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Re: [registrars] SIMPLE QUESTIONS
In a perfect world all ICANN accredited registrars would take appropriate
precautions to avoid fraudulent activity. Well, this isn't a perfect world
and no amount of policy is going to make it so. Even well intentioned
registrars make mistakes, have system glitches, get hacked, etc.
The issue isn't the amount of fraud, it's the result of it. If only 1 in a
1000 transfers is the result of fraud, that 1 fraudulent transfer can cause
an extreme amount of havoc for a registrar and become very costly. Try
telling that registrant that statistically they just aren't important.
It makes no sense to oppose the idea of a cool-down period after a
transfer. There is no significant impact on the registrant, yet the
protection it provides them is significant.
Tim
-------- Original Message --------
Subject: Re: [registrars] SIMPLE QUESTIONS
From: "Ross Wm. Rader" <ross@tucows.com>
Date: Sat, November 30, 2002 2:06 pm
To: "Michael D. Palage" <michael@palage.com>, <tim@godaddy.com>
Michael,
My problem with your proposal is very simple.
Legitimate registrants don't engage in fraudulent exercises.
Where a transfer has occurred, there is a presumption that a) payment
for the first year has already occurred and b) the identity of the
registrant has been verified as the result of the transfer process.
Your proposal assumes that there are a large number of scammers that
make it past these built-in filters and get to the stage where they
are able to bounce around the system and launder their domain names. I
submit that this is a bad basis upon which to make a decision and that
we should look at the real root of the problem, not a symptom.
How the scammer got their hands on the domain name in the first place
is a much more interesting question. Someone got hacked you say?
Someone else is allowing record updates via unverified faxes? Wouldn't
it make more sense for these registrars to get their act together and
deploy systems that don't make it this convenient for the scammers?
Why should my business practices and customers be impacted because
another registrar doesn't have the technical sophistication to
understand that a fax machine is inherently insecure.
That's the problem that I have with your proposal - it makes the
majority modify their practices because of the bad practices of the
minority.
-rwr
----- Original Message -----
From: "Michael D. Palage" <michael@palage.com>
To: "Ross Wm. Rader" <ross@tucows.com>; <tim@godaddy.com>
Cc: <registrars@dnso.org>; <cgomes@verisign.com>
Sent: Saturday, November 30, 2002 3:27 PM
Subject: [registrars] SIMPLE QUESTIONS
> Ross,
>
> Please just answer these questions with regard to my original
> proposal, to help me understand why TUCOWS opposes my original
> question.
>
> Question #1: The 60 day lock down period that is currently mandated
> by policy into the registration agreement exists to provide a
> registrar a safety mechanism to guarantee payment. YES [ ] or No [ ]
>
> Question #2: When transferring a domain name, registrars incur a
> registry fee for the additional year that is added to the
> registration term in connection with the transfer. YES [ ] or NO [ ]
>
> Question #3: What is the difference between an initial registration
> that remains locked for 60 days and a transfer that includes at a
> minimum a one year term extension from a Registrar's standpoint of
> wanting to guarantee payment prior to allowing a domain name to be
> transferred out.
>
> Question #4: Why not seek to abolish the initial 60 lock down window
> and allow for maximum domain name portability?
>
> Question #5: Is it not in both the registrars and registrant's best
interest
> to allow a registrar to contact a new customer and inform them of
> the services that they have to offer and explain some of the
> difficulties that may have been encountered in the transfer process?
>
>
> Personal Comment: Domain name portability is one of the fundamental
building
> blocks of the competitive domain name industry. In connection with
> domain name portability registrars will experience churn. However,
> advocating a system that potentially allows a domain name registrant
> to transfer a
domain
> name 5 times within one week does not seem to be benefiting
> registrars. I
am
> glad that TUCOWS' database does not reveal this problem. All my
> original proposal/question stated was that registrar should be
> permitted to impose this additional safeguard if they choose.
>
> Would you be able to share with us if TUCOWS has ever had to
> reverse(undo) an improper transfer into TUCOWS OpenSRS system. In
> the case where you may have had to undo the transfer, did the fact
> that the domain name was still with TUCOWS simply matters. Would it
> have not been increasingly difficult
if
> the domain name was with a different registrar?
>
> You ASSUMED in your post that I called for a 60 day lock down
> period. However, if you read my post carefully you will see that I
> explicitly
stated
> "I am not stating that the cool-down period be 60 days."
