[comments-deletes] Deletes Task Force Initial Report - Comments

["Cute, Brian" <bcute@networksolutions.com>]

Network Solutions submits the following comments for consideration by the
Task Force:

Establishing a uniform deletion practice would adversely affect the rights
of existing registrants.  There are numerous reasons why a registrant may
fail to communicate a request for renewal and why a registrar might not send
a delete command to the registry by the end of the Auto-renew Grace Period.
Registrants and registries are all too familiar with the ramifications of a
failure to renew a registrant's domain name[s].  Adoption of a uniform
deletion practice would effectively operate against the interest of existing
registrants who benefit from functional safeguards under the status quo.  

The proposed practice is purportedly designed to benefit a "prospective
registrant" who is  unable to ascertain the status of a domain that has
passed the 45-day grace period without having been subject of a delete
command from the registrar.  Ostensibly, imposition of a deletion system
would free up this category of names that are eagerly awaited by an
undefined group of prospective registrants.  Imposing a new delete system
overlooks the fact that rules designed to prevent the identified problem are
already in place.  Under their accreditation agreements, registrars are
obligated to refrain from engaging in practices that would otherwise
withhold names from prospective registrants.  Enforcement of these
obligations would go a long way toward solving the problem for prospective
registrants.  

Imposition of a deletion practice that tips the scales squarely against
existing registrants in favor of prospective registrants is not the
desirable balance.  Moreover, such a system would impose additional costs on
all registrars in terms of necessary internal systems adjustments.  The
Initial Report does not make a compelling case as to why the stated risks
and costs should be incurred by registrants and registrars alike.     

Regards,
Brian Cute
Director of Policy
Network Solutions