RE: [registrars] Interim Transfer Proposal

[Bruce Tonkin <Bruce.Tonkin@melbourneit.com.au>]

Hello Tim,

> 
> 
> Summary comment in the proposal: "Inter-registrar domain name 
> transfers
> become transactions predicated on trust and an assumed lack 
> of malfeasance
> on behalf of any party to the transaction."
> 
> As a result, it should no more assume any registrar would 
> "game" the system
> than that one would "slam" it. As a result losing registrars 
> should not have
> their hands tied as a result of such assumption of 
> malfeasance as implied
> below.
> 

Any system can be equally gamed by either the losing registrar or the
gaining registrar.
The current agreement between the Verisign registry and each registrar
states that it is the gaining registrar's responsibility to obtain the
approval from the registrant, however the Registry technical process gives
the losing registrar the power of veto.  Thus presently at the technical
level the losing registrar effectively has control over the process, and is
in the strongest position to "game" the system.

In either approach, what is currently lacking is any enforcement procedures.

The guiding principle is that the registrant should be able to choose their
registrar.
We need:
(1) A consistent process for the registrant to make their choice (this is
what the Transfers Task Force has focussed on so far, and what the latest
Verisign proposal attempts)
(2) An enforcement process to ensure that neither the gaining or losing
registrar can interfere in (1) - this is not currently solved by either the
transfers task force or Verisign Registry proposal as yet, and is the
missing element.

From my point of view, I don't care who's responsibility it is to get the
approval of the registrant, as long as such approval from the registrant can
be independently verified by the other party.  It does not make sense that
the registrant needs to go through two separate verification processes from
both the losing and gaining registrar.  This just leads to registrant
confusion.

An extreme solution is to create an independent third party that verifies
and authorises transfers.  This has been done in some industries.  There is
a cost in doing this, but it does remove the power from either the gaining
or losing registrar, and places it in the hand of the registrant.

Melbourne IT supports the current draft of the transfer task force report
and the Verisign proposal (with the clause about allowing transfers if the
registrant does not reply to the losing registrar).  It is a waste of effort
to debate this further.

Melbourne IT would like to see us move on and deal with an enforcement
approach that is acceptable to both the losing and gaining registrar.  This
is where the efforts of all would be better spent.

Regards,
Bruce