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[registrars] CoC


Dear Rick:

Here are some comments:

        http://www.icann-registrars.org/html%20docs/CodeofConduct3.htm

Purpose:

This Registrar Code of Conduct describes key areas of operation for accredited registrars competing in the registration of gTLDs.  The Code has been developed by operational Registrars, to reflect experience under the terms and conditions of the ICANN Registrar Accreditation Agreement (RRA), identifying roles and responsibilities common to all registrars and providing interpretive guidance; it should thus be considered in concert with this Agreement,  the RRA and any other documentation relevant to a particular transaction.

I think these changes made it easier to understand.

5.  Fraudulent transfers of registrant rights  (Hijacking)
 
ICANN-accredited registrars shall not initiate fraudulent transfers  transfer or change of registrant rights of any kind for any reason.


We continue to beat around the bush because a domain is not "property" but a "service".  That's why I beat around the bush in my wording.

The present document has two separate sections which refer to "Transfers", #5 and #9.  The casual reader will not understand that they are totally different processes.  I think they should be adjacent, e.g. change #5 to #8.

 
9.       Transfers of Sponsoring Registrar.
 
This paragraph modifies or clarifies the current process of transferring domain name registration sponsorship as identified in Exhibit B of the Registrar and License Agreement between VeriSign Global Registry Services and each registrar.

Comment:  We now have several gTLDs and possibly one ccTLD (.us) to which this CoC should be applicable.  I don't know how to reword it, but it should be so edited.  Is Exhibit B similar for Afilias and Neulevel?  If so, let's make it a generic reference to the registries and registrars.
 
 In closing, it is clear to many of us that there needs to be a CoC.  We will begin to have a link to the Interim CoC in our web sites.

Regards, BobC


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