[nc-deletes] Public Comments

[Bret Fausett <fausett@lextext.com>]

Attached is a summary of the public comments. I did not summarize the
comments of John and Tim in response to some of the submissions. Comments
1-3 on the pricing of the redemption grace period renewals are, I think,
beyond the scope of the task force's work, but we may wish to forward them
to the General Counsel or whomever else is looking at the redeption issues
now. 4-6 hit the substance of the report, and we may wish to add some
comment about why we made the decisions we made or how we've amended the
report in light of these comments.

    -- Bret

Summary of Public Comments on Initial Deletes Task Force Report

(1) In two separate messages, L. James Prevo comments on the high pricing on
redeption grace period domain name renewals, calling the redeption fee "the
worst case of consumer gouging I have ever seen in my life."

(2) "Krishna" writes to ask why the redeption grace period pricing was put
into effect without prior notice to domain name registrants so they could
"renew the domain name on time before the Redeption period comes into
picture."

(3) Marcia Wells also writes to complain about the high pricing on redeption
grace period renewals, calling the fees "exploitative and predatory."

(4) In separate messages, Marcia Wells makes a number of recommendations for
consideration by the task force, including: (a) providing registrants a
means to expressly disavow an intent to renew, thereby allowing the domain
name to be cancelled early or deleted promptly upon expiration; (b) ensuring
that registrars inform registrants of the fee they intend to charge for
renewals during the redeption grace period; and (c) requiring registrars to
provide timely and repeated notices to domain name registrants of the
impending expiration of their domain names. Ms. Wells also commented that
the Deletions Task Force "lacks representation in proportion to the impact
of its recommendation."

(5) Danny Younger argues that Recommendation 3.1.2 is seriously flawed, as
it allows a registrar discretion as to when a domain name may be deleted
within the forty-five days following its expiration. He proposes a uniform
policy whereby domain names are deleted only on the 45th day following
expiration.

(6) Brian Cute, writing on behalf of Network Solutions, believes that the
recommendations of the task force will have a negative effect on domain name
registrants who oftentimes benefit from registrar grace periods longer than
45 days. He suggests that the new rules would benefit prospective
registrants of expiring domain names at the expense of existing registrants,
which is the wrong emphasis.

deletes-summary.txt

Summary of Public Comments on Initial Deletes Task Force Report 

(1) In two separate messages, L. James Prevo comments on the high pricing on redeption grace period domain name renewals, calling the redeption fee "the worst case of consumer gouging I have ever seen in my life."

(2) "Krishna" writes to ask why the redeption grace period pricing was put into effect without prior notice to domain name registrants so they could "renew the domain name on time before the Redeption period comes into picture."

(3) Marcia Wells also writes to complain about the high pricing on redeption grace period renewals, calling the fees "exploitative and predatory."

(4) In separate messages, Marcia Wells makes a number of recommendations for consideration by the task force, including: (a) providing registrants a means to expressly disavow an intent to renew, thereby allowing the domain name to be cancelled early or deleted promptly upon expiration; (b) ensuring that registrars inform registrants of the fee they intend to charge for renewals during the redeption grace period; and (c) requiring registrars to provide timely and repeated notices to domain name registrants of the impending expiration of their domain names. Ms. Wells also commented that the Deletions Task Force "lacks representation in proportion to the impact of its recommendation."

(5) Danny Younger argues that Recommendation 3.1.2 is seriously flawed, as it allows a registrar discretion as to when a domain name may be deleted within the forty-five days following its expiration. He proposes a uniform policy whereby domain names are deleted only on the 45th day following expiration.

(6) Brian Cute, writing on behalf of Network Solutions, believes that the recommendations of the task force will have a negative effect on domain name registrants who oftentimes benefit from registrar grace periods longer than 45 days. He suggests that the new rules would benefit prospective registrants of expiring domain names at the expense of existing registrants, which is the wrong emphasis.