ISPCP -- Comments supporting the preliminary issue report on Uniformity of Contracts

["Mike O'Connor" <mike@xxxxxxxxxx>]

To whom it may concern,

The ISPCP supports the findings in this issue report and encourages the GNSO 
Council to proceed with a PDP to better understand the value of uniform 
provisions to address registration abuse -- and the drawbacks that may result 
as well.  The ISPCP especially supports the idea of developing: 

- a framework of metrics to measure the extent and trends of registration abuse 
activity

- a benchmark study that can be used to understand the current state of the 
problem and which can also be used as the basis to evaluate the effectiveness 
of various registration abuse provisions and policies

- an ongoing reporting mechanism that can be used to track changes in the level 
and nature of registration abuse activity as well as continuously evaluate the 
effectiveness of changes in policy and practice

- an evaluation of the benefit that may be gained by establishing a consistent 
minimum framework of registration abuse prevention activities and provisions 
that is applicable across gTLD registries and ICANN-accredited registrars

The ISPCP wishes to thank the staff for their efforts, and encourage the GNSO 
Council to move forward with appropriate policy actions to address the 
recommendations made in this report.

Sincerely,

Mikey O'Connor (ISPCP rapporteur)  

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