Re: [ga] Fw: Discussion Paper: Redemption Grace Periods for Deleted Names

[Don Brown <donbrown_l@inetconcepts.net>]

First, just some curiosity questions:
 1. Which individual, or individuals, authored this document?
 2. Whose work product is it, i.e. a work group, ICANN Staff, VGRS,
    or who?

With regard to the current system, it is my understanding that if a
Registrar retains a domain name past the expiration date, the
Registrar is required to pay VGRS $6. However, if the domain name is
deleted within the current 45 day period, then that the Registrar is
refunded that $6 by VGRS.  If the Registrar makes a mistake in timely
deletion, the Registrar owns the domain name for a year - their $6 fee
is non-refundable at that point.

Even though VGRS does not earn any revenue due to the current process,
think of the float it creates for VGRS. For instance, as Paul Stahura
of eNom points out ( see
http://www.dnso.org/clubpublic/ga-full/Arc09/msg01011.html ), the
current process ties up $270K of their capital. One might think of it
as a hidden tax imposed by VGRS, when the cost of money is considered.

Paul further makes the point that the Registrars have the discretion
to delete domain names within two days of expiration and the hardship
which that could cause for the previous Registrant.

Although I, personally, do not agree with charging the Registrant a
penalty for a post expiration renewal - unless it is uniformly imposed
in the same amount by all Registrars, I do comprehend the cost and
hardship the current process places squarely on the shoulders of the
Registrar. I also think that Paul has fairly well stated a reason
(although, there are probably other reasons, as well), why some
Registrars may be dropping domain names prior to the 45 day period and
the hardship which that creates for the prior Registrant.

As stated before, there is no uniform specification or policy for
domain name expirations as mentioned in 3.7.5 (and 3.7.11) of the
Registrar Accreditation Agreement ("RAA"), ( see
http://www.icann.org/registrars/ra-agreement-17may01.htm ). It is
noteworthy that this "Redemption Grace Periods for Deleted Names"
document ("RGPDN") ( see
http://www.icann.org/registrars/redemption-proposal-14feb02.htm )
specifically references 3.7.11 of the RAA, which speaks to the same,
absent specification or policy.

Reflecting on the absent specification or policy, the WLS proposal
and the current VGRS system problems, paragraph 10 of the RGPDN
document states, in part, the following:

"Also, the registry operator involved is forced to cope with
extraordinary re-registration demand from domain-name speculators for
the rights to domains that were mistakenly or unintentionally deleted.
Indeed, anecdotal evidence indicates that a significant portion of the
demand for registration of deleted domains involves domains that the
former registrant did not intend to have deleted. If the only names
that became available to the market for re-registering expired names
were ones that were truly no longer wanted by the original
registrants, the demand for expired names would be less intense, and
perhaps significantly so. The "add-storm" phenomenon of multiple
registrars simultaneously sending millions of requests in a race to
grab a few names being deleted from the registry is at least partly
fueled by speculators seeking names that the original registrant had
no intention of dropping. The public interest would be served by
reform of the current system, which operates to allow a few
well-informed and well-connected profiteers to prosper from others'
mistakes."

All things considered, I am in favor of the proposed solution
presented in the RGPDN document as a "policy and specification adopted
by ICANN pertinent to the RAA", with the following modifications:

1. The Deleted Name Redemption Grace Period ("Redemption Grace
Period") should be a "minimum" period for the domain name to be
on-hold by the Registry, so that the Registrant gets the intended time
benefit regardless of any error by any party.

2. Since non-resolution of the domain name is intended to be
notification to the Registrant, as I read the RGPDN document, the
Redemption Grace Period should probably be longer, perhaps still 45
days, when considering the affect that DNS cache expiration may have
on the domain name not resolving.

3. Instead of "During this 30-day period" stated in bullet point two,
under "Proposed Solution" of the RGPDN document, the domain name
should be placed on hold the day following expiration (or as soon as
practical, but subject to the "minimum" as stated in item 1 above), so
that it fails to resolve as soon as possible (it can take days for DNS
cache to expire).

4. When a domain name is on hold, it should be reflected as such in
the WHOIS along with the Registrar's and sponsoring Reseller's
information, so that the Registrant can determine who to contact in
order to initiate renewal.  They forget and many, perhaps most, are
not as computer savvy as most of us.

