RE: [ga] Ignoring the Rules

["Neuman, Jeff" <Jeff.Neuman@neustar.us>]

Danny,

See my comments in ALL CAPS below:

Also, this may put me beyond the posting limit, and if so, I apologize in
advance.

-----Original Message-----
From: DannyYounger@cs.com [mailto:DannyYounger@cs.com]
Sent: Thursday, November 07, 2002 2:15 PM
To: Jeff.Neuman@neustar.us; ga@dnso.org
Cc: mcade@att.com
Subject: Re: [ga] Ignoring the Rules


Jeff,

If the process was followed by members of the TF, then I wouldn't have to 
revert to arguing about process.  As I see it, the members of the TF have 
looked at one proposal only.  They have not even bothered to discuss the
VGRS 
Interim Transfer Policy Proposal posted at 
http://www.dnso.org/clubpublic/registrars/Arc01/doc00119.doc nor have they 
bothered to examine operative models within the ccTLD community that deal 
with transfers (such as the auDA published policy on transfers at 
http://www.auda.org.au/docs/auda-2002-08.txt which was brought to the 
attention of the registrar community by the Chair of the Names Council).  
There are also new proposals on the table such as the one put forth by
Elliot 
Noss at http://www.dnso.org/clubpublic/registrars/Arc01/doc00128.doc.  How 
then can you write "TO BE HONEST, THERE WERE NO OTHER PROPOSALS THAT WERE 
RECEIVED"...  


1)  VERISIGN HAS ONLY MADE ITS PROPOSAL TO THE REGISTRARS AND NEVER TO THE
TASK FORCE.  IN ADDITION, IF YOU LOOK AT CHUCK'S PROPOSAL, MOST OF IT WAS
DERIVED FROM OR IS VERY SIMILAR TO THE TF REPORT.

2)  WITH RESPECT TO AUDA, NO ONE HAS BROUGHT THAT TO THE ATTENTION OF THE
TASK FORCE UNTIL NOW.  

3)  ELLIOT'S PROPOSAL WAS PUT ON THE TABLE YESTERDAY (WAY AFTER THE REPORT
WAS PUT OUT) AND IT ONLY APPLIES TO .COM AND .NET (NOT TO ANY OTHER
REGISTRY).  HIS PROPOSAL WOULD BE IMPOSSIBLE TO IMPLEMENT (AS HE ADMITS) IN
THE EPP REGISTRIES.



Further, how much feedback do you expect when the language in your Interim 
proposal is as clear as mud to most registrants?  As David Safran wrote:  "I

am increasingly finding it hard to decide how my constituency should stand
on 
the proposals since more and more of the discussions are focusing on factors

which seem to me to be primarily within the knowledge base of the registrars

and registries, and appear to be directed to mechanics not policy."  You 
state regarding "a clear statement of what is being proposed and its 
underlying rationale" --THIS IS IN THE REPORT ITSELF -- I defy you to
present 
to us that clear statement.  In the entirety of your document, I have yet to

find a single phrase, sentance, or paragraph that explicitly states what the

proposed policy is in language that a layman can understand.  

THE PAPER PROVIDES PRINCIPLES AND PRACTICES FOR REGISTRARS TO FOLLOW IN BOTH
RRP AND EPP REGISTRIES TO EFFECTUATE A TRANSFER.  IT FOLLOWS A PREMISE OF
"AUTO-ACK" AND PROVIDES SPECIFIC EXAMPLES OF THE LIMITED CIRCUMSTANCES IN
WHICH A "LOSING" REGISTRAR CAN DENY A TRANSFER REQUEST FROM A "GAINING
REGISTRAR."  IT ALSO PROVIDES FOR A STANDARD FORM OF AUTHORIZATION TO
INITIATE A TRANSFER AND A DISPUTE RESOLUTION PROCESS IN THE EVENT THAT A
REGISTRAR DOES NOT FOLLOW THE PRINCIPLES AND PRACTICES SET FORTH IN THE
REPORT.

YOU ARE CORRECT IN THAT THE DOCUMENT IS VERY TECHNICAL AND NOT EASY TO
UNDERSTAND BY LAYMEN, AND FOR THAT I AM SORRY.  I WILL BRING THIS UP WITH
THE TASK FORCE.  SOMETIMES WHEN YOU ARE SO INTIMATE WITH THE DETAILS, YOU
FORGET THAT NOT EVERYONE HAS THOSE DETAILS.

How are we to provide you with substantive comments on "the costs and risks,

if any, of implementing the proposal and how they would be borne" when you 
haven't given us anything to work with?  

WHAT MORE CAN WE GIVE YOU?

The Dispute Resolution provisions -- 
we have no idea if you're talking about a $1500 fee or a $30 assessment 
because you haven't provided any commentary on this topic.

THIS IS SOMETHING WE ARE SEEKING COMMENT ON.  HOW MUCH SHOULD A DISPUTE COST
GIVEN THE AMOUNT OF WORK THAT A DISPUTE PANELIST WILL HAVE TO DEAL WITH?
WHAT PROCESSES DO YOU THINK SHOULD BE IN PLACE?  WILL SUCH A DISPUTE PROCESS
PROTECT THE ULTIMATE CONSUMER?    

More comments will follow later this evening...

WE WOULD APPRECIATE IT.

 
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