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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.

Name: Mark Ageeb
Date: 9 Aug 2022
Affiliation: Incredible Names
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.
Recommendation should be deleted

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

Preliminary Recommendation 2: Losing FOA is flawed because it does not protect the domain name registrant in the event that access to their domain name's authorization code was illegally obtained by unscrupulous party. This is synonymous to removing 2 Factor Authorization from the domain name security policy. There is no benefit to the domain name registrant for approving this recommendation, only removal of a proven security measure. ICAN should seek measures that enhance domain name registrant protection, not take away protection measures. Preliminary Recommendation 2: Losing FOA states: The working group recommends eliminating from the Transfer Policy the requirement that the Registrar of Record send a Losing Form of Authorization. This requirement is detailed in section I.A.3 of the Transfer Policy.

Please choose your level of support for Preliminary Recommendation 3.
No opinion
Please choose your level of support for Preliminary Recommendation 4.
Recommendation should be deleted

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

The authorization of Losing FOA should remain with the Registrant, not the Registrar. The Registrant is the person who has vested time and resources into developing the domain name into a public resource and utility; therefore, if abiding by the Policy of ICAN and the Registrar the ultimate decision to authorize a transfer should be their decision.

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.

The authorization of Losing FOA should remain with the Registrant, not the Registrar. The Registrant is the person who has vested time and resources into developing the domain name into a public resource and utility; therefore, if abiding by the Policy of ICAN and the Registrar the ultimate decision to authorize a transfer should be their decision.

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 Submission

Preliminary Recommendation 2: Losing FOA is flawed because it does not protect the domain name registrant in the event that access to their domain name's authorization code was illegally obtained by unscrupulous party. This is synonymous to removing 2 Factor Authorization from the domain name security policy. There is no benefit to the domain name registrant for approving this recommendation, only removal of a proven security measure. ICAN should seek measures that enhance domain name registrant protection, not take away protection measures.