Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Jason Banks
Date:1 Aug 2022
Affiliation: None
Are you providing input on behalf of another group (e.g., organization, company, government)?
No
Please choose your level of support for Preliminary Recommendation 1.
No opinion
Please choose your level of support for Preliminary Recommendation 2.
Significant change required: changing intent and wording

If your response requires an edit or deletion of Preliminary Recommendation 2, please indicate the revised wording and rationale here.

Please see comments below

Please choose your level of support for Preliminary Recommendation 3.
No opinion
Please choose your level of support for Preliminary Recommendation 4.
No opinion
Question to the community: Should the Gaining Registrar’s IANA ID be provided by the Registry Operator to the Losing Registrar so that it may be included in the Notification of Transfer Completion sent by the Losing Registrar to the Registered Name Holder? Why or why not? Please explain.

Yes. It would help alleviate concerns that the domain might not end up in the correct place.

Please choose your level of support for Preliminary Recommendation 5.
No opinion
Please choose your level of support for Preliminary Recommendation 6.
No opinion
Please choose your level of support for Preliminary Recommendation 7.
No opinion
Please choose your level of support for Preliminary Recommendation 8.
No opinion
Please choose your level of support for Preliminary Recommendation 9.
No opinion
Please choose your level of support for Preliminary Recommendation 10.
No opinion
Please choose your level of support for Preliminary Recommendation 11.
No opinion
Please choose your level of support for Preliminary Recommendation 12.
No opinion
Please choose your level of support for Preliminary Recommendation 13.
No opinion
Please choose your level of support for Preliminary Recommendation 14.
No opinion
Please choose your level of support for Preliminary Recommendation 15.
No opinion
Please choose your level of support for Preliminary Recommendation 16.
No opinion
Please choose your level of support for Preliminary Recommendation 17.
No opinion
Please choose your level of support for Preliminary Recommendation 18.
No opinion
Please choose your level of support for Preliminary Recommendation 19.
No opinion
Please choose your level of support for Preliminary Recommendation 20.
No opinion
Please choose your level of support for Preliminary Recommendation 21.
No opinion
Please choose your level of support for Preliminary Recommendation 22.
No opinion
Summary of Attachment

One of the most valuable assets a company or individual has in their identity. Even small companies and individuals have a deep interest in protecting their brand, and their address on the Internet, which includes their domain names.

My concern with the ICANN proposed policy to eliminate the losing FOA, is that it removes a critical safety check for owners of domain names.

Governments around the world have begun to recognize the value of identity as well as the assets that are developed by brands and businesses which attach to that identity. Identity security is itself a multibillion dollar global industry. I can see no good reason to reduce the security of one’s intellectual property holdings such as domain names, simply because a couple of days is “inconvenient”.

Transactions revolving around large or important assets like real property or money have numerous checks and balances. Assets of the magnitude of brand and identity (which have high relative value regardless of the size of the entity), should also have vigorous checks and balances.

Domain name transfers can be simple and secure

 1.) The current registrant of the domain name should be notified of a pending transfer.

2.) The current registrant of the domain name should have the option of approving or rejecting the transfer.

Why change this process?

Being notified after a domain name is transferred is akin to being notified after one’s bank account is emptied.

Credit card companies, when they recognize a potentially fraudulent transaction, contact the account owner to verify the purchase or transfer. They use the card or card number plus CVV to provide “proof of identity” and therefore proof of legitimacy. So, though inconvenient, the credit card companies I know of have superlative security measures in place.

Since ICANN and domain registrars are dealing with such valuable assets, doesn’t it make sense that they should also provide similar if not greater levels of security, even if a little inconvenient?  

Summary of Submission

I think that the change to the losing party FOA process is dangerous for owners of intellectual property including individuals, SMBs and multi-billion dollar businesses as well as institutions and non-profit organizations. I am requesting more time for the public to comment and discuss the proposed changes.