Forwarding Ed's response:

From: Edward G. Viltz 
Sent: Thursday, September 14, 2006 12:03 PM
To: 'Milton Mueller'; [log in to unmask] 
Subject: RE: [NCUC-DISCUSS] [Fwd: PIR Proposal to ICANN on
ProblemsCaused by "Domain Tasting"]

Hi Milton,
This and other questions regarding "domain tasting" are subjects for
discussion and recommendations from the Policy Committee of the
Advisory
Council next month at our annual summit. As you are aware Frannie is
the
NCUC representative. 
 
Elimination of the 5 day grace period is always a potential option and
may be considered by the council; however there are still legitimate
uses of the grace period to correct registrar error (especially by
smaller or newer inexperienced registrars).In the meantime, the excess
delete fee seemed to us to be a good way to deal with the existing
problem of abuse of the grace period and resulting harm, especially to
noncommercial users. 
 In addition, David Maher did in fact reference our proposal in the
Domain discussion in Marrakech and you may recall I mentioned it to
the
NCUC during my presentation. As to the economics, we believe that our
proposal is likely to reduce the number of .ORG registrations, and we
certainly don't believe that the proposed fee will be a "profit
center".

Communication with ICANN has been ongoing regarding our proposal and
we
have recently provided additional requested information in accordance
with the registry request service process.
 
If the NCUC has specific ideas in addition to what was expressed in
the
email thread, please ensure Frannie has the benefit of all NCUC
perspectives to be represented at the Advisory Council Summit. We
appreciate your support.
Best,
Ed

Edward G. Viltz                  (V) +1-703-464-7005 
President & CEO                (F)  +1-703-464-7006 
1775 Wiehle Ave.                Suite 102A 
Reston, VA                         20190 
www.pir.org 
  
       "Serving the Public Interest" 

 


-----Original Message-----
From: Milton Mueller [mailto:[log in to unmask]] 
Sent: Thursday, September 14, 2006 5:46 AM
To: [log in to unmask] 
Cc: Edward G. Viltz
Subject: Re: [NCUC-DISCUSS] [Fwd: PIR Proposal to ICANN on
ProblemsCaused by "Domain Tasting"]

Danny makes some good points. Ed, has PIR considered moving towards
the
elimination of the grace period? Can you inform us about any problems
or
undesirable side effects that would cause? In terms of the burdens on
registrry infrastructure, it would seem to be a better option. 

>>> Danny Younger <[log in to unmask]> 9/14/2006 3:44:39 AM >>>
Having read the PIR proposal as put forward to Tina
Dam, I have a number of preliminary concerns:

1.  From a policy perspective, creating a PIR
profit-center is not the best way forward to deal with
the domain tasting phenomenon, especially when
domainers can readily integrate this proposed five
cent fee into their future business models -- this is
not a threshold that would daunt any in the speculator
community -- it will only generate additional income
for PIR without making any appreciable dent in domain
tasting activities.

2.  As a matter of policy, the 5 day Add Grace Period
should be eliminated.  This time frame was created to
allow a registrant to void any accidental typo in the
registration process; it now serves primarily to allow
typosquatting to become manifest on a massive scale. 
With all the confirmations and re-confirmations now
built into the domain name registration process, we no
longer need a five day window to guard against
inadvertantly mistyped registrations.  Caveat emptor.

3.  This proposal was tendered over three months ago
(15 May 2006) and ICANN has yet to provide an initial
response to the proposal.  It would be nice to know
why there has been such a delay, why ICANN failed to
post this proposal in their Correspondence section of
the website, and why this proposal was not mentioned
at all at the Marrakech Domain Name Marketplace
Workshop in which PIR's David Maher was a panelist. 
It would also be nice to know why the language of this
proposal was not included in the 27 June 2006 proposed
.org registry agreement and is only now being brought
to the attention of the NCUC.

4.  Establishing a policy to deal with the 5 day Add
Grace period is rightfully the province of the GNSO
whose PDP on Contractual Conditions could readily deal
with this issue.  We should not be acting to support a
registry initiative to the detriment of ICANN's
policy-recommending body.  


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