I was asked to review the Initial Report of the Inter-Registrar Transfer Policy Part C PDP WG, and recommend whether the ALAC should comment on it, and if so, to draft a comment. The call for comments can be found at http://www.icann.org/en/news/public-comment/irtp-c-initial-report-04jun12-en... and the Interim Report at English version of the report can be found at http://gnso.icann.org/issues/transfers/irtp-c-initial-report-04jun12-en.pdf (other languages at first link). The Inter-Registrar Transfer Policy (IRTP) is primarily focused on the transfer of a registered domain name from one registrar to another. However, at the time of Registrar Transfer, there is often also a change of who the registrant is, yet the IRTP is silent on any aspect of that. Since transfers of this sort are often associated with domain hijacking, it should certainly be of concern to At-Large and ALAC. The PDP is also looking at a number of other aspects of IRTP including how Registrars are identified (currently some registries use proprietary identifications). I strongly recommend that the ALAC comment on this report and my draft comment follows. The initial comment period closes on July 5th. Alan ===================================================== The ALAC supports the general direction that the IRTP C PDP WG is heading. Specifically, the ALAC strongly supports all measures the will reduce the possibility of domain hijacking while still providing legitimate registrants the ability to change registrars. The ALAC similarly supports all efforts to formally define the process by which the registrant of record can be changed, with implicit safeguards to inhibit hijacking. The ALAC does not have strong views as to whether this needs to be a separate consensus policy of not, but the overall results and benefits to registrants should not be diminished by this decision. The ALAC supports the requirement to have all gTLDs use the IANA Registrar IDs (in addition to any proprietary ones if desired). Lastly, the report could benefit from a clearer overview describing the change of registrar and registrant processes.