[nc-imp] Implementation Issues
 We believe the final 29 recommendations made by the TF represent very little change in the current process, with the exception of the Standard Form of Authorization. This will be largest issue for those tasked with its implementation as well as for the registrars. There are two 
other recommendations where we felt comment was warranted. All other 
recommendations we believe can 
be implemented with no, or 
very little impact on our current 
operations. 
Recommendation 
5. 
The Registrant must be informed of and have access to, the 
published documentation of the specific 
transfer process of their current Registrar. The Task Force notes that it would 
also be useful for Registrants to have access to the transfer process 
documentation of Registrars that the Registrant is considering switching 
to. 
Comment 
The last sentence is not clear. Is the intent that links to the transfer documentation of all registrars would in some way be available? If so, this would best be done through a central location at the registries, or perhaps ICANN, since both have contractual relationships and could enforce compliance. Recommendation 
25. Instances when the Losing Registrar may not 
deny a transfer include, but are not limited to;  
d. Domain name registration period time constraints other than during the first 60 days of initial registration. Comment 
This conflicts with security measures that have been working for us. For example, we try to offer a simple, yet secure, mechanism for registrants to transfer ownership of their domain names. As a part of that security, the new registrant must agree not to transfer the domain away for 60 days. In addition, registrants transferring domains to us must also agree that they will not transfer the domain again for 60 days, another security measure. These are reasonable steps that have little impact 
on portability, yet add much security for the registrant, and lessens the 
likelihood of dispute resolution procedures. We believe allowing these two 
"optional" time constraints will improve security and lessen the likelihood of 
dispute resolution. 
Tim Ruiz 
Go Daddy Software, Inc.  |