Colleagues, The following is a list of comments/questions related to the second version of the URS technical requirements. Your feedback is appreciated. Comments from James Gould: 1. The text for requirement 8 provides two options for handling a domain that expires while in URS Lock that focuses on allowing the URS Lock domain to be deleted (online or offline) after the expiry and the subsequent auto renew. I believe that this is a corner case that adds some additional complexity. Allowing deletion of the URS Lock domain post-expiry makes the domain expiration date an element that must be considered when submitting the URS complaint. If the main driver of this requirement is to allow the domain to be deleted within the auto renew grace period, the likelihood of the URS process exceeding the auto renew grace period is extremely low. Based on my calculation the maximum URS duration is 45 days which matches our auto renew grace period of 45 days. The auto renew grace period of various TLD's could be shorter, but the auto renew grace period will most likely be a long enough period to cover the URS process. My recommendation is to not do anything at expiry of URS Lock domains and allow the URS process to complete prior to allowing the domain to be deleted. GL - For UDRP there is a provision (3.7.5.7) in the http://www.icann.org/en/resources/registrars/accreditation/eddp for handling the scenario of active UDRP process during the end of the validity period. Unfortunately the URS Procedures are silent about what happens if a URS locked DN expires. During our internal discussions, the conclusion was that the normal registration lifecycle should be followed when the URS Procedures are silent. The auto-renew grace period, as you mentioned may be shorter for some TLDs and this will create corner cases for the Registrars and the Registry Operator of that TLD, e.g. Is the registrar billed for the renew? Who pays the renew? Is credit provided to the Registrar if the URS process finalize and the registrant/complainant don't want the DN to be renewed? The number of UDRP cases filled in the last month of the validity period of a DN is low and we believe this is likely going to be the case for URS. The proposal is to show a warning message when filling the URS procedure if the domain name is within the last month of validity, explaining that the domain name may be deleted during the URS process and the process will be terminated. 2. The text in requirement 9 "Registry Operator MUST offer the option for the URS Complainant to extend a URS Suspended domain name registrations for up to one year from the date the domain name was Suspended", sounds like the renew command behavior needs to change for URS Suspension domains. The renew command should extend from the prior expiration date and not the date the domain name was suspended. I do not recommend making any change to the renew logic for URS Suspension domains, since it will impact all of the registries and the registrars. I recommend that the registries allow for the renew of URS Suspension domains and leave it up to the Registrars to ensure that the renew is done at most once for URS Suspension domains, by the URS Complainant, according to the Registry-Registrar Agreement. GL - The text needs to be clarified, as the idea behind Requirement 9 is basically what you are proposing. This is the proposed new text: Registry Requirement 9: In cases where a URS Complainant (as defined in the URS Rules) has prevailed, Registry Operator MUST offer the option for the URS Complainant to extend a URS Suspended domain name's registration (if allowed by the maximum validity period of the TLD). Registry Operator MAY collect the renewal fee paid by the URS Complainant for the URS Suspended domain name from the sponsoring Registrar of the domain name. It's worth mentioning that in section 4, the following provisions are defined: The Registry Operator MUST specify in the Registry-Registrar Agreement for the Registry Operator¹s TLD that the Registrar MUST accept and process payments for the renewal of a domain name by a URS Complainant in cases where the URS Complainant prevailed. The Registry Operator MUST specify in the Registry-Registrar Agreement for the Registry Operator¹s TLD that the Registrar MUST NOT renew a domain name to a URS Complainant who prevailed for longer than one year (if allowed by the maximum validity period of the TLD). 3. Handling the URS Suspension of domains when the domain has child hosts. The redirect of the domain with child hosts could impact many other domains outside that TLD, since the resolution of those name servers will not or should not work. If a registry shares the same pool of name servers across TLD's, the glue for the child hosts might be returned in DNS, but the resolvers might not trust cross-TLD name server glue. Consider the case of URS Suspension domain foo.com with child host ns1.foo.com, where bar.net uses ns1.foo.com as a name server. A query for bar.net could include the IP addresses for ns1.foo.com, but since .com and .net are different TLD's the resolver could and most likely independently attempt to resolve ns1.foo.com. Resolution of ns1.foo.com will not work if foo.com is redirected to the URS Provider's name servers. This issue impacts TLD's outside of that registry, since they most likely would not have the glue. There might be nothing that can be done about potentially breaking resolution of other domains using child name servers of a URS Suspension domain, but we should discuss it and determine if there is anything that needs to be done to minimize the impact. GL - It's difficult to know which domain names depend on another domain name as separate entities administer separate sections of the DNS tree. However, this seems to be a corner case. It would seem unlikely that URS suspended domain names will be used to define hosts of other domain names, as the expectation is that these domain names are not used for legitimate purposes, but we will work with URS providers to add some text that advises the Registrant of the URS suspended domain name that he/she should notify other Registrants which domain names may depend on the URS suspended domain name to take the appropriate action. 4. A related topic to #3 is what to do with the child hosts when a URS Suspension domain is auto-deleted / auto-purged at expiry. In our registries, a domain cannot be deleted if there are child hosts being used as name servers for other domains in our registry database. The registrars will typically rename the child hosts under another domain to allow for the domain to get deleted. My recommendation is to remove the serverDeleteProhibited status at expiry of a URS Suspension domain instead of auto-deleting or auto-purging it, and allow the domain to auto renew. The Registrar can and will most likely go ahead and delete the domain during the auto renew grace period following the existing process that they follow in deleting domains with child hosts being used as name servers for other domains. I recommend disallowing the use of the RGP restore command for URS Suspension domains that entered RGP after deletion. Without the ability to restore, the domain will propagate through the RGP statuses (redemptionPeriod and pendingDelete) prior to getting purged from the registry, which is consistent with how domains are currently deleted. GL - When creating the draft of the URS technical requirements, we followed the strategy that if something is not clear in the URS Procedures, we should follow the normal registration life cycle. Your suggestion follows this strategy; therefore we believe your proposal is adequate. The activation of serverUpdateProhibited during URS Lock and URS Suspension should be enough to prohibit the restore from working, therefore there is no need to specify that a Registrar should not send a restore command for URS suspended DNs or that the Registry should disallow restore, correct? Comments from Rubens Kuhl: As the second version still shows issues that the community addressed in the past for domain registrations, it seems to us that registries should handle URS providers the same ways they handle domain registrars: thru EPP. URS providers could have proper EPP credentials that would allow them to make a limited set of transformations (URS Suspension, URS Lock, URS Roll-back) to every domain in the registry (except for mandatory domains like NIC or WHOIS). Everything we are trying to do with e-mail have already been done with a higher degree of process integrity thru EPP. GL - The idea of using EPP has been discussed internally and was also mentioned during the conference call. Defining EPP extensions, requiring registries to modify their SRS implementations and requiring URS providers to implement EPP may be over engineering if we don't know the volume of URS procedures and the URS Procedures define email as the interaction mechanism. In case that the volume of URS procedures is high and the community believes that EPP support is required, ICANN is willing to consider transitioning the process to EPP. Comments from Kal Feher: Under what circumstances would a name transition from URS Suspension to URS Lock? I am referring to your Note under the definition of URS Lock. I¹ve reviewed both the technical and non-technical requirements and neither explain when this would occur. GL - This is an unlikely scenario, and the purpose of the note is that if this transition is required, the Registry Operator regenerates the glue records. Also will there be further detail on how URS interacts with other processes, such as UDRP? GL- Section 3(g) of the URS rules define: A URS Complaint may not be filed against a domain name that is part of an open and active URS or UDRP case. Regards, Gustavo