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RE: [registrars] additional comments re:Touton's letter to VGRS
The
letter doesl reflect the Registered Name Holder to repond but the statment
reads:
"express authorization from an
individual who has the apparent authority to legally bind the Registered Name
holder".
This could be the Admin contact which
may be different then the Registrant.
David
W.
IARegistry
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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