RE: [del-com] Transferred from Bruce Tonkin
Thanks for getting this ball rolling. My initial comments are below.
The addition of "in the absence of extenuating circumstances" makes this not enforceable. If the registrar has spent weeks prior to expiration, and weeks following expiration trying to contact the registrant for renewal, in most cases has then put the name on hold or parked it at their website, then has the RGP of 30 days, just how much more needs to be done before a name is finally deleted? If there is a court order or something other similar situation that requires the name not be deleted, then of course that is an extenuating circumstance, but it should be the only one. A UDRP under process confers no special rights to the domain name to anyone until it is resolved, and it should stay that way.
The requirement for a registrar to submit a renew report makes this excessively complex and expensive. I see no way for this to be implemented without requiring manual intervention as we currently have with the RGP restore report. And what do these reports mean anyway? Who is going to review them, how are they going to be used in any dispute, etc.
Same comment as above regarding "in the absence of extenuating circumstances." Only a court order or similar situation should prevent this.
I see no need for the last paragraph in the suggested replacement text. The registrar should be allowed to make it clear to the registrant that policies change, and how to monitor those changes. It should NOT require the registrar to take specific action to inform the registrant beyond that. We all know the difficulty involved in reaching registrants, and we end up with a possible dispute issue that is difficult to resolve and enforce.
3.2.1 through 3.2.7
The main problem, as I see it, with removing these recommendations entirely is that it may make it difficult to reach a concensus.