Re: [nc-deletes] NSI's Comment on Deletions

["John Berryhill Ph.D. J.D." <john@johnberryhill.com>]

> By not requiring deletion, there is the potential that registrars
> may hoard or warehouse domains
> But there are already provisions in the RAA to
> prevent that, if they are just enforced.

No, there aren't.  Filling that hole in the RAA is one of the primary
purposes of this TF.

In the objective version of reality which most of us inhabit, the RAA says:

"3.7.9 Registrar shall abide by any ICANN adopted specifications or policies
prohibiting or restricting warehousing of or speculation in domain names by
registrars."

If someone told you that there is such an "ICANN adopted specification or
polic[y] prohibiting or restricting warehousing" in the RAA, Tim, then that
person is being disingenuous in the extreme.  There is nothing to enforce in
3.7.9 of the RAA, because there simply is no such policy, and there has never
been such policy.

It would be one thing if there were some specificity of what 'functional
safeguards' are mentioned in the VRSN comment, but if the basis for that
statement is some fictional RAA provision against warehousing, then someone
needs to read the RAA.