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[nc-deletes] Revised Public Comments

Below is a link to my re-draft of the public comments summary and our
responses. Jordyn, for your convenience, I've done this in html, with links
to the relevant source documents, so you should be able to just plug it into
the existing report. The source is attached.

 http://www.lextext.com/deletescomments.html

Comments and revisions welcome.

  -- Bret


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	<title>Deletes Comments</title>
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<p>
<b>D R A F T</b>
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<p>
Summary of Public Comments on Initial Deletes Task Force Report 
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<p>
(1) In two separate messages (<a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00001.html">first</a> / <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00002.html">second</a>), 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."
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<p>
(2) "Krishna" <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00003.html">writes to ask</a> 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."
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<p>
(3) Marcia Wells <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00005.html">also writes to complain</a> about the high pricing on redeption grace period renewals, calling the fees "exploitative and predatory."
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<p>
<blockquote>
<b>TASK FORCE COMMENT ON 1, 2, and 3:</b> <br />
<i>Comments on the pricing for domain names renewed during the deletion grace period are beyond the scope of the task force's work. The ICANN Board <a href="http://www.icann.org/minutes/prelim-report-25feb03.htm#RedemptionandConsoliDateServicesincomandnet">recently approved</a> revisions to the Verisign Registry Contract, allowing the new pricing model. The Task Force has taken note of the pricing concerns, however, and will forward the comments above to the ICANN General Counsel, the GNSO's Registrars Constituency, and the GNSO's Registry Constituency.</i>
</blockquote>
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<p>
(4) In separate messages (<a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00007.html">first</a>, <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00008.html">second</a>, <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00010.html">third</a>), Marcia Wells makes <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00007.html">a number of recommendations</a> 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."
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<p>
<blockquote>
<b>TASK FORCE COMMENT ON 4:</b> <br />
<i>The Task Force was grateful for the many substantive suggestions contained in Ms. Wells' posts and took account of them in its deliberations and revisions to the Task Force document. Specifically, Ms. Wells' suggestion that "registrars inform registrants of the fee they intend to charge for renewals during the redeption grace period" is now included in the proposed recommendation. While the suggestion that registrars provide "timely and repeated notices to domain name registrants of the impending expiration of their domain names" is a good one, the Task Force members noted that a requirement for at least two notifications is currently included in <a href="http://www.icann.org/registrars/ra-agreement-17may01.htm#3.7.5">the ICANN Registrar Accreditation Agreement</a>. 
</i>
</blockquote>
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<p>
(5) Danny Younger <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00012.html">argues that Recommendation 3.1.2 is seriously flawed</a>, 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.
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<p>
<blockquote>
<b>TASK FORCE COMMENT ON 5:</b> <br />
<i>Mr. Younger raises an issue that the Task Force discussed early in its deliberations. At its initial meetings, members of the Task Force appointed from constituencies composed of users raised the same issue as Mr. Younger. The registrars, however, made the point that registries bill the registrars for a renewed domain promptly on its renewal date and then credit the renewal fee back if the domain name is deleted within forty-five (45) days. While some registrars are willing and financially able to front the registry fee on behalf of a domain name registrant, not all registrars are in the same position. The registrars expressed the strong concern that requiring them to bear the registry fee would place an undue hardship on smaller registrars. Based primarily on this concern, the Task Force compromised on the discretionary window of 45 days, which will provide some uniformity and certainty while also allowing those registrars who wish to do so to avoid the registry renewal fee for domain names not renewed by the registrant.
</i>
</blockquote>
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<p>
(6) Brian Cute, <a href="http://gnso.icann.org/dnso/dnsocomments/comments-deletes/Arc02/msg00013.html">writing on behalf of Network Solutions</a>, 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. 
</p>

<p>
<blockquote>
<b>TASK FORCE COMMENT ON 6:</b> <br />
<i>During its deliberations, the Task Force, including those members appointed from constituencies comprised of users and registrants, took account of the concerns raised by Network Solutions. On balance, the Task Force members believed that the greater certainty and uniformity required by the recommended rules outweighs the benefits described in Mr. Cute's contribution. 
</i>
</blockquote>
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