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