RAA Public Comment

[Confidential <scuba840@xxxxxxxxx>]

My public comment on the RAA has several points that
need to be implemented to ensure impartial, equal, and
fair access to the internet.

1) A registrar needs to be fair and impartial, and all
access to the registrar's records, computer systems,
and database needs to be impartial and equal for all
individuals seeking the registrar's service.
Currently, independent domain name speculators have
unfair and unequal special access to the registrar's
computer systems. Registrars need to offer fair and
equal access to their computer systems and databases
to all users.  Large domain name speculators have
entered into agreements with registrars to have
preferential access to their computer systems and
databases including mass domain name mass registration
capabilities, instant capture of recently expired
attractive domain names, running computer code on
registrars servers to trend data.   

2) Domain names must be instantly revocable should
they be "sold" for more than "face value". This would
effectively end large auctions and domain name
speculation. Domain name speculation has become
rampant, often providing a financial bar which is too
high for legitimate internet commerce. Rampant stories
of auctions selling domain names for 1.5 million
dollars must be immediately halted.

3) Domain name registration must be limited per entity
per time period. Example:  A reasonable internet
entity would not need to register more than 5 domain
names per day, not to exceed 30 domain registrations
per year. Domain names acquired by fraud should be
terminated along with all related domain names
acquired by that entity.

4) The free 5 day "tasting" period of domain names
needs to be curtailed, somehow. This current practice
has led to serious abuse of the process by
speculators.

5) Parked domain names shall not be allowed.  There
should be an easy and anonymous complaint process
through each register to quickly return parked domain
names back to the public.

6) Expired domain name blackmail must cease.  Many
small business owners spend years building up their
web traffic only to forget to renew their domain name.
Then a speculator will quickly buy the new name and
demand thousands of dollars to return control back to
the original owner. Like old phone numbers, an expired
registration should remain parked for a period of time
with the original owner having full rights to
repurchase it, or voluntarily relinquish it.

7) A domain name owner shall have registrar
portability within a reasonably and well-defined
amount of time.  A handover must be mandated to take
place seamlessly within 24 hours.  Currently, 
unscrupulous registrars will place the domain  name in
limbo for long periods of time.  So, an attempt to
transfer registrars will result in domain name
suicide.

8) Along with registrar portability described in # 7
above, "domain name slamming" shall be prevented by
the registrars.  An all too familiar term in the
telephone industry,  unauthorized registrar switching
must be vigorously protected against with anti fraud
measures.

9) The actual purchaser maintains ownership of domain
names, not third party registration services.  For
example,  smallbusiness.yahoo.com takes your money and
registers a domain for you, but yahoo.com retains
ownership rights to the domain name, therefore not
allowing domain name portability - forever for that
registrar. 

10) A domain name must have an individual or a
corporate contact information of the actual owner of
the domain name.  No more domain name anonymous
services.

Thank You


       
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