Summary of Comments received on VeriSign Proposal # 201004, Domain Name Exchange in .NET Between 5 April and 20 April 2010, ICANN received three comments to the registryservice@icann.org comment forum on a proposal from VeriSign to offer the Domain Name Exchange service in .NET. The comments are archived at * George Kirikos: http://forum.icann.org/lists/registryservice/msg00033.html * Alan Greenberg: http://forum.icann.org/lists/registryservice/msg00034.html * Marilyn Cade on behalf of the Business Constituency: http://forum.icann.org/lists/registryservice/msg00035.html All three comments cautioned ICANN staff against approval of the request, or alternatively to provide more time to evaluate the potential impacts of the proposed service and provide opportunity for a formal public comment period. Analysis George Kirikos wrote on 5 April that the proposal is "functionally no different than reintroducing domain tasting, albeit with a 30-day minimum registration period and no refund." In addition, he noted that the proposal created a new loophole around the deletions policy and that ICANN should deny the proposal, or at a minimum open it up for a formal public comment period. Alan Greenberg submitted his comment on 14 April in his personal capacity but noted that the comment was under consideration as a formal position of ALAC. He noted that the proposal raised potential negative impacts which could lead to a new form of domain tasting. He stated that "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." Alan also asserted that the proposal did not provide explicit details on how and when reporting will be performed, and the service may raise issues for dispute resolution procedures such as the Uniform Domain Name Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS). The Business Constituency echoed concerns from George Kirikos and Alan Greenberg that the proposal may reintroduce domain tasting. "The proposed service reasonably raises concerns that permitting applicants to register a dozen domain names for the price of a single domain name will invite speculators to game the system and use it for domain name abuse....it is also reasonable to ask staff to explore whether VeriSign's new service might be used so excessively that it would cause the same kinds of stability problems." The Business Constituency noted that VeriSign described steps to make the service more transparent, but were skeptical that the proposed remedies would prevent domain name abuse. Next Steps The comments received are being considered by ICANN staff in the evaluation of the proposed service. Further information will be provided at http://www.icann.org/en/registries/rsep/#201004. -- Patrick -- Patrick L. Jones Senior Manager, Continuity & Risk Management Internet Corporation for Assigned Names & Numbers 4676 Admiralty Way, Suite 330 Marina del Rey, CA 90292 Tel: +1 310 301 3861 patrick.jones@icann.org patrickjones.tel