Hi again, According to: http://gnso.icann.org/mailing-lists/archives/council/msg05146.html we are allowed to make comments at any time on proposed new services. I'd like to put my comments below that I posted on the GA list on the record. I'd oppose setting up registries as judge, jury AND executioner. Even the UDRP has checks and balances. So should any new policy, in order to protect the inherent rights of registrants to due process. Removing a domain name from the zone file, without cancelling the domain, is surely sufficient for even the most urgent cases of abuse. Sincerely, George Kirikos http://www.kirikos.com/ --- George Kirikos <gkirikos@yahoo.com> wrote:
Date: Sat, 21 Jun 2008 15:50:19 -0700 (PDT) From: George Kirikos <gkirikos@yahoo.com> Subject: Potential Danger Ahead for Registrants -- dot-info Abusive Domain Use Policy To: ga@gnso.icann.org
Hi folks,
ICANN has posted a request by Afilias for a new registry service in relation to "abusive" domains in dot-info:
http://www.icann.org/registries/rsep/index.html#2008007 http://www.icann.org/registries/rsep/afilias-request-20jun08.pdf
While in general the proposal is motivated by good intentions, the devil is in the details. While most folks (including myself) probably care very little about the .info TLD, my concern is that any bad implementation in .info might be copied or used as a precedent in other more important TLDs, in particular .com run by VeriSign.
In particular:
"Pursuant to Section 3.6.5 of the RRA, Afilias reserves the right to deny, **cancel** or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, **in its discretion**;........"
(emphasis added)
I would be against giving VeriSign (if the model was copied to .com) that discretionary power over my company's domains, especially the "right to cancel." What exactly is "illegal"? In China, I'm sure there are many things that are illegal that are perfectly legal in Canada, the USA or the EU. Suppose a domain name gets hacked for a brief time, and is temporarily used to serve up spam or malware, etc. That company experiencing bad luck, having their site hacked, can then be put totally out of business in the event that the registry operator, "in its discretion," decides to cancel the domain name.
Thus, I think concern should be raised that any implementation be very conservative in order to protect the inherent right of registrants to due process. The potential for harm in a bad implementation is enormous, and companies and individuals could be put out of business if a valuable domain name is taken from a registrant.
Sincerely,
George Kirikos http://www.kirikos.com/