2. If your response requires an edit or deletion of Recommendation #18, please indicate the revised wording and rationale here.

Recommendation 18 was presented as Preliminary Recommendation 17 in the WG's initial Group 1(a) recommendations and purported to remedy problems related to: the failure of the Transfer Policy to meet the expectations of RNHs, credit card fraud and domain name theft in registrars' operations, and gaps in the integrity of the UDRP process. No empirical evidence was presented to support the existence of these problems. In its comment to the initial report, Dynadot requested that the WG obtain evidence sufficient to demonstrate that these problems are material enough to support changes to the Transfer Policy that contradict its very purpose, which is identified in its preamble as the imperative to enhance domain name portability and transferability between registrars. The amended Group1(a) recommendations again present no empirical evidence to support these assertions. Legislators across the world are proposing legislation aimed at discouraging market practices that restrict users’ rights to port their digital services among competing platforms. Adopting Recommendation 18 would result in the ICANN model adopting a policy that runs counter to global legislators' imperatives, and to boot it will be in the absence of a balancing of any evidence showing the value the industry gained by the transfer restriction as against the value lost by it. Although Dynadot supports the carveout provided for a subset of registrants whose circumstances meet the requirements for removal of the lock, it notes that even a qualified transfer restriction requires evidence supporting departure from the default position that a registrant would find herself absent adoption of this recommendation at all. In the absence of supporting evidence, policies that contradict the very purpose of the Transfer Policy should be deleted. Thank you for considering Dynadot’s comment.