>
> Mike
>
>
>
>
>
>
>
>
>
>
> -----Original Message-----
> From: Ross Wm. Rader [mailto:ross@tucows.com]
> Sent: Saturday, November 30, 2002 2:12 PM
> To: Michael D. Palage; tim@godaddy.com
> Cc: registrars@dnso.org; cgomes@verisign.com
> Subject: Re: [registrars] Transfer Misc Question
>
>
> Michael,
>
> I'm not sure which message you were reading, but your response
> includes several inaccuracies. Perhaps this is the miscommunication
> that you are referring to.
>
> 1. I continue to speak on behalf of Tucows unless otherwise noted. I
> don't believe that this is causing anyone but you confusion.
> 2. No where did I dismiss the concern as "theoretical", I stated
> that "theoretical or limited exceptions are fine" but that they
> tend not to
add
> value to the discussion or solve real business problems.
> 3. The data that I was looking for was where duly identified
> registrants that had transferred a domain name to a new registrar
> chargebacked on
their
> request. I did not ask Tim nor you to provide me with "instances in
> which the proposed mechanism would safeguard registrar and
> registrants
interests."
> 4. Asking Dan the questions you propose don't give me the answers
> that I asked you for in #3. Besides, real registrars ask their
> sales, customer service and finance people to quantify registrant
> issues for them - not ICANN. A scan of our ticketing system and
> datamart doesn't support the
basis
> of fact that you put forward in support of your proposal for the
> reasons I identified in my initial message.
> 5. Your proposal requires domain names to be locked 1/6 of the time.
> The impact to registrants is clear: decreased portability. The
> impact to Registries is obvious: decreased revenue from decreased
> churn. The impact
to
> Registrars is dire: increased costs and decreased revenues.
> 6. I'll leave the rest of your comments untouched for the reasons I
> mentioned privately. If they were actually important please re-ask
> them
and
> I'll be happy to clarify. I assure you, my motives remain
> transparent and
my
> intentions are clear.
>
> -rwr
>
> ----- Original Message -----
> From: "Michael D. Palage" <michael@palage.com>
> To: "Ross Wm. Rader" <ross@tucows.com>; <tim@godaddy.com>
> Cc: <registrars@dnso.org>; <cgomes@verisign.com>
> Sent: Saturday, November 30, 2002 1:28 PM
> Subject: RE: [registrars] Transfer Misc Question
>
>
> > Ross,
> >
> > If GoDaddy has a business concern, and one which I have heard from
> > other registrars then I do not believe as the Task Force
> > representative of
this
> > constituency use should unilaterally dismiss these concerns as
> > "theoretical."
> >
> > I know of at least one instance in which a registrar's system was
> > hacked
> and
> > transfers initiated, and laundered in the manner which I
> > described. For obvious reasons this registrar would prefer not to
> > have these facts
> recited
> > publicly. GoDaddy seems to indicate that it also has seen similar
> > questionable activity.
> >
> > What I do not understand is why would you prohibit registrars from
> > voluntarily imposing a security safeguard to minimize fraud and
> > protect domain name registrants. This is really no different than
> > the redemption grace period designed to protect the interests of
> > individuals and businesses. You have asked Tim and I to give you
> > instances in which the proposed mechanism would safeguard
> > registrar and registrants interests.
I
> > think we have and would suggest you contact Dan Halloran as he
> > could
give
> > you some additional feedback as he has been involved in a number
> > of
these
> > instances.
> >
> > In turn, I would ask you to provide me a situation in which a
> > registrar/registrant would be penalized by asking that registrant
> > to
stay
> > with a registrar for a brief period of time AFTER transferring
> > his/her domain name. Again under the current policy, that
> > registrant MUST stay
> with
> > a registrar for 60 days after registration. I am not stating that
> > the cool-down period be 60 days but allowing a registrant to
> > transfer in and transfer out with a matter of hours should raise
> > questions about the intention of the registrant, or the
> > circumstances surrounding that transaction.
> >
> > Since you oppose what Tim and I deem as fairly reasonable proposal
> > as "further limiting the rights of registrants and registrars in
> > such an aggressive fashion", then does TUCOWS oppose the original
> > 60 day lock
down
> > period as similarly onerous? Why did TUCOWS not seek to eliminate
> > that requirement from the transfer's policy as similarly
> > interfering with the registrars and registrant's rights in such an
> > aggressive fashion.
> >
> > I think this is just crossed communication, and a
> > misinterpretation on
> your
> > end that this safeguard could be used to prohibit an INITIAL
> > transfer.
It
> is
> > not, it is a safeguard mechanism that registrars would be
> > voluntarily allowed to impose in the case of MULTIPLE registrar
> > transfers within a
> brief
> > period of time.
