RE: [registrars] current update on whois task force
Hello
Ken,
I
notice that the current draft proposes that in addition to checking that an
email address is correct after a name has been placed in HOLD status (e.g via
sending a confirmation email to the new contact email address) that a registrar
should do further checks (such as attempting to contact the registrant using
other contact points e.g post or fax or phone etc). This is a further cost
on the registrar, and I do not support it (e.g manual labour cost and cost of
postage etc). I think email should be the minimal check
REQUIRED.
If the
email address is working, then a complainant has at least one verified method of
communicating with the registrant. The complainant is free to carry
out their own checks of postal address etc, or alternatively the
complainant could pay the registrars costs in doing further checks. It is
not reasonable that a registrar should incur further costs as a result of
failure of a registrant to provide correct details. Alternatively a
registrant may be charged to update contact details after a name has been placed
on HOLD just as they are charged for retrieving a name in the Redemption Grace
Period.
So I
recommend that this change to the implementation committees suggestion not be
accepted. It is what I call scope creep. If it is accepted, then the
WHOIS Task Force should be made aware that as a consequence registrars will need
to charge either the registrant or the complainant for the additional
costs. The WHOIS Task Force should consider whether the burden of costs
should lie with the registrant or the complainant in their suggested
procedure.
I note
the implementation committee also recommended a review process for the new WHOIS
recommendations and also recommended a 30 day period for a registrant to respond
to a request.
Regards,
Bruce
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