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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: Jody Kolker
Date: 11 Aug 2022
Affiliation: GoDaddy
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.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 2.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 3.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 3, please indicate the revised wording and rationale here.

GoDaddy supports the RrSG's position.

Please choose your level of support for Preliminary Recommendation 4.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 4, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 5.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 6.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 7.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 7, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 8.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 9.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 9, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 10.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 10, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 11.
Support Recommendation as written

If your response requires an edit or deletion of Preliminary Recommendation 11, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 12.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 12, please indicate the revised wording and rationale here.

GoDaddy supports the intent but would like the WG to review whether the notification of Transfer Request should be mandatory, allowing Registrants a period of time to review the transfer request prior to the TAC being issued. With the current recommendations, transfers will be completed upon the Gaining Registrar’s request of the transfer, thus removing the current pending transfer window that allows Registrants to accept or deny the transfer request. GoDaddy also strongly recommends that any changes to the transfer policy continue to provide registrants the ability to pre-authorize transfers without subsequent registrant or registrar approval.

Please choose your level of support for Preliminary Recommendation 13.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 13, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 14.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 14, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Please choose your level of support for Preliminary Recommendation 15.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 16.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 17.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 18.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 19.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 19, please indicate the revised wording and rationale here.

GoDaddy supports the intent of this recommendation to allow for broader support for denial of transfer requests beyond "Evidence of Fraud". GoDaddy does not, however, support the current wording of the recommendation because it is overly broad and provides registrars with the ability to abuse the denial of transfer requests simply by stating a request violates the registrar’s terms of service. GoDaddy supports registrant choice and the free transfer of domain names, but we also want to balance those concepts against bad actors and abuse. Therefore, we recommend that the Working Group consider defining an enumerated list of abusive practices that would be eligible for appropriate denial of transfer requests. Such a list could include “evidence of fraud, illegal activity, phishing, distribution of malware, or to comply with the law".

Please choose your level of support for Preliminary Recommendation 20.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 21.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 22.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 22, please indicate the revised wording and rationale here.

GoDaddy supports the RRsG's position.

Are there any other comments or issues you would like to raise pertaining to the Initial Report? If yes, please enter your comments here. If applicable, please specify the section or page number in the Initial Report to which your comments refer.

Generally, we maintain that privacy/proxy should be considered holistically and not an issue this WG needs to resolve. Instead, use of RNH is the appropriate mechanism to consider privacy/proxy issues.


Summary of Submission

GoDaddy is pleased to comment on the Initial Report on the Transfer Policy Review Policy Development Process - Phase 1(a). We appreciate the hard work of the group members and leadership team, and overall support the efforts of the working group.

It is important to ensure that domain owners maintain the ability to choose their provider, which includes the ability to transfer the domain when they want to do so, while also not being at risk of domain theft (and especially not at increased risk due to the changes outlined here). GoDaddy believes that the updated Transfer Policy will appropriately balance these needs.

In general, GoDaddy supports most recommendations. Godaddy has several suggestions to improve two recommendations.