> >
> > Mike
> >
> >
> >
> >
> >
> > -----Original Message-----
> > From: Ross Wm. Rader [mailto:ross@tucows.com]
> > Sent: Saturday, November 30, 2002 12:51 PM
> > To: tim@godaddy.com; michael@palage.com
> > Cc: registrars@dnso.org; cgomes@verisign.com
> > Subject: Re: [registrars] Transfer Misc Question
> >
> >
> > The example provided presumes that the domain name transfer wasn't
> verified
> > in the first place. I'm not sure that it makes a ton of sense to
> > throw
the
> > baby out with the bathwater in such an aggressive fashion. If
chargebacks
> > really are the issue, then lets talk about that, but I suspect the
problem
> > being voiced is more concerned with poor authentication
> > requirements
under
> > the current policy. Duly identified registrants that actually
> > exist are
> not
> > likely to stop payment (its not inconceivable, but I submit that
> > we are dealing with exceptions, not rules at that point.) I'd like
> > to see some
> data
> > that supports the conclusion that this is a widespread issue.
> >
> > I don't agree with further limiting the rights of registrants and
> registrars
> > in such an aggressive fashion in order to deal with what I would
> > characterize extremely limited instances of fraud.
> >
> > Theoretical or limited exceptions are fine but they don't provide
> > value
to
> > the discussion or help those of us that have a real business to
> > run.
> >
> > -rwr
> >
> > ----- Original Message -----
> > From: "Tim Ruiz" <tim@godaddy.com>
> > To: <michael@palage.com>
> > Cc: <registrars@dnso.org>; <cgomes@verisign.com>
> > Sent: Saturday, November 30, 2002 12:09 PM
> > Subject: Re: [registrars] Transfer Misc Question
> >
> >
> > > Go Daddy supports this idea. We've seen the exact fraud scenario
> > > you
> refer
> > > to first.
> > >
> > > Tim
> > >
> > > -------- Original Message --------
> > > Subject: [registrars] Transfer Misc Question
> > > From: "Michael D. Palage" <michael@palage.com>
> > > Date: Sat, November 30, 2002 9:40 am
> > > To: <registrars@dnso.org>
> > >
> > > Under the current policy a domain name is locked for 60 days
> > > after registration to allow the registrar to secure payment.
> > > However,
there
> > > is no similar provision in the case of transfers. In more
> > > than one instance involving domain name hijacking/theft, I
> > > have seen a
domain
> > > name get transferred through multiple registrars then deleted
> > > and re-registered in an attempt to launder a domain name
> > > within a
couple
> > > of days. Why under the proposed policy is it not permissible
> > > for a registrar to lock a domain name on transfer since there
> > > is a
payment
> > > which the registrar must verify for the one additional year
> > > that
the
> > > gaining registrar is billed by the registry. In addition, by
locking
> > > down a domain name after transfer it would limit the ability
> > > of bad guys to launder domain names through multiple
> > > registrars.
> > >
> > > I believe that several registrars have implemented a similar
> > > policy
> to
> > > cut down on fraud, and I was wondering why this mechanism not
> > > be incorporated into the transfer policy, at least on a
> > > voluntary
basis.
> > > I am not requesting that registries modify their software to
> > > incorporate this safeguard. However, I believe registrars
> > > should
not
> > > be prohibited from incorporating this safeguard voluntarily.
> > >
> > > Although this scenario at first blush might possibly qualify
> > > under
> the
> > > fraud and payment exception of Point 16, in the case of
> > > domain name theft/hi-jacking the domain name is generally in
> > > and out of a registrar's system within a day or two. This
> > > brief period of time
is
> > > not adequate enough for a registrar to identify a possible
> > > problem
> and
> > > halt the transfer. What I am basically proposing is that
> > > registrars
> be
> > > permitted to incorporate a "cool down" period after a
> > > transfer to guarantee payment and ensure that there is no
> > > fraud.
> > >
> > > One would have to admit that if it reasonable for a domain
> > > name registrant to stick with one registrar for 60 days after
registering
> a
> > > domain name, it is not unreasonable to ask that registrant to
> > > stick with a domain name registrar for brief period of time
> > > to identify
any
> > > potential illegal activity. Moreover, would people not find
> > > it
highly
> > > irregular for a domain name registrant wanting to
> > > transfer-out
after
> > > just transferring in. Obviously this voluntary policy would
> > > not prohibit registrars from remedying transfers that were
> > > made in
error
> > > or illegally. In fact this transfer's cool down period is
> > > design to make such remedial actions much more easier as the
> > > number of registrars involved in limited to two.
> > >
> > > Any thoughts?
> > >
> > > Mike
> > >
> > >
> > >
> >
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