Re: [registrars] Re: Registrar Code of Conduct (RCoC)

["Tim Ruiz" <tim@godaddy.com>]

Rick,

Here are some of my initial comments/questions.

First, it would be good if you went through and updated it to refer to the
current ICANN RAA sections, and made the second section 9 a 10. It might
keep these discussions from getting too confusing to follow.

My biggest concern is that a lot of what's included is just restating what
we have already agreed to in the RAA, or that really shouldn't need stating
at all.

For example section 5. Is it really necessary to state that registrars
shouldn't engage in fraudulent activity? If a registrar intended to do so,
stating this here would make little difference. I don't have a problem with
it, it just seems obvious and unnecessary.

Section 8 and the second section 9 also seem to be just restatements of
various sections of the RAA, as well as most of the first section 9 except
for the last sentence of B., E. and most of F. What is the purpose of
restating what we have already agreed to in the RAA?

I do have a few items I would like clarified.

What is the purpose behind not changing name servers during a transfer? Not
that I disagree with it, I just want to understand the purpose, and perhaps
that should be at least eluded to in the document.

Section 9.E. is problematic in that it doesn't allow for the situations
that I believe section 2 of Exhibit B of the RLAs was allowing for,
primarily court orders and dispute resolutions. WIPO decisions on the INFO
names is a recent example. Or am I not understanding the intent here?

Section 9.F. requires maintaining DNS for 90 days after a transfer. Could
you explain how you came to that time period? Why does it need to be more
than a few days?

Tim