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[ga] RE: [GTLD Registries List] FW: .BIZ Transfer Policy


Thanks for your e-mail.  You are certainly entitled to your opinion on the
subject, but perhaps before jumping to the conclusion that you already have,
please consider the following:

1)  NeuLevel has every interest in finding a workable solution to the
problems associated with transfers between Registrars.   NeuLevel, a
subsidiary or NeuStar, has since the very beginning supported the Registrars
position in doing everything possible to enhance the portability of domain
names.  In fact, NeuStar has a long history of enhancing portability of
telephone numbers for all of North America.  For example, because of
NeuStar, all United States consumers can switch local telephone companies
without having to change their phone numbers because we maintain the Local
Number Portability database.  The parallels between the telephone industry
and domain names are striking, and NeuStar intends to apply the same
philosophies to the Internet space.  

2)  It is not in the interest of any new Registry, including NeuLevel, to
inhibit portability.  To be blunt, transfers are a revenue event for the
Registry (because an additional term must be bought with every transfer), so
it is very much in a Registry's interest to see that the transfer process is
as easy as possible.  That being said, we do not want to allow the transfers
to take place until the proper secure systems are in place, and the ultimate
consumer is protected.  

3)  We believe the mess in .com, .net and .org has taken way too long to
resolve and often the consumer is being left out of the debate.  With the
new method that NeuLevel is proposing to be adopted, consumers will be able
to easily transfer their domain names by giving their "auth-info" tokens to
the "gaining registrars" and see their transfers take place immediately --
No e-mails from the losing registrar, no auto-nacks, no games -- no hassle
to the consumer.  If a registrant presents a valid token to the gaining
registrar when a transfer is requested, the Registry knows that the transfer
has been authorized by the Registrant.  There will be no waiting periods and
thus, no room for a losing registrar to "game" the system.

4)  Before this can happen, however, registrars and registrants must be
educated on how to generate a token, how to maintain the security of a
token, and how to recover a lost token, through the EPP Protocol used by the
"thick registries."  This takes time.  We are aggressively engaging in such
an educational campaign now and as soon as the Registrars and Registrants
can be educated, you will see a far more superior and secure transfer
mechanism than anything that currently exists.

Jeffrey J. Neuman, Esq.
Director, Policy and Intellectual Property
NeuLevel, Inc. 
Loudoun Tech Center
46000 Center Oak Plaza
Building X
Sterling, VA 20166
e-mail: Jeff.Neuman@NeuLevel.biz

-----Original Message-----
From: Jeff Williams [mailto:jwkckid1@ix.netcom.com]
Sent: Thursday, January 17, 2002 4:45 PM
To: Neuman, Jeff
Cc: 'gtld@gtldregistries.org'; 'michael@Palage.com'; General Assembly of
the DNSO
Subject: Re: [GTLD Registries List] FW: .BIZ Transfer Policy

Jeff and all,

  I am afraid that I would have to disagree with Richards contention
here with respect to Transfer of Domain names.  His long winded
explanation after stating his and it seems Nuelevels position on this
issue is also a bit suspicious in and of itself to boot.  In that Richard
is a sales person and therefore is predisposed to "Sell" this position
whether of not it has merit, also looks very suspicious.

  Therefore I can only read this Nuelevel position as one that
strongly indicates that Nuelevel is not interested in looking or
assisting in finding a workable solution to the many Transfer
problems and poor practices that have been broadly reported
and have become a concern of fairly large proportions.  In addition
this Nuelevel position seems to be one of protecting your own
.BIZ registrations and registrants whether or not they would like
to move to a different registrar.

