[nc-transfer] VRSN Response to Motion

["Ross Wm. Rader" <ross@tucows.com>]

For the record, I received two direct comments regarding the solicitation
for comments that I made to my constituency. This being the second received,
the first to follow shortly.

Also for the record note that the official position of the registrar
constituency has not changed, but these comments have been noted.

Thanks,

-rwr
----- Original Message -----
From: "Beckwith, Bruce" <bbeckwith@verisign.com>
To: "Registrars@Dnso. Org" <registrars@dnso.org>
Sent: Tuesday, June 04, 2002 3:50 PM
Subject: RE: [registrars] Fw: [nc-transfer] WLS Draft TF Recommendations


> Ross,
>
> The VeriSign Registrar objects to any recommendation regarding the WLS or
> any other service or product promoted by any of the registries, either
gTLD
> or ccTLD.  As noted in Grant's email below, specifically item 3, other
> organizations have been able to offer services without ICANN, Names
Council,
> nor Transfers Task Force review, therefore, it is not reasonable to
subject
> registries to this level of intrusive regulation.
>
> Regards,
>
> Bruce
>
> -----Original Message-----
> From: Ross Wm. Rader [mailto:ross@tucows.com]
> Sent: Monday, June 03, 2002 6:12 PM
> To: Registrars@Dnso. Org
> Subject: [registrars] Fw: [nc-transfer] WLS Draft TF Recommendations
>
>
> If you have any input on the following draft recommendation regarding WLS,
> please drop me a note. If required, I will be reconciling the input with
the
> Constituency ExComm.
>
> I will be preparing a response later tomorrow that takes into account the
> current consensus of the constituency as I understand it (and including
the
> substantive feedback that I receive from the constituency between now and
> then).
>
> Thanks in advance,
>
> -rwr
>
> ----- Original Message -----
> From: "Grant Forsyth" <grant.forsyth@team.telstraclear.co.nz>
> To: "'Cade,Marilyn S - LGA'" <mcade@att.com>; "Transfer TF"
> <nc-transfer@dnso.org>
> Sent: Monday, June 03, 2002 5:31 PM
> Subject: [nc-transfer] WLS Draft TF Recommendations
>
>
> > Marilyn
> >
> > Having noted on the last Transfers call that the Task Force should draft
a
> > policy recommendation on the subject such that this can be taken back
into
> > our constituencies for a quick turn around in order to get something
able
> to
> > be communicated to the NC at Bucharest, then I  thought I  should start
> the
> > ball rolling.
> > I have now posted this to the whole TF and invite you and others to work
> on
> > refining the wording such it can be taken to properly represent the TF
> > position.
> >
> > Here is my draft policy statement for the Transfer TF on WLS
> >
> > Whereas Verisign has proposed to introduce a new registry service  - the
> > Wait List Service (WLS) - and requested  from ICANN a change to its
> registry
> > agreement to enable this, and
> > Whereas the WLS policy has been extensively posted and commented on, and
> > Whereas the ICANN Board on the 22 April 2002 adopted a resolution
> "inviting
> > community comment on the [Verisign WLS] request, and particularly on
> policy
> > concerns raised by the request that would harm the legitimate interests
of
> > others."
> >
> > The Names Council Transfers Taskforce provides the following comments.
> > We observe that:
> > 1. There is both legitimate  frustration felt by prospective registrants
> in
> > securing a currently registered gTLD domain name when its registration
> > lapses and grave concern by existing registrants that they may loose
their
> > currently registered gTLD domain name should its registration
> > unintentionally lapse.
> > 2. At the core of this frustration and concern is an ill defined and
> poorly
> > enforced deletions policy and practice between the ICANN accredited
> > registrars, their agents and their registry.
> >
> > 3. There exists today a range of competing services that provide the
> > function of seeking out specific expiring gTLD domain names for
> registration
> > by prospective registrants.
> > 4. The WLS service would essentially render the existing services
> > superfluous and we would expect them to exit the market. Even a 12 month
> > trial of the WLS (noting that a 12 month trial would have a 24 month
> effect
> > as a WLS option is for 12 months), as proposed by Verisign, could be
> > expected to result in the current services exiting the market.
> > 5. There has been no evidence provided suggesting that there are any
> > technical issues that would prohibit the existing services from
continuing
> > to operate
> >
> > >From the above we would note that:
> > 1. Current consumer frustration and concern over legitimately acquiring
an
> > expiring gTLD domain name can and should be addressed through the swift
> > introduction and effective enforcement of the proposed Redemptions Grace
> > Period for Deleted Names policy and practice.
> > 2. There is no added legitimate consumer benefit achieved from the
> > introduction of the WLS.
> > 3. Consumer interests are likely to be harmed through the reduction in
> > competition and possibility of discriminatory behaviour between the
> > vertically integrated registrar and registry businesses of Verisign as a
> > result of the monopolisation of the key registry function as a result of
> the
> > introduction of the WLS.
> >
> > Based on the above observations we make the following policy
> recommendations
> > that:
> > 1. The ICANN Board move with all haste to implement and actively enforce
> the
> > proposed Redemptions Grace Period for Deleted Names policy and practice
> > 2. The ICANN Board rejects Verisign's request to amend its agreement to
> > enable it to introduce its proposed WLS.
> > 3. The ICANN Board rejects Verisign's request to trial the WLS for 12
> > months.
> >
> > Should the ICANN Board not accept the policy recommendations noted above
> and
> > grant Verisign's request for a change to its agreement and a 12 month
> trial
> > of its WLS, we would further recommend that:
> > 4. The introduction of the WLS be dependent on the implementation and
> proven
> > (for not less than 3 months) practice envisaged in the proposed
> Redemptions
> > Grace Period for Deleted Names policy and practice
> > 5. The price for the WLS be set at the same amount as the current
registry
> > fee for a registration - the cost of the WLS function being no more, and
> > probably less than a registration (given that the activity is less
> > complicated).
> > 6. The WLS include a requirement that notice be provided by the registry
> > (through the registrar) to the existing registrant of a domain name when
a
> > WLS option is taken out against that registrant's domain name.
> > 7. The WLS include a requirement for full transparency as to who has
> placed
> > a WLS option on a domain name and the registrar that action the option.
> > {Marilyn, you could add a couple more if you wanted to. Do we need to do
> > this or do we want to leave it at the first 3 policy recommendations?}
> >
> > Grant Forsyth
> > BC Rep on the Transfers Task Force
> >
> >