I wish to raise a further issue wrt Reco 19, allowing registrars to deny a transfer for virtually any breach of the registration agreement.  Given that registrars can put just about anything they like into a registration agreement, and that they are given full discretion whether to judge whether the RNH is in some breach of it, I am concerned this is far too broad of a reason and far too much discretion for a registrar to deny a transfer.  

It seems to be a fairly radical change unless we can develop some restrictive language.  I think our intent was to allow greater freedom to stop transfers where there has been abuse, other than 'fraud'.  And that is a laudable goal that certainly the IPC supports.  So perhaps we should expand on 'fraud' but not so far as 'almost any breach of any provision of the registration agreement' (..., I am paraphrasing).  We could say "fraud or other illegal or abusive behavior", or something like that?

Thanks,
Mike

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Mike Rodenbaugh

address:

548 Market Street, Box 55819

San Francisco, CA 94104

email:

mike@rodenbaugh.com

phone:

+1 (415) 738-8087



On Mon, May 9, 2022 at 2:36 AM Emily Barabas <emily.barabas@icann.org> wrote:

Dear working group members,

 

As a reminder, the deadline for submitting input on the draft Initial Report is 14 May 2022. Please see instructions below for additional details.

 

Kind regards,

 

 Caitlin, Julie, Berry, and Emily

 

From: Emily Barabas <emily.barabas@icann.org>
Date: Friday, 29 April 2022 at 16:27
To: "gnso-tpr@icann.org" <gnso-tpr@icann.org>
Subject: Draft Initial Report - Input Due 14 May 2022

 

Dear working group members,

 

As discussed on Tuesday’s call, staff had an action item to provide the draft Initial Report to the Working Group today for review. Please see the draft attached.

 

Please carefully review this draft Initial Report in coordination with the groups you represent. If you feel that there are items that need to be revised, please enter them here. For each item, please include:

 

  • Report version (the date listed in the header of the Initial Report draft) and applicable line numbers ( these are listed along the left margin of the document).
  • Name and group you represent: If multiple WG members represent a group, input should be in coordination with these other members.
  • Rationale: please provide a clear explanation for why you are proposing the revision.
  • Specific proposed revision: Provide the language you would like to see added/removed/edited.

 

The deadline for submitting input is 14 May 2022. After the deadline, the working group will spend the following four working group meetings reviewing the items submitted in the input document. If your groups are unable to provide input by 14 May, feedback on the Initial Report can be provided during the public comment period.

 

As you review, please note that some sections of the report are highlighted:

 

  • Text highlighted in purple is relatively new and should be reviewed closely.
  • Text highlighted in orange is still under discussion and may change.
  • Yellow highlights are administrative in nature can be ignored.

 

Please do not hesitate to reach out with any questions about the review process.

 

Kind regards,

 

 Caitlin, Julie, Berry, and Emily

 

 

 

 

Emily Barabas

Policy Development Support Senior Manager

Internet Corporation for Assigned Names and Numbers (ICANN)

Phone: +31 (0)6 84507976

www.icann.org [nam10.safelinks.protection.outlook.com]

 

 

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