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RE: [del-com] Transferred from Bruce Tonkin

Some comments on the first draft....

Just a general comment - I understand that everyone is very busy so this
might not be possible to achieve, but I find it very difficult to
produce informed comments and talk to them on the same day.  It would be
very helpful if documents and revisions were produced more in advance of
a discussion call in order to have some minimum time to properly digest
the inputs and formulate coherent output. As it stands, I have not yet
read the second draft, nor the minutes from the prior call. These
comments are specifically intended to discuss issues with the first
draft. Specific thanks to Bruce for yet again taking the initiative to
ensure that these discussions are taking place and focusing the group on
the goals at hand.


3.1.1 - I suppose some further clarity could be brought to the language,
but it was perfectly clear from the original language that "the
registrant, or somone acting on the registrant's behalf" could pay for
the renewal. The discussion in the feasibilty category points to the
opposite. Anything that brings clarity is fine, as long as we don't
over-invest our time in pedantics and semantics.

3.1.3 - Discusses grandfathering effective 180 days post-adoption. Why
isn't this immediate contemporaneous with the start of implementation?

3.1.4 - Suggested Replacement: "Make readily available" and "an
indication" are incredibly vague. The following sentence would be much
more precise re: intent - "Registrars must publicly post or otherwise
make available to existing and prospective clients, at the time of
registration and at any time during the registration period, details of
the Registrars' deletion and auto-renewal policy."

Also - what is a domain name license? This should simply state "during
the registration period"

3.1.5 - What is "a conspicuous place"?

3.1.6 - I'm not sure that the SRT necessarily translates to something
that I can implement. I operate a website that allows registrants to
maintain their registration. This interface does not allow for purchase
or renewal. Registrants must interface with their reseller for a
purchase, renewal or any other chargeable service. Further, these
resellers, conceivably could, all charge a different rate for an RGP.
What is it exactly that I should be doing under this recommendation?

Lastly, this is a policy recommendation regarding the deletion of domain
names, not the redemption of domain names. It is not appropriate to lump
notice requirements concerning RGP transactions into a body of policy
that purports to be dealing with deletion transactions. I would like to
see 3.1.6 stricken entirely with a note to the RGP evaluation process to
consider notice requirements.

3.2.1 - Strongly agree with recommendation to delete based on the
incorrect assumption that the registrar must assume an administrative
burden as the result of a dispute resolution process. The complainant,
the UDRP provider and the "defendant" are all capable of using Whois to
determine when a domain name might expire. 

3.3.1 - Also an RGP specific recommendation that extends beyond the
scope of these recommendations. Similar to my thoughts on 3.1.6, this is
better addressed within the context of the entire RGP policy and any
evaluation of its effectiveness.


"There's a fine line between fishing and standing on the shore like an
- Steven Wright

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> -----Original Message-----
> From: owner-del-com@dnso.org [mailto:owner-del-com@dnso.org] 
> Sent: Tuesday, May 06, 2003 2:58 PM
> To: del-com@dnso.org
> Subject: [del-com] Transferred from Bruce Tonkin
> From: Bruce Tonkin
> Sent: Tuesday, 6 May 2003 10:30 PM
> To: 'Ross Wm. Rader'; 'ebroitman@register.com'; 'Cute, Brian';
> 'tim@godaddy.com'; 'tom@schlund.de'; 'Rick Wesson'; 
> 'stahura@enom.com';
> 'rob@momentous.com'; 'Jordyn.Buchanan@Registrypro.com'
> Cc: 'michael@palage.com'; 'Ken Stubbs'; 
> 'jeff.neuman@neustar.us'; 'Louis
> Touton'; 'halloran@icann.org'
> Hello All,
> I have carefully reviewed the deletes task force 
> recommendations and the
> comments provided by the ICANN staff.
> I have produced the following draft deletes implementation report for
> discussion.  It reflects my views as a registrar (ie not as 
> GNSO chair, or
> on behalf of the registrars constituency).   The 
> implementation report is in
> the same format as that used for the implementation reports 
> for transfers
> and WHOIS in January 2003.
>  http://www.dnso.org/dnso/notes/Deletes_Implementation_Report_v1.0.htm
> I will schedule a teleconference for later this week to 
> discuss, but would
> welcome any comments prior to then.
> I think it is important that the major registrars, and other 
> registrars that
> focus on policy development, review the report carefully.
> Regards,
> Bruce Tonkin
> Melbourne IT

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