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PIR Application for Approval of Excess Delete Fee and Response to Letter from the INTA

  • Subject: PIR Application for Approval of Excess Delete Fee and Response to Letter from the INTA
  • From: Edward G. Viltz <eviltz@xxxxxxx>

From: Edward G. Viltz [mailto:eviltz@xxxxxxx]
Sent: Tuesday, November 21, 2006 5:11 PM
To: Vint Cerf; paul.twomey@xxxxxxxxx
Cc: John Jeffrey; PIR Board; David W. Maher
Subject: PIR Application for Approval of Excess Delete Fee and Response to Letter from the INTA

Vint Cerf, Chairman

Paul Twomey, President and CEO

ICANN

4676 Admiralty Way, Suite 330

Marina del Rey, CA 90292



re: PIR Application for approval of Excess Deletion Fee



Gentlemen:



In the interest of time, this letter is being sent via email. Public Interest Registry (PIR) is writing in response to a letter of November 16, 2006 addressed to you by the International Trademark Association (INTA)http://www.icann.org/correspondence/ reidl-to-icann-16nov06.pdf. PIR has a pending application before the Board of Directors of ICANN to amend its Registry Agreement to provide for an “excess deletions fee” on certain .ORG domain names deleted during the 5-day add-grace period (the “Proposal”). The INTA letter mischaracterizes this as a proposal to amend the “Registrar Accreditation Agreement” (sic) “in order to reduce the number of instances of what has become known as ‘domain name tasting’”.



The PIR Proposal makes it abundantly clear that it is not intended to address the phenomenon known as “domain tasting”, nor is it intended to resolve all the problems that have arisen in connection with the 5-day add-grace period. PIR has not taken a position pro or con on domain tasting. Furthermore, it may well be that there are reasons to amend, improve or even abolish the 5-day add-grace period, but the PIR Proposal does not address these.



The PIR proposal is a straightforward attempt to deal with a problem that has arisen from certain abuses of the 5-day add-grace period in the experience of PIR. It is not offered to the Internet community as an endorsement of domain tasting or as a model for other registries (although PIR would have no objection to its adoption by other registries).



PIR believes that INTA is entirely free to adopt a position opposed to domain tasting, but that position should not be leveraged to interfere with the pending PIR Proposal.



PIR urges you and the Board of ICANN to approve PIR’s Proposal as currently scheduled on the agenda of the Board meeting on 22 November.



Respectfully submitted,



Edward G. Viltz



Edward G. Viltz                  (V) +1-703-464-7005
President & CEO                (F)  +1-703-464-7006
1775 Wiehle Ave.                Suite 102A
Reston, VA                         20190
www.pir.org

       "Serving the Public Interest"







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