Robin,

Thank you for the work that you have done on this
topic.  Having served as a representative on the
domain tasting ad-hoc working group, allow me to make
the following observations:

(1)  You cite the five purportedly legitimate uses of
the Add Grace Period as stipulated by the registrars
in the ad hoc report; lets review them as I find none
of their justifications to have sufficient merit:

AGP Use 1: Correction of typographical errors made by
registrant -- with all the redundancies built into the
registration process (including all the upsell pages)
the AGP is no longer needed to dealt with this remote
possibility.

AGP Use 2: Cart “hold” to provide access to domain
names -- the concept of reserving a domain at the
registry once it gets "looked up" by a user (that
hasn't paid for the registration) is an abomination.  
As stated in the White Paper:  "The failure to make a
domain name applicant pay for its use of a domain name
has encouraged cyberpirates and is a practice that
should end as soon as possible." 

AGP Use 3: Fraud remedies -- arrangements regarding
the settlement of fraud claims can be built into the
Credits section in the Service Level Agreement within
the relevant registry-registrar agreements; it need
not be part of the AGP.

AGP Use 4: Monitoring, testing and development of
systems -- This argument seeks to make the "cost of
doing business" a registry subsidy.  The argument is
weak and can readily be rejected.

AGP Use 5: Addressing Registrant ‘Buyer’s Remorse’ --
a fine example of BS.

The best way of dealing with the current spate of
domain tasting is to eliminate the Add Grace Period;
this option is preferable to all others.  

Even the PIR approach is amenable to gaming as
registrars can adjust their business and pricing
models to compensate for the extra miniscule charges
that are being imposed -- five cents is not a
sufficient barrier, and even a twenty cent
registrar-level transaction fee may not be sufficient
to stem the tide as registrants have been willing to
pay registrars .2 Euro (see the NASK domain tasting
program launched 3 September) for the privilege of
tasting a domain -- here in the States, programs such
as Traffic Club already charge 25 cents for tasting --
what we don't want to do is to create another new
opportunity for registrars to game the system and
thereby allow domain tasting to continue.  

If you take a close look at the .org Monthly registry
reports, you will see that capitoldomains deleted
1,026,628 domains in .org during the month of May --
they certainly weren't deterred by the PIR fee
assessment.  Accordingly, I disagree with your
conclusion that "Of the proposed responses to the
growing practice of domain name tasting, the most
appropriate may be the imposition of a modest excess
deletion fee."  Simply put, it won't work.

The only safe course of action is to advocate for the
complete elimination of the AGP -- the "modest
restocking fee" approach can and will be gamed.

(2) By the way, with regard to your reference to
phishing/pharming, I should point out that the APWG
study found no correlation between phishing and domain
tasting -- see
http://www.antiphishing.org/reports/DNSPWG_ReportDomainTastingandPhishing.pdf
 

The APWG does note that "tasting affects anti-phishing
efforts. Members of the anti-phishing community have
had to increase their infrastructure to account for
the larger number of potential phish sites that are
being registered by tasters, and this impedes
anti-phishing efforts and increases the cost of
detecting and mitigating the fraudulent behavior."

regards,
Danny


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