PIR Application for Approval of Excess Delete Fee and Response to Letter from the INTA

[Edward G. Viltz <eviltz@xxxxxxx>]

> > From: Edward G. Viltz [mailto:eviltz@xxxxxxx]
> > Sent: Tuesday, November 21, 2006 5:11 PM
> > To: Vint Cerf; paul.twomey@xxxxxxxxx
> > Cc: John Jeffrey; PIR Board; David W. Maher
> > Subject: PIR Application for Approval of Excess Delete Fee and  
> > Response to Letter from the INTA
> >
> > Vint Cerf, Chairman
> >
> > Paul Twomey, President and CEO
> >
> > ICANN
> >
> > 4676 Admiralty Way, Suite 330
> >
> > Marina del Rey, CA 90292
> >
> >
> >
> > re: PIR Application for approval of Excess Deletion Fee
> >
> >
> >
> > Gentlemen:
> >
> >
> >
> > In the interest of time, this letter is being sent via email.   
> > Public Interest Registry (PIR) is writing in response to a letter  
> > of November 16, 2006 addressed to you by the International  
> > Trademark Association (INTA)http://www.icann.org/correspondence/ 
> > reidl-to-icann-16nov06.pdf. PIR has a pending application before  
> > the Board of Directors of ICANN to amend its Registry Agreement to  
> > provide for an “excess deletions fee” on certain .ORG domain names  
> > deleted during the 5-day add-grace period (the “Proposal”). The  
> > INTA letter mischaracterizes this as a proposal to amend the  
> > “Registrar Accreditation Agreement” (sic) “in order to reduce the  
> > number of instances of what has become known as ‘domain name  
> > tasting’”.
> >
> >
> >
> >             The PIR Proposal makes it abundantly clear that it is  
> > not intended to address the phenomenon known as “domain tasting”,  
> > nor is it intended to resolve all the problems that have arisen in  
> > connection with the 5-day add-grace period. PIR has not taken a  
> > position pro or con on domain tasting. Furthermore, it may well be  
> > that there are reasons to amend, improve or even abolish the 5-day  
> > add-grace period, but the PIR Proposal does not address these.
> >
> >
> >
> >             The PIR proposal is a straightforward attempt to deal  
> > with a problem that has arisen from certain abuses of the 5-day  
> > add-grace period in the experience of PIR. It is not offered to  
> > the Internet community as an endorsement of domain tasting or as a  
> > model for other registries (although PIR would have no objection  
> > to its adoption by other registries).
> >
> >
> >
> >             PIR believes that INTA is entirely free to adopt a  
> > position opposed to domain tasting, but that position should not  
> > be leveraged to interfere with the pending PIR Proposal.
> >
> >
> >
> >             PIR urges you and the Board of ICANN to approve PIR’s  
> > Proposal as currently scheduled on the agenda of the Board meeting  
> > on 22 November.
> >
> >
> >
> > Respectfully submitted,
> >
> >
> >
> > Edward G. Viltz
> >
> >
> >
> > Edward G. Viltz                  (V) +1-703-464-7005
> > President & CEO                (F)  +1-703-464-7006
> > 1775 Wiehle Ave.                Suite 102A
> > Reston, VA                         20190
> > www.pir.org
> >
> >        "Serving the Public Interest"