory intervention is not necessary to
address this issue. This issue is more appropriate for market based solutions
rather than regulatory intervention.
The RC wishes to acknowledge one comment regarding the relationship between the
Registrant and Admin Contact. According to the IRTP Initial Report, one
question that was brought up during discussion among the Working Group involves
a Registrant's authority to overrule the Admin Contact. The RC believes this
related sub-issue deserves greater consideration, and the RC plans to examine
it during subsequent phases of the IRTP Policy Development Process.
1. Whether there is need for other options for electronic authentication
(e.g., security token in the Form of Authorization (FOA)) due to security
concerns on use of email addresses (potential for hacking or spoofing).
The RC does not believe that a regulatory approach to authentication is
necessary. The RC recommends that the questions of whether additional
authentication technology is needed, and if so which technology to implement,
be decided based on market demands rather than regulation.
To that end, the RC cautions ICANN about the unintended consequences of
technology directives. Specifically, any mandated technology is guaranteed to
become the target of hackers who seek to circumvent its security. Having the
option of a variety of technologies which may be developed and implemented
based on market demands offers greater security in the long-run.
1. Whether the policy should incorporate provisions for handling "partial
bulk transfers" between registrars - that is, transfers involving a number of
names but not the entire group of names held by the losing registrar.
The RC agrees with the conclusions reached in the Working Group. There is no
need to incorporate provisions for handling partial bulk transfers between
registrars at this stage. The RC agrees with the Working Group that these
scenarios can be addressed either through the existing Bulk Transfer services
offered by some gTLD registries, or through existing market solutions.
CONCLUSION
The opinions expressed by the RC in this Position Paper should not be
interpreted to reflect the individual opinion of any particular RC member.
Attachment:
RC Position re IRTP Initial Report v1-3.pdf |