Hi Ron,<br><br>Thanks for following this issue so closely and your draft responses. My few comments are in line below. I realize I'm coming late to this, so if the point I've raised has already been discussed just let me know.<br>
<br>Best regards,<br><br>Brenden<br><br><div class="gmail_quote">On Thu, Nov 26, 2009 at 3:56 AM, Ron Wickersham <span dir="ltr"><<a href="mailto:rjw@itsmyinternet.org">rjw@itsmyinternet.org</a>></span> wrote:<br><div>
<br><snip><br> </div><blockquote class="gmail_quote" style="border-left: 1px solid rgb(204, 204, 204); margin: 0pt 0pt 0pt 0.8ex; padding-left: 1ex;">
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---------- Forwarded message ----------<br>
Date: Thu, 1 Oct 2009 23:14:49 -0700 (PDT)<br>
From: Ron Wickersham <<a href="mailto:rjw@itsmyinternet.org" target="_blank">rjw@itsmyinternet.org</a>><br>
To: Robin Gross <<a href="mailto:robin@IPJUSTICE.ORG" target="_blank">robin@IPJUSTICE.ORG</a>><br>
Subject: Post-Expiration Domain Name Recovery Policy Draft<br>
<br>
hi Robin,<br>
<br>
i have heard from no one else on the draft, perhaps due to the election, so proceeded on my own.<br>
<br>
note that this is due Oct 6th (may not be reflected on the sites, but the<br>
working group decided to extend the deadline).<br>
<br>
-ron<br>
<br>
#############################################################################<br>
<br>
Constituency Input Template<br>
<br>
Post-Expiration Domain Name Recovery Policy Development Process<br>
<br>
PLEASE SUBMIT YOUR RESPONSE TO THE PEDNR WG AT THE LATEST BY [TO BE CONFIRMED]<br>
<br>
The GNSO Council has formed a Working Group of interested stakeholders and Constituency representatives, to collaborate broadly with knowledgeable individuals and organizations, in order to consider recommendations for best practices as well as or instead of recommendations for Consensus Policy to address a number of questions related to post-expiration domain name recovery.<br>
<br>
Part of the working group's effort will be to incorporate ideas and suggestions gathered from Constituencies through this Constituency Statement. Inserting your Constituency?s response in this form will make it much easier for the Working Group to summarize the Constituency responses. This information is helpful to the community in understanding the points of view of various stakeholders. However, you should feel free to add any information you deem important to inform the working group's deliberations, even if this does not fit into any of the questions listed below.<br>
<br>
For further background information on this issue, please review the GNSO Issues Report on Post-Expiration Domain Name Recovery.<br>
<br>
Process<br>
<br>
* Please identify the members of your constituency who participated in developing the perspective(s) set forth below.?<br>
<br>
<br>
Ron Wickersham drafted the response.<br>
Reviewed by NCUC Executive committee.<br>
<br>
* Please describe the process by which your constituency arrived at the perspective(s) set forth below.<br>
<br>
Notice of PEDNR WG was posted on the NCUC wiki for volunteers.<br>
The NCUC mailing list solicited volunteers and comments from members.<br>
Progress of PENDR WG was discussed briefly on two NCUC teleconferences.<br>
<br>
<br>
Questions<br>
<br>
Please provide your constituency?s views on:<br>
<br>
1. Whether adequate opportunity exists for registrants to redeem their expired domain names;<br>
<br>
Current ICANN policies endeavor to assure that expired domain names can<br>
be redeemed. However, due to the complex array of registrars, and expecially<br>
resellers, these ICANN policies are not as effective as envisioned.<br>
<br>
On the narrow question of "opportunity" it is likely that a timely request<br>
for restoration of an expired domain name is honored.<br>
<br>
But there is a broader aspect which is that the registrant may be offered<br>
no information or incomplete information from the reseller or registrar<br>
handling the domain, and the policies vary widely.<br>
<br></blockquote><blockquote class="gmail_quote" style="border-left: 1px solid rgb(204, 204, 204); margin: 0pt 0pt 0pt 0.8ex; padding-left: 1ex;">
<br>
2. Whether expiration-related provisions in typical registration agreements are clear and conspicuous enough;<br>
<br>
While "typical" registration agreements (especially for the larger<br>
registrars) are good, it is not the case that every registrant receives<br>
a registration agreement.<br>
<br>
Process are in place to assure that the Registries handle every domain in<br>
a uniform manner. Expiration issues should be equally uniform, and not<br>
be considered in the realm of "competitive" variations.<br>
<br></blockquote><div><br>Do you mean "Expiration policies should be equally uniform,..."? If not, I'm unclear what "Expiration issues" are.<br><br>More importantly, while I agree there should be a baseline of policy uniformity, I wonder if we want to allow registries/resellers the flexibility to set policies that could be even _more_ favorable for consumers?<br>
<br> </div><blockquote class="gmail_quote" style="border-left: 1px solid rgb(204, 204, 204); margin: 0pt 0pt 0pt 0.8ex; padding-left: 1ex;">
In matters of this type, education of the Registrant has been suggested as the solution. NCUC believes that education can only suceed if the policies around expiration are identical from any registrar or reseller.<br>
<br></blockquote><div><br>Again, do we want entirely identical policies, or some identical baseline policies?<br><br><br>Thanks,<br><br>Brenden<br><br><br> </div><blockquote class="gmail_quote" style="border-left: 1px solid rgb(204, 204, 204); margin: 0pt 0pt 0pt 0.8ex; padding-left: 1ex;">
Therefore the PEDNR WG would fulfill its mission if ICANN established minimum policies to be set out for notification when domains approach expiration, for procedures to be followed if the registration is not renewed (so that DNS changes at expiration uniformly regardless of registrar or reseller), and notification for restoring an expired domain name is uniform.<br>
<br>
<br>
3. Whether adequate notice exists to alert registrants of upcoming expirations;<br>
<br>
Most registrars provide adequate notice.<br>
<br>
<br>
4. Whether additional measures need to be implemented to indicate that once a domain name enters the Auto-Renew Grace Period, it has expired (e.g., hold status, a notice on the site with a link to information on how to renew, or other options to be determined);<br>
<br>
NCUC finds that whois information on expiration is confusing for registrants due to auto-renew. It would be ideal to eliminate the use of the identical term at the registry whois and the registrar or reseller whois to indicate the status of the domain.<br>
<br>
Because many domains are handled by web-hosting/email-hosting registrars<br>
and resellers, and these are often automated and competitively disparate<br>
offerings, there is little uniformity on what happens and at what speed<br>
changes are made to web sites and email routing when a domain expires.<br>
This variation makes registrant education a difficult goal.<br>
<br>
5. Whether to allow the transfer of a domain name during the RGP.<br>
<br>
Read as if ICANN policy should allow, from willing registrars or resellers, transfer during the RGP, the answer is affirmative. On the other hand, to _require_ registrars and resellers is fraught with difficulties.<br>
<br>
While it is slightly out of scope of the PEDNR WG, there is a related<br>
issue of a registrant being able to transfer before the registration<br>
expires, and in some cases this is precluded by registration agreements<br>
that vary. It would be good policy to require uniformity on this<br>
aspect of oportunity to renew with a registrar or reseller of the<br>
registrant's choice.<br>
<br>
</blockquote></div><br>