Robin, Thank you for the work that you have done on this topic. Having served as a representative on the domain tasting ad-hoc working group, allow me to make the following observations: (1) You cite the five purportedly legitimate uses of the Add Grace Period as stipulated by the registrars in the ad hoc report; lets review them as I find none of their justifications to have sufficient merit: AGP Use 1: Correction of typographical errors made by registrant -- with all the redundancies built into the registration process (including all the upsell pages) the AGP is no longer needed to dealt with this remote possibility. AGP Use 2: Cart “hold” to provide access to domain names -- the concept of reserving a domain at the registry once it gets "looked up" by a user (that hasn't paid for the registration) is an abomination. As stated in the White Paper: "The failure to make a domain name applicant pay for its use of a domain name has encouraged cyberpirates and is a practice that should end as soon as possible." AGP Use 3: Fraud remedies -- arrangements regarding the settlement of fraud claims can be built into the Credits section in the Service Level Agreement within the relevant registry-registrar agreements; it need not be part of the AGP. AGP Use 4: Monitoring, testing and development of systems -- This argument seeks to make the "cost of doing business" a registry subsidy. The argument is weak and can readily be rejected. AGP Use 5: Addressing Registrant ‘Buyer’s Remorse’ -- a fine example of BS. The best way of dealing with the current spate of domain tasting is to eliminate the Add Grace Period; this option is preferable to all others. Even the PIR approach is amenable to gaming as registrars can adjust their business and pricing models to compensate for the extra miniscule charges that are being imposed -- five cents is not a sufficient barrier, and even a twenty cent registrar-level transaction fee may not be sufficient to stem the tide as registrants have been willing to pay registrars .2 Euro (see the NASK domain tasting program launched 3 September) for the privilege of tasting a domain -- here in the States, programs such as Traffic Club already charge 25 cents for tasting -- what we don't want to do is to create another new opportunity for registrars to game the system and thereby allow domain tasting to continue. If you take a close look at the .org Monthly registry reports, you will see that capitoldomains deleted 1,026,628 domains in .org during the month of May -- they certainly weren't deterred by the PIR fee assessment. Accordingly, I disagree with your conclusion that "Of the proposed responses to the growing practice of domain name tasting, the most appropriate may be the imposition of a modest excess deletion fee." Simply put, it won't work. The only safe course of action is to advocate for the complete elimination of the AGP -- the "modest restocking fee" approach can and will be gamed. (2) By the way, with regard to your reference to phishing/pharming, I should point out that the APWG study found no correlation between phishing and domain tasting -- see http://www.antiphishing.org/reports/DNSPWG_ReportDomainTastingandPhishing.pdf The APWG does note that "tasting affects anti-phishing efforts. Members of the anti-phishing community have had to increase their infrastructure to account for the larger number of potential phish sites that are being registered by tasters, and this impedes anti-phishing efforts and increases the cost of detecting and mitigating the fraudulent behavior." regards, Danny ____________________________________________________________________________________ Be a better friend, newshound, and know-it-all with Yahoo! Mobile. Try it now. http://mobile.yahoo.com/;_ylt=Ahu06i62sR8HDtDypao8Wcj9tAcJ