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My comment on: Potential Change to Registrar Accreditation Insurance Requirement

  • To: comments-raa-insurance-15jan15@xxxxxxxxx
  • Subject: My comment on: Potential Change to Registrar Accreditation Insurance Requirement
  • From: Mark Elkins <mje@xxxxxxxxxxx>
  • Date: Wed, 04 Mar 2015 00:02:19 +0200

ICANN seeks input on the following questions:

1 - Are there valid reasons why ICANN should continue to require CGL

I hope not as to me the insurance obligation is too costly.

2 - Has any registrar or gTLD or ccTLD registry found CGL coverage
useful in running their businesses?

I'd ask - has anyone ever claimed on this type of policy with good
cause? Why not make it voluntary?

3 - Are there alternatives to CGL insurance that would provide similar
or better protections for registrants that could be instituted either as
new contractual requirements or as "best practice" recommendations?

Perhaps a general pool policy - that people contribute to according to
number of domains???

4 - If the CGL requirement is maintained, is the $500,000 limit
Nope - way too high.

5 - If ICANN eliminates the CGL requirement, should the elimination
apply to all registrars or should "waivers" be granted only on a
case-by-case basis?

Either - as long as I'm part of the case-by-case waiver group.


My name is Mark Elkins. I have attended some ICANN Meetings (presented
papers) and a number of staff would know me. I'm also a Board member of
AfriNIC and involved with the local ccTLD registry system in South
Africa. I am involved with the Local and African internet industry, give
talks/presentations, teach DNS - etc.

My primary business is my ISP business where I also do a fair amount of
Hosting services - including Domains. I already register domains via EPP
with the "co.za" system, Central-NIC and a few other African ccTLD's. I
also have domains in the 'generic' space (com/net - etc).

ie - people believe technically competent.

To buy insurance for US$500,000 that covers all territories (inc USA,
Canada and Australia) will cost me around R100,000 (US$10,000) per year.
That is a deal breaker.

If you would like more than the 8 or so ICANN Accredited Registrars in
Africa - there needs to be a change.

In Africa - there are probably about 1.2 million "local" (ie ccTLD)
domains - we have a million of those in South Africa. I've no idea how
many non ccTLD domains there are in Africa - probably less than
400,000 ??? (Please correct me). I don't think there are enough
non-ccTLD domains to justify having more than 10 Registrars?

If the insurance cost was proportional to the number of gTLD domains -
perhaps something like US$1 per domain - then the picture would I
believe change.

I'd love to become an ICANN accredited Registrar.

I use OpenSRS/TuCows and they still don't support DNSSEC!!!
I've been running DNSSEC for about five years..

Mark James ELKINS  -  Posix Systems - (South) Africa
mje@xxxxxxxxxxx       Tel: +27.128070590  Cell: +27.826010496
For fast, reliable, low cost Internet in ZA: https://ftth.posix.co.za

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