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Comments on proposed Amendment for Partial Bulk Transfer in dot-COM & dot-NET

  • To: vrsn-btappa-amendment@xxxxxxxxx
  • Subject: Comments on proposed Amendment for Partial Bulk Transfer in dot-COM & dot-NET
  • From: Patrick Mevzek <contact@xxxxxxxxxxxx>
  • Date: Mon, 16 Nov 2009 04:54:47 +0100

Following the ICANN announcement at
please find below my comments related to the Verisign proposed
amendment at

I would like to make some comment not on the registrar contract
amendments but more broadly on the VeriSign request.

I think it mixes two cases that should be handled differently and

Both cases are specified on page 1 of Verisign request:
"BTAPPA will be beneficial in situations where one ICANN-accredited
registrar purchases [...] a portion [...] of another ICANN 
accredited registrar's domain name portfolio 
where a Gaining Registrar receives a request from a registrant to 
transfer a significant number of its domain names"

The second case is simple: it is a new service for end users, and it
might be useful for them, so I see no problems with that, except
maybe the fact that registrants do happen to possess domain names in
multiple TLDs and if they find that some registries do have a BTAPPA
process and others do not, it will make their life complicated. This
is a point on which I come back later.
Other than that, BTAPPA for registrants domain names seems ok.

However this is not the case of the first point, related to transfers
of registrars domain names.

Of course, it would be difficult in all cases to be 100% sure to know
if we are in a registrant portfolio transfer or a registrar one,
specifically as outsiders of the transaction, and considering the
number of registrars under some common umbrellas.
Let us imagine that we can and the following concentrates on
registrar portfolio transfers.

There seems to be almost at the same time a desire to put more
controls and verifications to registrars operations, as can be learnt
citing an email from ICANN COO pointing at some upcoming work on
"Cybersquatting: Explicitly tackle the issue of possible
cybersquatting by Registrars, suggesting that cybersquatting be
considered a violation of the RAA."

I think this would imply that there may be current problems with
registrars and their handling of their own domain names portfolio if
I understand the above correctly.

If this the case, it would seem odd to me to give them even more
tools to be able to quickly transfer domain names (through the
aforementioned BTAPPA service provided by registry) from one
registrar to another, that will make disputes procedures even more

In light of this I would say that it seems better to correctly tackle
all issues related to registrars right now, and postpone any new
service to them after the review is done, and the necessary changes
in the RAA are made. I do not believe there are some pressing
concerns that needs this new service to be available as soon as

The part of the BTAPPA that applies to registrants could be granted
right now, but the first case dealing with registrar domain names
should be postponed after the GNSO conclusions and related works on
registrars issues.

However from the drafting of Verisign request, after describing the
two cases as outlined above, the rest of the request seems to
concentrate only on the case of registrars portfolio transfer.

And for registrars portfolio transfer, delays of 15 days to alert
registrants that will be impacted by these changes are far too short. 
Considering that a normal registrar transfer could take up to 5 days,
or even a week taking into account all actors, there would barely be
enough time to try doing two of them, if some registrants would
prefer to "opt-out" from the registrars transfer. And this is not
including the fact that registrants may be on vacation and other
activities far from their computer when such request comes.
Rules for this transfer should be modeled after rules for renewal,
and not be more lax than them. 
More drastically, like for normal transfers, the BTAPPA should only
apply to domain names for which the registrant gave specific
approval, after registrar request. If the registrar does not get
authorisation from registrant/administrative contact (the same rules
as for ordinary transfers could be used), then the domain name would
be automatically excluded from the BTAPPA.

Now, I understand that the equivalent service was requested by .BIZ
in 2006 and granted, and on that basis I understand that it would be 
hard to deny the same thing to VeriSign today.

It should however prompt a deeper analysis so that this service, if
useful and carefully described, could be offered by all registries,
like by including it in all future gTLDs contracts/policies (since
there is already a Bulk Transfer policy, with slight changes it could
also handle Partial Bulk Transfers), or at renewal
time for the current ones. Of course each registry would decide if it
wants to provide it, and if so for what amounts and procedures fine
points such as delays or exclusions. But doing it that way would
profit end users with a more uniform experience as more registries
would provide the same service, and it would also simplify things as
registries would not need, one by one, to request the same thing
which would need to go again through a RSEP round.

VeriSign own request specifies that:
"Registrars have periodically approached VeriSign (as well as other
unsponsored gTLD registries) about offering BTAPPA."

The "as well as other unsponsored gTLD registries" seems to prove
that such kind of service (after review) should be by default in all 
registries contracts.

It would also help if use of this service would have some statistics,
Neulevel could provide a review of the number of times it has been
used since 2006, like monthly, with the number of domain names
involved in each case. It would also be probably useful to know if
each case is a registrant portfolio transfer or a registrar one, and
in the later case the name of both the gaining and loosing registrar.
This would permit a review of the service and its usefulness.

If such requests are to be granted in the future, including the
VeriSign one, they should incorporate requirements on reports with
numbers to monitor the use of this service. This could be added to
the already monthly registries reports to ICANN, contrary to Verisign
position on their request at page 5.

As a sidenote on RSEP globally, and not specifically for this
request, besides the table at
it would be probably useful (as requests are being more and more
frequent - 4 in 2006, 5 in 2007, 11 in 2008 and already 11 in 2009 -
and we can expect more registries arriving and more services - such
as DNSSEC, IDNs, Locks, etc. - requested by current registries)
to be able to search, through some online form and a database to
query, with fields for the registry/TLD, the service name, date of
request and of approval, documents/comments linked to it, and so on,
without having to rely on external search engines (when possible, some
PDF documents are in fact scanned images).

Patrick Mevzek
Dot and Co <http://www.dotandco.com/> <http://www.dotandco.net/>

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