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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If your response requires an edit or deletion of Preliminary Recommendation 2, please indicate the revised wording and rationale here.
As stated by 'Andrew Allemann', a domain owner should be made aware of a fraudulent transfer and have time to contact the registrar to stop it. Lack of notification even if redundant is simply bad security.
Yes of course, having the IANA ID stated in the notifications is very important. In case of fraudulent transfers, one could easily and instantly determine the gaining registrar when investigating the fraud path. Even though WHOIS details are publicly available, not everyone will be tech savvy enough to find out where did the fraudulently transferred name go. Having more readily available information points is certainly helpful.
If your response requires an edit or deletion of Preliminary Recommendation 7, please indicate the revised wording and rationale here.
RFC 9154 and BCP 106 requires reference for further clarifications regarding the difference between current and previous RFC/BCP
If your response requires an edit or deletion of Preliminary Recommendation 13, please indicate the revised wording and rationale here.
On 13.2: The Registrar of Record MAY set the TAC to null after a period of less than 14 days, but MAY NOT set the TAC to null after a period of less than 24 hours. Rationale: This is to prevent registrars from abusing this clause and blocking users from legitimately transferring out their domain names like for example - setting TAC to null after one minute. Agreements between registrars and RNHs are never truly binding and are too easily altered by the registrars all the time, making the term "by agreement" completely pointless and useless.
If clause 13.2 is not rectified to limit losing registrar's ability to arbitrarily block legitimate transfers, then losing registrars are able to abuse and bully RNHs. As stated by 'Edward Seaford', registrars are currently able to charge arbitrary fees to prevent legitimate domain name transfers. So even if clause 22 is rectified to ban transfer away fees, affected registrars will then use clause 13.2 to indirectly withhold domain name transfers. If clauses 13.2 and 22 are not rectified as according, then it would be best to allow registrars to only have second-level management of the standard 14-day TTL, followed by registries or ICANN itself having top-level management of the standard 14-day TTL
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.