Hi Ron, Thanks for following this issue so closely and your draft responses. My few comments are in line below. I realize I'm coming late to this, so if the point I've raised has already been discussed just let me know. Best regards, Brenden On Thu, Nov 26, 2009 at 3:56 AM, Ron Wickersham <[log in to unmask]>wrote: <snip> > > > ---------- Forwarded message ---------- > Date: Thu, 1 Oct 2009 23:14:49 -0700 (PDT) > From: Ron Wickersham <[log in to unmask]> > To: Robin Gross <[log in to unmask]> > Subject: Post-Expiration Domain Name Recovery Policy Draft > > hi Robin, > > i have heard from no one else on the draft, perhaps due to the election, so > proceeded on my own. > > note that this is due Oct 6th (may not be reflected on the sites, but the > working group decided to extend the deadline). > > -ron > > > ############################################################################# > > Constituency Input Template > > Post-Expiration Domain Name Recovery Policy Development Process > > PLEASE SUBMIT YOUR RESPONSE TO THE PEDNR WG AT THE LATEST BY [TO BE > CONFIRMED] > > The GNSO Council has formed a Working Group of interested stakeholders and > Constituency representatives, to collaborate broadly with knowledgeable > individuals and organizations, in order to consider recommendations for best > practices as well as or instead of recommendations for Consensus Policy to > address a number of questions related to post-expiration domain name > recovery. > > Part of the working group's effort will be to incorporate ideas and > suggestions gathered from Constituencies through this Constituency > Statement. Inserting your Constituency?s response in this form will make it > much easier for the Working Group to summarize the Constituency responses. > This information is helpful to the community in understanding the points of > view of various stakeholders. However, you should feel free to add any > information you deem important to inform the working group's deliberations, > even if this does not fit into any of the questions listed below. > > For further background information on this issue, please review the GNSO > Issues Report on Post-Expiration Domain Name Recovery. > > Process > > * Please identify the members of your constituency who participated in > developing the perspective(s) set forth below.? > > > Ron Wickersham drafted the response. > Reviewed by NCUC Executive committee. > > * Please describe the process by which your constituency arrived at the > perspective(s) set forth below. > > Notice of PEDNR WG was posted on the NCUC wiki for volunteers. > The NCUC mailing list solicited volunteers and comments from members. > Progress of PENDR WG was discussed briefly on two NCUC teleconferences. > > > Questions > > Please provide your constituency?s views on: > > 1. Whether adequate opportunity exists for registrants to redeem their > expired domain names; > > Current ICANN policies endeavor to assure that expired domain names can > be redeemed. However, due to the complex array of registrars, and > expecially > resellers, these ICANN policies are not as effective as envisioned. > > On the narrow question of "opportunity" it is likely that a timely request > for restoration of an expired domain name is honored. > > But there is a broader aspect which is that the registrant may be offered > no information or incomplete information from the reseller or registrar > handling the domain, and the policies vary widely. > > > 2. Whether expiration-related provisions in typical registration > agreements are clear and conspicuous enough; > > While "typical" registration agreements (especially for the larger > registrars) are good, it is not the case that every registrant receives > a registration agreement. > > Process are in place to assure that the Registries handle every domain in > a uniform manner. Expiration issues should be equally uniform, and not > be considered in the realm of "competitive" variations. > > Do you mean "Expiration policies should be equally uniform,..."? If not, I'm unclear what "Expiration issues" are. More importantly, while I agree there should be a baseline of policy uniformity, I wonder if we want to allow registries/resellers the flexibility to set policies that could be even _more_ favorable for consumers? > In matters of this type, education of the Registrant has been suggested as > the solution. NCUC believes that education can only suceed if the policies > around expiration are identical from any registrar or reseller. > > Again, do we want entirely identical policies, or some identical baseline policies? Thanks, Brenden > Therefore the PEDNR WG would fulfill its mission if ICANN established > minimum policies to be set out for notification when domains approach > expiration, for procedures to be followed if the registration is not renewed > (so that DNS changes at expiration uniformly regardless of registrar or > reseller), and notification for restoring an expired domain name is uniform. > > > 3. Whether adequate notice exists to alert registrants of upcoming > expirations; > > Most registrars provide adequate notice. > > > 4. Whether additional measures need to be implemented to indicate that > once a domain name enters the Auto-Renew Grace Period, it has expired (e.g., > hold status, a notice on the site with a link to information on how to > renew, or other options to be determined); > > NCUC finds that whois information on expiration is confusing for > registrants due to auto-renew. It would be ideal to eliminate the use of > the identical term at the registry whois and the registrar or reseller whois > to indicate the status of the domain. > > Because many domains are handled by web-hosting/email-hosting registrars > and resellers, and these are often automated and competitively disparate > offerings, there is little uniformity on what happens and at what speed > changes are made to web sites and email routing when a domain expires. > This variation makes registrant education a difficult goal. > > 5. Whether to allow the transfer of a domain name during the RGP. > > Read as if ICANN policy should allow, from willing registrars or resellers, > transfer during the RGP, the answer is affirmative. On the other hand, to > _require_ registrars and resellers is fraught with difficulties. > > While it is slightly out of scope of the PEDNR WG, there is a related > issue of a registrant being able to transfer before the registration > expires, and in some cases this is precluded by registration agreements > that vary. It would be good policy to require uniformity on this > aspect of oportunity to renew with a registrar or reseller of the > registrant's choice. > >