[registrars] additional comments re:Touton's letter to VGRS
I see the crux of the transfer issue covered by touton's
comments as follows:
"3. The allocation
of responsibility does indicate, however, that the
losing registrar may not deny a transfer request that the gaining registrar has
verified merely because the losing registrar has not verified
it. Thus, a losing registrar should not deny a
transfer request simply because it has notified the Registered Name Holder of
the request and has not received a response.
4. The losing registrar may, however, deny the transfer request where it has an adequate reason for believing that the Registered Name Holder has not authorized the transfer. In some instances, the failure of the Registered Name Holder to respond to a notification may form one element of the reason. Because the policy allocates the verification responsibilty to the gaining registrar, however, the lack of such a response is not by itself an adequate reason to deny the transfer. Additional elements of an adequate reason may include information relating to the Registered Name Holder (such as prior communications) or the authorization practices followed by the gaining registrar." comments anyone ?
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