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Partial Bulk Inter-Registrar Transfers of .COM and .NET Domain Registrations.

  • To: vrsn-btappa-amendment@xxxxxxxxx
  • Subject: Partial Bulk Inter-Registrar Transfers of .COM and .NET Domain Registrations.
  • From: - <d.stussy@xxxxxxxxx>
  • Date: Tue, 3 Nov 2009 14:15:41 -0800 (PST)

I am totally against the entire concept, except when it must be done because a 
registrar is going out of business (or has been bought) with respect to a given 
TLD, whether voluntarily or not.  Registrars (in a distributed database model) 
and registration services should not be permitted to transfer away registration 
records willy-nilly.  Registrants generally pick and choose the registration 
services they want using such qualities as level and reputation of service as 
well as price and perhaps other add-ons (hosting, "private" registrations, 
etc.), and quality of service such as IPv6 glue (for which support varies).  
Such registrants could find their domains transferred to registrars that don't 
support the services they need (e.g. IPv6 glue), or away from registrars that 
also provide their hosting.  These registrants are likely to transfer their 
domains BACK to the losing registrar when possible.  Therefore, to permit this 
type of action makes no sense,
 especially when registrants may regularly reverse such transfers.

Should ICANN choose not to listen to my comments above, I also object to the 
notification period.  A proper study of alternative registrars cannot be 
completed by registrants in 15 days or less.  I have transferred domain 
registrations before, and the last time I performed such a study, it took me 
about 3 months.  The first half of that period was to ascertain whether each 
registrar supported what I needed at the time - IPv6 glue - as I was moving 
away from a registration service that did not support such.  The second half of 
that time was used to search for the reputation of each candidate choice.  
Reputation web sites are often not indexed by search engines - especially when 
the reputation appears bad or hostile.  Therefore, my recommendation is that 
losing registrars MUST give registrants no less than 90 days notice, and do so 
by now less than TWO means (electronic mail and a post card via the postal 
services are suggested).  I indicate two means
 because such electronic mail will obviously be in bulk and is therefore likely 
to be classified as "spam" or junk e-mail and not delivered.  Such registrars 
must also post a notice on their web sites HOME PAGE, also no less than 90 days 
before the proposed transfer, alerting users to the transfer.  Should the 
losing registrar be engaged in simultaneous or overlapping multiple 
transfers-out, they are encouraged to give their registrants a choice as to 
which gaining registrar they desire.  I note another reply has suggested 6 
months in place of 90 days.  I have chosen to specify a minumum and have no 
objection to a longer period.

Remember that the registrant made a contract with the losing registrar and may 
have no desire whatsoever to have any business relationship with the gaining 
registrar.  As such, should a transfer occur registrar-to-registrar without the 
registrant's involvement, such a registrant should be permitted to transfer 
away from the gaining registrar to a registrar of his choice WITHOUT having to 
wait for the 60-day clock following a transfer to expire.  That is, the 60-day 
transfer lock should apply ONLY to registrant-initiated transfers.

Other replies have addressed the problem of transferring registrations which 
will shortly expire or expire before the transfer is complete.  Should renewal 
be attempted, the losing registrar (who holds the registration at the time of 
renewal) must notify the registrant of the transfer out BEFORE such renewal is 
accepted and processed.  The rule preventing transfer of registrations about to 
expire (60 days or less) should be suspended for registrations that would 
otherwise be transferred pursuant to this procedure.

There is also the issue of sharing billing information (credit/debit card 
information).  Sensitive billing information MUST NOT be transferred.  We 
already have much identity theft and credit card fraud on the Internet; don't 
compound the problem by releasing the registrant's information to a party he 
never authorized to bill him.  Such disclosures may even be illegal in some 

Technical correction:  "Gaining registrar must make a request for BTAPPA from 
VeriSign within one calendar year of the closing date of the acquisition."  
Technically, one day is "within one year."  Maybe this should be "no less than 
one year before"?

Although I have addressed some of the compnents of this transfer agreement, I 
am still against the concept as a whole, except when a registrar is going out 
of business or is disaccredited, etc.

- D. Stussy.
  Los Angeles, CA, USA

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