5. The WHOIS should also indicate the expiration date, the date it was
put on hold and the date it will be dropped/deleted from the Registry.
(The drop/deletion date may also lessen impact on the Registry, as
some have suggested in the past).

6. The Redemption Grace Period should no longer be conditioned upon
payment of the fee to VGRS by the Registrars. In fact, bullet point
three, under "Proposed Solution" of the RGPDN document, speaks to the
payment of the renewal fee at the time it is renewed (if it is renewed
by the Registrant). This will cost VGRS some money and, I'm sure that
some math major can calculate the number of monthly drops, the
resulting float and the cost thereof at, say, Prime +1%. However,
fundamentally, VGRS is suppose to be charging based upon its costs
and, consequently, the profit from the float would seem to be gravy,
anyway -- making it a moot point.

7. With respect to the "service charge" as stated in bullet point
three, under "Proposed Solution" of the RGPDN document, I fail to see
how this procedure will adversely impact the costs of VGRS in a
substantial nature. It seems they will be providing essentially the
same functionality, although some system modifications may be
required. Even so, it is difficult to determine, at this time anyway,
the justification for an additional fee to be paid to VGRS. After all,
their fee is suppose to be based upon cost. On the other hand, if a
"service charge" is determined to be warranted and justified, then I
believe it should be passed through to the Registrant without markup
by the Registrars and Resellers. The alternative, and a more consumer
friendly one, is to amortize the cost of this process (which I think
should be negligible) in the fee (currently $6/yr) paid to VGRS by the
Registrars; what could it cost by amortizing it over new/renewed
domain name registration years -- a penny? Again, VGRS is suppose to
be basing their pricing on their cost.

8. Bullet point three, under "Proposed Solution" of the RGPDN
document, suggests that ONLY the ORIGINAL REGISTRANT is permitted to
renew the domain name during the Redemption Grace Period. I think that
language needs to be more specific and that is should specify
prohibitions, as well.

9. Further, to the RGPDN document, the policy or specification adopted
by ICANN, should also prohibit other potential abuses, such as, but
not limited to "Inappropriate Lending of Registry Access" ( See
http://www.icann.org/announcements/advisory-12feb02.htm ).

10. Also, in addition to the RGPDN document, there should be included
a set procedure or policy for the timely deletion of domain names to
prevent the current hoarding by certain Registrars.

11. Furthermore, there should be some type of mechanism incorporated
into this policy or specification adopted by ICANN (or incorporated
into the RAA in general) which allows the levy of a fine or some other
monetary penalty (notwithstanding the right to cancel the RAA) for an
infraction. There is at least one Registrar which has been hoarding
domain names for a very long time and there needs to be a better
mechanism to address these types of flagrant abuses, short of contract
cancellation.

WLS Proposal:
With respect to the WLS proposal now before us and reflecting upon the
substance of paragraph 10 of the RGPDN document (which was quoted in
part above), we should now turn our attention to ICANN's proposal for
reform, as represented by the RGPDN document.  Consequently, we should
now put on hold any further consider of, and activity pertinent to,
WLS.  Furthermore, if anything should be tested to prove its value, it
should be the product of this ICANN initiative before that of any
vendor.

FWIW




Thursday, February 14, 2002, 11:57:36 PM, Ross Wm. Rader <ross@tucows.com> wrote:
RWR> ----- Original Message ----- 
RWR> From: "Ross Wm. Rader" <ross@tucows.com>
RWR> To: <registrars@dnso.org>
RWR> Sent: Friday, February 15, 2002 12:52 AM
RWR> Subject: Discussion Paper: Redemption Grace Periods for Deleted Names 
RWR>
RWR> Interesting read.
RWR>
RWR> http://www.icann.org/registrars/redemption-proposal-14feb02.htm
RWR>
RWR> -rwr

----
Don Brown - Dallas, Texas USA     Internet Concepts, Inc.
donbrown_l@inetconcepts.net         http://www.inetconcepts.net
PGP Key ID: 04C99A55              (972) 788-2364  Fax: (972) 788-5049
Providing Internet Solutions Worldwide - An eDataWeb Affiliate
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