Blacknight Comments on PEDNR

["Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxx>]

Blacknight welcomes the opportunity to be able to submit some comments on the 
Post Expiry Domain Name Recovery Working Group report.

We have been actively involved in this group for a year, but feel that it is 
opportune to submit our comments to the group in this form.

The group was asked several specific questions in relation to domain expiry / 
post-expiry:

1. Whether adequate opportunity exists for registrants to redeem their expired 
domain names;

 From what we have seen - yes

2. Whether expiration-related provisions in typical registration agreements are 
clear and conspicuous enough;

The question would be better asked - are registrants aware of what can and will 
happen to their domain(s) if they don't renew them?
This is really a matter of education. Some registrars probably do a better job 
of making the information conspicuous than others, but the ICANN community as a 
whole should be taking a leadership role in helping educate registrants on how 
domains work.



3. Whether adequate notice exists to alert registrants of upcoming expirations;

Most registrars send registrants multiple notifications. In some cases 
registrants complain about the volume of these reminders, so there is more than 
adequate notice.
As a sidenote - many registrars offer an "auto renew" type option in their 
billing systems which allow registrants to automatically renew their domains as 
long as their credit card is valid.

4. Whether additional measures need to be implemented to indicate that once a 
domain name enters the Auto-Renew Grace Period, it has expired (e.g., hold 
status, a notice on the site with a link to information on how to renew, or 
other options to be determined);

As has been mentioned by several members of the group, some clear indication in 
WHOIS of a domain's current status would help avoid confusion. The exact form 
and method for implementing this is probably beyond this group's remit.

If the domain post-expiry resolves to a holding page of some kind there should 
be an indication that the domain has expired and provide details (or a link to 
them) on how to renew it. One complaint we have heard in the past is that 
registrants assume that the domain has been "hijacked"

5. Whether to allow the transfer of a domain name during the RGP

In short - no. 


However we strongly believe that the issue isn't what happens if / when a 
domain expires, but more to do with how it gets that far.

 From our experience in dealing with "normal" registrants we have seen that 
there is a significant knowledge gap problem. Many registrants do not realise 
how important their domain name is until there is an issue.
In many cases domains are registered with email addresses that have been 
abandoned, or that belong to former employees etc., 

It would make more sense, from our perspective, if time and energy were 
focussed on encouraging registrants to do more active housekeeping on their 
domain(s) prior to expiry. 

Regards

Michele


Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Brand Protection
ICANN Accredited Registrar
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