Summary of Comments Received on Domain Name Exchange proposal in .NET

[Patrick Jones <patrick.jones@xxxxxxxxx>]

Summary of Comments received on VeriSign Proposal # 201004, Domain Name 
Exchange in .NET

Between 5 April and 20 April 2010, ICANN received three comments to the 
registryservice@xxxxxxxxx comment forum on a proposal from VeriSign to offer 
the Domain Name Exchange service in .NET. The comments are archived at


 *   George Kirikos: http://forum.icann.org/lists/registryservice/msg00033.html
 *   Alan Greenberg: http://forum.icann.org/lists/registryservice/msg00034.html
 *   Marilyn Cade on behalf of the Business Constituency: 
http://forum.icann.org/lists/registryservice/msg00035.html

All three comments cautioned ICANN staff against approval of the request, or 
alternatively to provide more time to evaluate the potential impacts of the 
proposed service and provide opportunity for a formal public comment period.

Analysis

George Kirikos wrote on 5 April that the proposal is "functionally no different 
than reintroducing domain tasting, albeit with a 30-day minimum registration 
period and no refund." In addition, he noted that the proposal created a new 
loophole around the deletions policy and that ICANN should deny the proposal, 
or at a minimum open it up for a formal public comment period.

Alan Greenberg submitted his comment on 14 April in his personal capacity but 
noted that the comment was under consideration as a formal position of ALAC. He 
noted that the proposal raised potential negative impacts which could lead to a 
new form of domain tasting. He stated that "the service effectively introduces 
the concept of monthly gTLD domain registrations, a practice which does not 
seem to be forbidden by the various ICANN contracts, but regardless has not 
been the subject of any policy discussion in recent years."

Alan also asserted that the proposal did not provide explicit details on how 
and when reporting will be performed, and the service may raise issues for 
dispute resolution procedures such as the Uniform Domain Name Dispute 
Resolution Policy (UDRP) and Uniform Rapid Suspension (URS).

The Business Constituency echoed concerns from George Kirikos and Alan 
Greenberg that the proposal may reintroduce domain tasting. "The proposed 
service reasonably raises concerns that permitting applicants to register a 
dozen domain names for the price of a single domain name will invite 
speculators to game the system and use it for domain name abuse....it is also 
reasonable to ask staff to explore whether VeriSign's new service might be used 
so excessively that it would cause the same kinds of stability problems."

The Business Constituency noted that VeriSign described steps to make the 
service more transparent, but were skeptical that the proposed remedies would 
prevent domain name abuse.

Next Steps

The comments received are being considered by ICANN staff in the evaluation of 
the proposed service. Further information will be provided at 
http://www.icann.org/en/registries/rsep/#201004.

--
Patrick


--
Patrick L. Jones
Senior Manager, Continuity & Risk Management
Internet Corporation for Assigned Names & Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292
Tel: +1 310 301 3861
patrick.jones@xxxxxxxxx
patrickjones.tel