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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