Comments on proposed final report PEDNR PDP Working group

["Pieter van Ieperen" <pieter@xxxxxxxxxxxxxx>]

Below my comments on the recommendations in the proposed final report of
the PEDNR PDP Working group.


Comment on recommendation 2:

DNS interruption for only 8 consecutive days and, on top of that, at a
random point in time after expiry, will create confusion instead of
warning to the RNHaE (now it works, now it doesn't, now it works again,
so all is OK).

If ICANN really wants to give the RNHaE fair warning of expiry, then DNS
interruption must start at expiry, continue through the whole Auto-Renew
Grace Period and the whole Redemption Grace Period, until the RNHaE
renews or restores.

DNS interruption to be defined as total internet service interruption
except for an informational web page (only one IP on which only port
80/443 active).

And why should a registrar have the right to delete a domain at any time
during the Auto-Renew Grace Period? Why not only in the last 5 days of
that period?
If a registry offers grace to a registrar, that registrar must offer
grace to the registrant, in my opinion.


Comment on recommendation 3:

If ICANN really wants to give the RNHaE the opportunity to renew or
restore after expiry, then WHOIS contact data after expiry must be the
same as before expiry, so everyone can see who has to be warned about
the expiry.


Comment on recommendation 5:

What is said here about the RGP, must also be said about the Auto-Renew
Grace Period, for example as follows:

"If a Registrar offers registrations in a gTLD that supports the
Auto-Renew Grace Period, the Registrar must allow the RNHaE to renew the
Registered Name until 5 days before the end of that period".


Comment on recommendation 6:

ICANN must maximize the fees for post-expiration renewal and post-delete
restoration, relative to the fee for pre-expiry renewal. If not,
registrars will simply continue with 3 digit USD fees or more.
And if ICANN is concerned about legal implications (price agreements
between competing registrars being illegal in many countries), they
should consider that ICANN is more than a registrar society.


Comment on recommendation 13:

See 2 and 3.


General comment:

Missing is a clear statement that during the ARGP and the RGP (and any
other time) a registrar has no right to transfer a domain name to
another registrant without explicit consent at the time of transfer from
the RNHaE. Exceptions for arbitration orders and judicial orders.

And yes, such a statement would not be good news for Godaddy Auctions,
Namejet, Snapnames, Afternic, etcetera.


Kind regards,


Pieter van Ieperen

a small scale registrant
from The Netherlands