Learning from the RegisterFly nightmare...

["Mike Brown - Triangle Multimedia Ltd" <mike@xxxxxxxxxxxxxxxxxxxxxx>]

Hi there,

Wishing to add to public comments on your performance this year!

I'm going to try and put this very complex issue into the simplest of terms.

Following the RegisterFly debacle, ICANN needs to do 3 things...

1. Review the accreditation process - to ensure that any old cowboy can't
become accredited by acquiring the business and assets of an existing
Registrar. Accreditation agreements should be non-transerable unless the
organisation acquiring the accreditation is subject to the normal
accreditation process in their own right.

2. Make the registrant God - obtain agreement from the Registries that they
will make provision to allow Registrant's to transfer / renew / manage
domain names directly should they have a dispute with their Registrar. Much
can be learnt from the UK's system run by Nominet. In this system, the
Registrant can transfer the name to a chosen TAG holder (equivelant of a
Registrar) on demand, by submitting a request directly to Nominet.

3. Implement spot checks on Registrars to ensure they are complying with all
aspects of their accreditation agreement. If they're not in compliance, they
should either receive financial penalties or be forced to bulk transfer
domains to a 3rd party Registrar.

It's incredible to think that when formulating the structure, management and
policing of the domain name system, nobody had the foresight to put
Registrants interests at the very heart of it.

Whilst ICANN claims it can't be responsible for the actions of a rogue
Registrant, the very fact they don't have procedures to protect the
stability of the domain name system in these circumstances is in itself
negligent. The claim of negligence is not about what ICANN is doing to
remedy the situation (I think it's doing what it can). It's really about not
ensuring it couldn't happen in the first place.

It's a bit like someone punching you in the face and then defending
themselves by taking you to hospital.

$Billions of business depend on this highly unstable system that is open to
abuse and fraud on a massive scale. ICANN need to take a reality check and
realise that several Registrars (not just RF) are abusing the system that
ICANN (and others) introduced to protect Registrants.

The solutions are easy. So, come on ICANN, go to court and the US government
and get granted some serious muscle!


Mike Brown
Triangle Multimedia Ltd

1a Whip-Ma-Whop-Ma-Gate, The Shambles, York. YO1 8BL
Direct Tel : +44 1904 610783

www.trianglemultimedia.com