Draft statement on the Verisign RSTEP request for a Domain name exchange service
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC. I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate. Alan ======================= This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry. We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following: - In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting. - This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged. - The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years. - In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse. - The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service. - Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario. - The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved. - Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
I am fine with your statement. I do note, though, that this is mainly addressing the requests of registrars that also have a hosting business. While I have no problem with companies offering both services, their hosting business is not part of the RAA. As such, I do not think ICANN should adapt its policies to suit a cheap hosting business model. If a hosting/registrar company loses the customer after a few months and stays with the domain name, this is a part of his business risk. I also note that VRSN did not even care to ask those registrants. From their submission: Were consultations with end users appropriate? Which groups were consulted? What were the nature and content of these consultations?: Since the proposed service does not change the behavior, performance or understanding of a domain name, those discussions are not applicable. I find it hard to believe that they considered no consultation was necessary with the end users, some of them being the very customers of these registrars/hosters. Patrick On 13 Apr 2010, at 18:50, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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Patrick, as noted in my comment, hosting or other value-added services was used as the rationale for why such a registry service would be useful, but it is not mentioned in the actual service and so its use would not be limited to this. Also, and not as a defence of request, VeriSign is not asking that ICANN change its policies, just that they approve this new service - it is not clear that this service requires a "policy" change. But the converse is not true. A formal policy change perhaps could make this request impossible. Regarding consultation with users, I thought about that, but ultimately decided that the main impact on users "based on the original rationale" was probably just on users who had already given up their rights to the name. As a result, I didn't think that this was a strong argument. Alan At 13/04/2010 02:48 PM, Patrick Vande Walle wrote:
I am fine with your statement.
I do note, though, that this is mainly addressing the requests of registrars that also have a hosting business. While I have no problem with companies offering both services, their hosting business is not part of the RAA. As such, I do not think ICANN should adapt its policies to suit a cheap hosting business model.
If a hosting/registrar company loses the customer after a few months and stays with the domain name, this is a part of his business risk.
I also note that VRSN did not even care to ask those registrants. From their submission:
Were consultations with end users appropriate? Which groups were consulted? What were the nature and content of these consultations?:
Since the proposed service does not change the behavior, performance or understanding of a domain name, those discussions are not applicable.
I find it hard to believe that they considered no consultation was necessary with the end users, some of them being the very customers of these registrars/hosters.
Patrick
On 13 Apr 2010, at 18:50, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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I read Verisign's proposal when Sebastien sent the note about the new services. I didn't completely understand what was being proposed, but it seemed very much for the benefit of the industry (I wondered how domainers might take advantage) rather than registrants. But I felt pretty ignorant about what the implications might be. Alan's statement helps clarify, and I'm happy with that statement. Do we have any comment about the other new service, Neustar's "gTLD Registry Lock". I thought it seemed more beneficial, but again feel somewhat ignorant of the issues. Adam
Patrick, as noted in my comment, hosting or other value-added services was used as the rationale for why such a registry service would be useful, but it is not mentioned in the actual service and so its use would not be limited to this. Also, and not as a defence of request, VeriSign is not asking that ICANN change its policies, just that they approve this new service - it is not clear that this service requires a "policy" change. But the converse is not true. A formal policy change perhaps could make this request impossible.
Regarding consultation with users, I thought about that, but ultimately decided that the main impact on users "based on the original rationale" was probably just on users who had already given up their rights to the name. As a result, I didn't think that this was a strong argument.
Alan
At 13/04/2010 02:48 PM, Patrick Vande Walle wrote:
I am fine with your statement.
I do note, though, that this is mainly addressing the requests of registrars that also have a hosting business. While I have no problem with companies offering both services, their hosting business is not part of the RAA. As such, I do not think ICANN should adapt its policies to suit a cheap hosting business model.
If a hosting/registrar company loses the customer after a few months and stays with the domain name, this is a part of his business risk.
I also note that VRSN did not even care to ask those registrants. From their submission:
Were consultations with end users appropriate? Which groups were consulted? What were the nature and content of these consultations?:
Since the proposed service does not change the behavior, performance or understanding of a domain name, those discussions are not applicable.
I find it hard to believe that they considered no consultation was necessary with the end users, some of them being the very customers of these registrars/hosters.
Patrick
On 13 Apr 2010, at 18:50, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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The Neustar proposal is a copy of what was already approved for .com and .net. and there is no question about it being approved. In fact, it apparently already has been approved even though the 15 days has not elapsed. Alan At 14/04/2010 05:09 AM, Adam Peake wrote:
I read Verisign's proposal when Sebastien sent the note about the new services. I didn't completely understand what was being proposed, but it seemed very much for the benefit of the industry (I wondered how domainers might take advantage) rather than registrants. But I felt pretty ignorant about what the implications might be. Alan's statement helps clarify, and I'm happy with that statement.
Do we have any comment about the other new service, Neustar's "gTLD Registry Lock". I thought it seemed more beneficial, but again feel somewhat ignorant of the issues.
Adam
Patrick, as noted in my comment, hosting or other value-added services was used as the rationale for why such a registry service would be useful, but it is not mentioned in the actual service and so its use would not be limited to this. Also, and not as a defence of request, VeriSign is not asking that ICANN change its policies, just that they approve this new service - it is not clear that this service requires a "policy" change. But the converse is not true. A formal policy change perhaps could make this request impossible.
Regarding consultation with users, I thought about that, but ultimately decided that the main impact on users "based on the original rationale" was probably just on users who had already given up their rights to the name. As a result, I didn't think that this was a strong argument.
Alan
At 13/04/2010 02:48 PM, Patrick Vande Walle wrote:
I am fine with your statement.
