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[nc-deletes] FW: New Paper on Deletions

To kick off some discussions, I'm attaching to this e-mail a message from
Scott Hollenbeck from the VeriSign registry.  He outlines some issues and
concerns with the initial issues paper.

------ Forwarded Message
Thank you for the opportunity to review the Issue Paper on Deletion of gTLD
Registrations.  I would like to provide the following comments:

Issue 1 (Uniform delete practice after domain name expiry by registrars)
includes statements such as this:

"Lack of consistent practice in these areas may, amongst other things, cause
substantial confusion among registrants."


"A possible policy action is to consider a uniform delete process amongst
gTLD registries and registrars."

There will surely be some benefit in developing minimal guidelines for
consistent practices, but the need for consistency must be balanced against
the need to ensure that registries and registrars have flexibility to offer
services that differentiate their business practices from those of their
competitors.  If all registries and registrars offer the same services, with
the same terms of service, there is little room for innovation and consumer
choice suffers.

Issue 2 (Deletion following a complaint on WHOIS accuracy) correctly
identifies the risk in deleting a domain name when the current registrant
can not be contacted to resolve a data accuracy complaint.  There is likely
significant merit to defining a minimum period of time that must elapse and
a sequence of steps that must be taken before a registrar must delete a name
due to a data accuracy complaint.

Issue 3 (Registry delete process) also touches on business practices and the
ability if registry operators to offer services that set them apart from
their competitors.  Any effort to develop a uniform process for domain
deletion should balance the needs of the registrars and the needs of the
registries while allowing room for business service innovation.  Publication
of names to be purged and an estimate of when they will become available for
re-registration may be all that is needed to address the "add storm" and
uncertainty issues that are part of current processes.

Issue 4 (Reversal of renewal transactions) seems based on a misconception: I
do not believe that renewal errors can be addressed only by deleting the
domain name whose registration has been extended in error.  In the VeriSign
Shared registration System, a renewal for a domain registration that has
expired can be undone by issuing an RRP DEL command and then subjecting the
name to normal expiration processing; if the issue is that the renewal was
performed in error after expiration undoing the renewal via a DEL (delete)
operation puts the domain in the same state it would be in if the renewal
had never taken place at all.  Reversing a renewal for a domain registration
that has not yet expired can be addressed through administrative procedures
without deleting the domain name, though again this becomes an issue of
business service differentiation.  At no time is it required to delete a
domain name to undo a renewal operation if the renewal was requested prior
to expiration of the domain name registration period.

Thank you again for the opportunity to provide comments.

Scott Hollenbeck
VeriSign Global Registry Services

------ End of Forwarded Message

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