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. __________________________________________________ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com