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RE: [comments-deletes] Fairness is all we ask

--- Tim Ruiz <tim@godaddy.com> wrote:
> A. & B. I understand your recommendation here, but
> as the document at the link above explains, ICANN
> was responding to a growing trend of complaints
> about unintentional domain-name deletions. A
> relatively short delay in returning the name to the
> general pool protects the original registrant from
> oversights, registrar errors, etc.

Actually, recommendation "A" was that registrants
should be provided the means to expressly disavow an
intent to renew, so that the name can be returned
promptly.  Not one sentence in the Task Force report
discusses this possibility.  Not one.  As there is
nothing "unintentional" or "inadvertant" when a
registrant expressly disavows his/her intent to renew,
and as the RGP was reputedly created to solely protect
against inadvertant deletions, the RGP should not come
into play.  Even if the RGP covered this as well,
there would be no reason to apply the "auto renew
period" when the registrant clearly is not renewing.

> C. & E. There is a cost to the registrar, imposed by
> the registry, for redeeming a name during the
> Redemption Grace Period. This cost is separate
> from any normal registration or renewal fees. There
> is also a certain amount of manual intervention
> required by the registrar to complete the 
> redemption. The cost imposed by the registry had to
> be approved by ICANN and had to represent a fair
> price based on the cost to the registry to
> implement the RGP.

"had to represent a fair price".  Absolutely HAD TO. 
We understand.  And the additional $115 that
registrars can throw on top of the $85 registry fee
will most assuredly be a fair price as well.  Just
because ICANN blesses something, it doesn't mean it's
fair or that people are honest and upfront.  If
everything ICANN did was great, if everything the
registries and registrars did were honest, there would
be no need for all the reform.  But we all know that's
not the case, don't we Tim?

> D. Antitrust concerns would likely prevent us from
> being able to discuss this, or make recommendations
> regarding it.

If the Task Force discussion truly does represent a
broad range of constituencies, where is the antitrust
issue?  Perhaps you didn't understand.  Recommendation
"D" merely has to do with a disclosure whether or not
the 45 day period (which precedes the 30 day RGP)
*must* be at the registrar's normal registration
price, or whether the registrar may charge a higher
price during this time as well.  This is completely
unclear in the Task Force's report, whether
intentionally or not.  Recommendation "D" is not a
request for collusion, but merely a request that if
the possibility of a higher price exists under the RAA
during this time period, this detail should be made
public in the report so that the public may better
understand the effects of the Task Force's proposals.

> F. A good point. I will bring this up with the other
> members of the task force.

Thank you.  Did you bring this up before you solicited
the registrar constituency for a vote on the Task
Force's report Feb. 27?  The public comment period is
still open until March 3rd.  Should you not wait to
hear all the public's comments before voting?  Again,
what is the point of a public comment period if you
encourage others to make up their minds before the
comments are all in?


Marcia Wells

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