Milton, thank you for forwarding Ed's response.  

There may be some value in considering how other
registries have approached this issue.  For example,
Nominet has the following policy:

"In order to protect our systems we impose a limit on
DELETE operations.  This limit is the higher of 5
domains, or 5% of domains that have not yet been
invoiced.  The effective period is calculated as
follows:

From the 8th of the month to the end of the month, the
period is calculated back to the beginning of the same
month.
From the beginning of the month to the 7th of the
month, the period is calculated back to the beginning
of the previous month."

http://www.nominet.org.uk/tag/auto/aup/




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