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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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Submissions for this Proceeding

Initial Report on the Transfer Policy Review - Phase 1(a)

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Initial Report on the Transfer Policy Review - Phase 1(a) Submission - León, Lucía
16 August 2022

Submission Summary:

There are several improvements in order maximize the principles of data minimisation and privacy by design. Considerations about denying reasons must be taken into account, maybe extending the deadline.

I support Preliminary Recommendations 1-15 as written (with an observation for PR 13, following RySG criteria).


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Dynadot
16 August 2022

Submission Summary:

Preliminary Recommendations 16 & 17 seek to impose new ICANN restrictions on RNHs’ rights to transfer domain names subsequent to initial registrations and subsequent to inter-registrar transfers.

 

Dynadot opposes the introduction of any new restrictions on registrants’ rights to transfer domain names to competing registrars. Legislators across the world are proposing laws aimed at discouraging market practices that restri...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Poole, John
16 August 2022

Submission Summary:

The Working Group has further critical work to do. As my comments have indicated, terminology and consistency with RFC 9154 are paramount.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Newfold Digital
16 August 2022

Submission Summary:

Newfold Digital appreciates the opportunity to submit comments in response to the Initial Report on the Transfer Policy Review Policy Development Process - Phase 1(a). We congratulate and thank the efforts put in by the members and leaders of this Working Group. The aspects and functionality of a domain name transfer is a crucial and integral piece for many domain owners. Working towards improving the security and efficiency of transfers will ...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - RrSG
16 August 2022

Submission Summary:

The Registrar Stakeholder Group (RrSG) 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...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Namecheap
16 August 2022

Submission Summary:

Namecheap submits these comments in response to the Initial Report on the Transfer Policy Review Policy Development Process - Phase 1(a). Namecheap appreciates the opportunity to provide feedback to this policy initiative, which will have significant impact on registrants and registrars. The proposed recommendations will improve the transfer process from a registrant perspective, while additionally improving security of domain name transfers.<...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - NCSG
15 August 2022

Submission Summary:

Transfer policies can have grave consequences for noncommercial registrants rights. We are pleased to see that some of those problems have been handled in phase one. 

We agree that the previous policies that needed the registrars access to sensitive private information of domain name registrants are not legally viable anymore. Therefore we agree with and applaud the working group for not pursuing specific methods for coming up with ...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Busca, Philip
15 August 2022

Submission Summary:

Someone wrote on NP forum about 2FA security, what if ones wife have access to the mobile phone and can access the registrant account with 2FA after receiving the code through SMS or application, well it's your fault that you have such wife or who ever is around you, not the registrar, humans will find ways to steal from you it's your responsibility, you must make sure to keep it secret if you have valuable domain assets. So in the end it's on...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Com Laude
15 August 2022

Submission Summary:

We generally support the recommendations developed by the WG. We propose the following amendments to reasons why registrars must deny transfers:

I.A.3.8.6 The Registrar of Record has credible evidence of fraud

I.A.3.8.7 the Registrar has knowledge of credible evidence of the domain currently being used for malware, phishing, pharming, or command & control botnets. 


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Leap of Faith Financial Services Inc.
15 August 2022

Submission Summary:

There is a lot wrong with this working group's report, too long to summarize briefly. Read the entire 60 pages to see our full analysis.

We wish to emphasize, though, that the TAC is very dangerous. It should be eliminated, by adopting our counterproposal in Section E (generate a transaction ID at the gaining registrar, to input at the losing registrar). This would be a huge improvement. 

Also, the Losing FOA needs to be ...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Kariuki, Samwel
14 August 2022

Submission Summary:

I appreciate the work of PDP WG members and, overall, support this report.



Initial Report on the Transfer Policy Review - Phase 1(a) Submission - GoDaddy
11 August 2022

Submission Summary:

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 a...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Policy staff in support of the At-Large Community, At-Large Advisory Committee (ALAC)
11 August 2022

Submission Summary:

The At-Large community and the At-Large Advisory Committee (ALAC) appreciate the opportunity to submit comments on the Transfer Policy Review Policy Development Process (TPR PDP) Phase 1a Initial Report. The At-Large community is focused on the Registrant and End-User perspective, and supports processes and policies that make an Inter-Registrar Transfer and a Change of Registrant simple, safe and secure. 


At-Large support...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Rantsetse, Keolebogile
09 August 2022

Submission Summary:

I commend the Transfer Policy working group for their thoughtfulness in recommending a flexible and portable approach for the registrants to transfer their domain names from one registrar to the other. Some recommendations however raise issues such as security of domain names that need to be ironed out in the policy


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Incredible Names
09 August 2022

Submission Summary:

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 sho...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Haroon, M Omair
08 August 2022

Submission Summary:

As a domain investor, I am surprised that ICANN as the sole domain authority is keen on making investments of other domain investors including myself to be hijacked so easily with the newly proposed policy of registrar being unable to NACK a domain transfer. I feel that the new proposed policy regarding registrar being unable to NACK a domain transfer will expose a lot of investors who are constantly on the move. And expose our investments to ...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Jackson, Ron
08 August 2022

Submission Summary:

It is unfortunate that an issue of this importance that could lead to an increase in domain hijackings is being put before the public at this time of year when many are on vacation, away from (or less engaged) with their computers than they normally would be. This will be the case at least through the Labor Day weekend (I find myself among those in this position). Since it is vital that all registrants have an opportunity to receive and unders...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Johnson, David
08 August 2022

Submission Summary:

Please extend the period for public comments to mid-September. Thank you.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Domain registrant
08 August 2022

Submission Summary:

Please extend the comments deadline for submission until mid September.