The Tucows family of registrars thanks the ICANN staff team for preparing this Preliminary Issue Report. We support the topics already included in the Charter, and suggest that bulk transfers between registrars should be added to the list of topics which this Working Group is chartered to address. Policy which supports transferring domains in bulk at this time is limited to the BTAPPA process, which does not apply in most scenarios; as such, registrars and registrants would benefit from a more universal policy not tied to an acquisition. We note that Question A1 in the “Gaining Registrar FOA and Losing Registrar FOA” section is confusingly worded, as the second part of the question is based on a yes/no response to the first part, which is not itself a yes/no question. Also, in the “A. Expected Skills for Working Group Members” section, the third bullet and the second-to-last bullet are almost identical, and could be combined for clarity. Finally, in the interests of moving towards more effective and efficient PDPs, we are open to using the “member/alternate/observer” model for this Transfer Policy Working Group. We suggest that the membership model should be included as part of the eventual PDP review process, to ensure that we evaluate the outcome of that decision. Thank you, Sarah Wyld -- Sarah Wyld, CIPP/E Policy & Privacy Manager Tucows swyld@tucows.com +1.416 535 0123 Ext. 1392