Neuman, Jeff wrote:

> FYI - This is the note that NeuLevel sent out to the Registrars earlier
> today regarding transfers in the .BIZ domain.
> Jeffrey J. Neuman, Esq.
> Director, Policy and Intellectual Property
> NeuLevel, Inc.
> Loudoun Tech Center
> 46000 Center Oak Plaza
> Building X
> Sterling, VA 20166
> e-mail: Jeff.Neuman@NeuLevel.biz
> *****************************************
> Dear Registrar Partner,
> We have recently received numerous questions and comments from registrars
> the issue of domain transfers between registrars, and we want to begin a
> dialogue with you on the transfer-related challenges facing our industry.
> It is NeuLevel's belief that there is currently no acceptable method for
> transferring domain names in the existing gTLD space that accomplishes the
> goal of portability of domain names while at the same time preventing
> such as "slamming."  As most of you are aware, and as has been extensively
> documented, there are significant problems in the .com, .net and .org TLD
> space with how transfers of domain names occur, not the least of which is
> the challenge of establishing apparent authority.  The current situation
> not only confusing for registrars, but also to the ultimate consumer.
> We also understand that many registrars are just now becoming familiar
> the capabilities and functionality of the "auth-info" tokens provided by
> so-called "thick registries" including .biz and .info.  However, overall
> knowledge of the thick registry transfer process, particularly at the
> Registrant level, is still minimal or non-existent.
> Some of the problems that have come to our attention include (a) that some
> Registrars are generating blanket (common) tokens for all domain name
> registrants; (b) other registrars are not providing tokens to their
> customers at all; (c) registrants are neither requesting tokens nor do
> have an adequate understanding about the need or use for tokens.  Finally,
> there do not yet exist secure and efficient systems for token retrieval
> (re-issuance) in cases where a token is lost or stolen.
> The net result is that few unique, secure and valid tokens are getting
> the hands of registrants, and hence to potential gaining Registrars.
> this is not the result of bad faith or bad practice by Registrars, it is
> currently causing a gap in the education of the Registrar community and
> our ultimate consumers, the Registrants.  The industry and end-user
> population have simply not been educated in the proper use of "auth-info"
> tokens.   This is the fault and responsibility of NeuLevel as much as
> anyone.  We feel that it is both our responsibility and obligation to
> that systems for the proper issue, storage and processing of tokens are
> institutionalized within the industry.
> We do not believe there is currently a working transfer model in the gTLD
> industry.  If we implement .BIZ transfers now we expect we would
> to industry problems rather than fixing them.  Therefore, we intend to
> freeze .BIZ transfers for a period of 30 to 60 days and engage in a
> of channel/user education regarding transfers with tokens. In this program
> we will work with you to create systems and awareness for the issue,
> and processing of secure, unique, valid tokens.  We do not believe this is
> an insurmountable task.  We are at fault for not initiating it sooner, and
> we want to advance this dialogue with you for the betterment of our
> practices and for the enhancement of the end-user experience.
> In addition, during this period, we also intend to discuss with each of
> the merits and flaws of a system that recognizes a five (5) day ACK/NACK
> a system that already provides for reliable, authorized transfers by using
> valid token.  With your collaboration we will look to stimulating industry
> debate on the merits of instantaneous transfer (in the presence of a valid
> token).  We believe this is an achievable and desirable position, when we
> have all institutionalized the proper management of tokens.
> I will be available to discuss this as will your Registrar Relations
> Executive.  Thank you in advance for your cooperation and contribution to
> this dialogue.  If you have any immediate reactions, please feel free to
> respond to this email and we'll begin collecting and reviewing your
> feedback.
> Sincerely,
> Richard Tindal
> Vice President, Sales and Channel Relationships
> NeuLevel, Inc.
> 46000 Center Oak Plaza
> Sterling, VA 20166 USA
> richard.tindal@neulevel.biz
> ---------
> Participants on the gTLD Registry Constituency public mailing list are
requested to not cross-post messages.

Jeffrey A. Williams
Spokesman for INEGroup - (Over 121k members/stakeholdes strong!)
CEO/DIR. Internet Network Eng/SR. Java/CORBA Development Eng.
Information Network Eng. Group. INEG. INC.
E-Mail jwkckid1@ix.netcom.com
Contact Number:  972-244-3801 or 214-244-4827
Address: 5 East Kirkwood Blvd. Grapevine Texas 75208

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