I do note, though, that this is mainly addressing the requests of registrars that also have a hosting business. While I have no problem with companies offering both services, their hosting business is not part of the RAA. As such, I do not think ICANN should adapt its policies to suit a cheap hosting business model.
If a hosting/registrar company loses the customer after a few months and stays with the domain name, this is a part of his business risk.
I also note that VRSN did not even care to ask those registrants. From their submission:
Were consultations with end users appropriate? Which groups were consulted? What were the nature and content of these consultations?:
Since the proposed service does not change the behavior, performance or understanding of a domain name, those discussions are not applicable.
I find it hard to believe that they considered no consultation was necessary with the end users, some of them being the very customers of these registrars/hosters.
Patrick
On 13 Apr 2010, at 18:50, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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Based on the comments received to date, and given that it seems that some RSTEP requests are approved prior to the completion of the 15 day period, I am going to submit my comment as a personal one, but add that it is currently being discussed by the ALAC and has the support of several other ALAC members) and is likely (in my opinion) to become a formal ALAC statement. I suggest a 5-day vote starting on Monday. If anyone disagrees with this plan, please speak up quickly. And knowing about those who agree would also be useful. Alan At 13/04/2010 12:50 PM, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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Thanks Alan for your proposal. I agree. I just want to add that if this RSEP is accepted by ICANN it can have consequences not only on end-users but also potentially to the new-gTLDs program. Because if it not included in the possibilities to the new gTLDs it could be seen as a difference of treatment. And if it is to be included it must be discuss as a policy issue and it will take time and can delay the introduction of new gTLDs. As I already suggest in a previous mail, I think we must add the RSEP topics to be followed into the PAD. All the best Sébastien Bachollet sebastien@bachollet.com +33 6 07 66 89 33
-----Message d'origine----- De : alac-bounces@atlarge-lists.icann.org [mailto:alac-bounces@atlarge- lists.icann.org] De la part de Alan Greenberg Envoyé : mercredi 14 avril 2010 14:43 À : ALAC Working List Objet : Re: [ALAC] Draft statement on the Verisign RSTEP request for a Domain name exchange service Importance : Haute
Based on the comments received to date, and given that it seems that some RSTEP requests are approved prior to the completion of the 15 day period, I am going to submit my comment as a personal one, but add that it is currently being discussed by the ALAC and has the support of several other ALAC members) and is likely (in my opinion) to become a formal ALAC statement.
I suggest a 5-day vote starting on Monday.
If anyone disagrees with this plan, please speak up quickly. And knowing about those who agree would also be useful.
Alan
At 13/04/2010 12:50 PM, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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Works for me (noting the RSTEP & PAD matters Sebastien has posted) Cheryl Langdon-Orr (CLO) On 14 April 2010 22:43, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
Based on the comments received to date, and given that it seems that some RSTEP requests are approved prior to the completion of the 15 day period, I am going to submit my comment as a personal one, but add that it is currently being discussed by the ALAC and has the support of several other ALAC members) and is likely (in my opinion) to become a formal ALAC statement.
I suggest a 5-day vote starting on Monday.
If anyone disagrees with this plan, please speak up quickly. And knowing about those who agree would also be useful.
Alan
At 13/04/2010 12:50 PM, Alan Greenberg wrote:
I plan to submit a statement on the RSTEP request. The issue was discussed at the NARALO meeting yesterday and I will also be submitting this draft to a WG within NARALO for further enhancement as a possible NARALO statement. Optimally, if the ALAC can come to closure, a statement could be submitted on behalf of ALAC.
I am using the term "we". In the final version, this will change to the ALAC, NARALO or just me as appropriate.
Alan
=======================
This statement is in response to the VeriSign request for approval of a Domain Name Exchange Service for the .NET Registry.
We caution against approval of this request. Although there may be some benefit to registrars and even to selected registrants for such a service, the potential for negative impact is simply too great. We note the following:
- In the absence of knowing what the exchange fee will be, or any ability for ICANN to control it, this service could be new form of Domain Tasting.
- This is exacerbated because the RSTEP provision "The registrar's account balance will be debited the exchange fee at the time of the initial exchange occurring within a one year term based upon initial registration date" could be read to imply that if more than one exchange is done in a year, only a single fee for the initial exchange will be charged.
- The service effectively introduces the concept of monthly gTLD domain registrations, a practice which does not seem to be forbidden by the various ICANN contracts, but regardless has not been the subject of any policy discussion in recent years.
- In the absence of explicit details on how and when reporting will be performed, there is the potential for abuse.
- The transient nature of domain names (with a potential life as short as one month) will render UDRP and for new gTLDs, URS proceeding virtually ineffective. At the very least, the UDRP and URS would need to be adjusted to address the concept of a Domain Name Exchange Service.
- Although the background of the service cites "Today when a registrant terminates a package of services from a registrar after, for example, an introductory 1 or 3 month period, the registrar is forced to recoup the investment in the associated domain via monetization or the secondary market.", these is no restriction that the service, if approved, be used to address that situation. In fact, further statements in the request imply that Registrars may in fact market it in ways unrelated to the initial scenario.
- The used of the term "forced" in the preceding point implies that monetization and the secondary market are only reluctantly used by registrars or those in the domain name industry. In reality, current wisdom seems to imply that monetization and the secondary market generate more revenue that traditional domain registrations and there is no apparent reluctance involved.
- Although we have no doubt that the introduction of such a service would result in innovative products and marketing, there is little evidence that the service will be in the public interest, and there is some evidence that it could do harm.
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participants (5)
-
Adam Peake -
Alan Greenberg -
Cheryl Langdon-Orr -
Patrick Vande Walle -
Sébastien Bachollet