ICANN has observed community comment concerning the interpretation of RAA Subsection 3.7.7.3. In order to provide clarity, ICANN is posting for public comment the following draft advisory http://www.icann.org/en/compliance/reports/draft-advisory-raa-3773-14may10-en.pdf [PDF, 216 KB]. The forum will be open through 9 July 2010.
One central clarification: if a Registered Name Holder licenses the use of a domain name to a third party, a licensee, the third party is not the Registered Name Holder of record (or "registrant"). This advisory also describes under what conditions that a Registered Name Holder is to identify the licensee and to whom.
Community members are invited to review the draft advisory and comment on all aspects of the document. At the end of this Public Comment period, ICANN Staff will review the comments submitted, prepare a summary analysis of the various submissions, and post the final version of the advisory.
The Public Comment Forum is located here: http://www.icann.org/en/public-comment/public-comment-201007-en.htm#raa-3773