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