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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 - Tootoosis, Tanner
07 August 2022

Submission Summary:

Please extend the public commentary period to mid-September 2022. 


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - ICANN Org
05 August 2022

Submission Summary:

ICANN org would like to thank the Transfer PDP team for its thoughtful and dedicated work in producing this report. ICANN org hopes that its review of the initial report and input provided in this form will support the Transfer PDP Working Group  as it discusses community input, and establishes its final recommendations for a successful and efficient Consensus Policy implementation. 


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Internet Commerce Association
05 August 2022

Submission Summary:

The Internet Commerce Association expresses its gratitude to the Transfer Policy Working Group for its diligent, thoughtful, and timely Interim Report. The Transfer Policy obviously presents complex issues which are challenging to navigate, and on the whole we support the Proposals made in the Interim Report. Nevertheless, we do have some significant concerns regarding particular Proposals within the Interim Report which we ask the Working Gro...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission Retracted - NameBlitz
02 August 2022
This Submission has been removed.

Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Kenyanito, Ephraim Percy
02 August 2022

Submission Summary:

At the end of June 2022, ICANN published the  ICANN Initial Report on the Transfer Policy Review - Phase 1(a), seeking input from the community.

We welcome the work of ICANN on releasing the document in line with Workstream 2 Recommendations on ICANN Transparency. The policy governs the procedure and requirements for Registrants to transfer their domain names from one Registrar to another, also referred to as an inter-Registrar tran...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - ICANN Business Constituency (BC)
02 August 2022

Submission Summary:

The ICANN Business Constituency (BC) supports all recommendations except Rec 3, and we have provided explanation for other recommendations that we have supported.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - (RySG), Registries Stakeholder Group
29 July 2022

Submission Summary:

The RySG welcomes the opportunity to provide feedback on the Initial Report on the Transfer Policy Review - Phase 1(a) and provides comments and alternative language for recommendation 8, 13 and 18.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Tucows
28 July 2022

Submission Summary:

We believe that:

- transfers should be simple (for the RNH) to perform.

- restrictions on when a domain can be transferred should be minimal.

- a transfer should not require sharing of private personal data.


We believe this can be achieved in balance with ensuring that the updated transfer policy does not make it easier to steal domain names. We thank this PDP WG for their efforts towards meeting these goals....


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Banks, Jason
01 August 2022

Submission Summary:

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.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Mugford, Brad
31 July 2022

Submission Summary:

The most valuable assets many companies own are their domain names. This is true with everyone from small end users, large corporate end users, investors, organizations, non-profits, etc.

Some of the proposed changes seem like a terrible idea when it comes to domain security. All it would do is lead to a more rampant problem with domain theft than already exists.

It would be giving an extra bag of tools to those with the most ...


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Security and Stability Advisory Committee (SSAC)
19 July 2022

Submission Summary:

SSAC2022-06: SSAC Input to the GNSO Transfer Policy Review PDP WG on DNSSEC


Submitted in lieu of completing the form.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Chang, Ted
12 July 2022

Submission Summary:

I support the change from highly restrictive 60-day locks to 30-day locks instead. Added other suggestions on security and preventing unscrupulous registrars from exploiting RNHs. Thank you.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Seaford, Edward
27 June 2022

Submission Summary:

Under Section 22, A Registrar imposed transfer away fee should be banned where their intent is arguably to deter Registrants from freely porting to a different Registrar.


Initial Report on the Transfer Policy Review - Phase 1(a) Submission - Allemann, Andrew
23 June 2022

Submission Summary:

Thank you for your work modernizing domain transfers.

I'm concerned about the decision to remove the losing registrar's Form of Authorization (FOA). With the FOA, a domain owner could be made aware of a fraudulent transfer and have time to contact the registrar to stop it. Under the proposed system, the domain registrant likely won't learn of a transfer until after the transfer is complete.

While this will make transfers easier and...