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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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  • English

Name: Sophie Hey
Date: 15 Aug 2022
Affiliation: Com Laude
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.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 2.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 3.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 4.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 5.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 6.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 7.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 8.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 9.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 10.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 11.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 12.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 13.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 14.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 15.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 16.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 17.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 18.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 19.
Significant change required: changing intent and wording

If your response requires an edit or deletion of Preliminary Recommendation 19, please indicate the revised wording and rationale here.

Edit: Strike “evidence of fraud” from I.A.3.7.1 (retain proposed language: violation of the Registrar’s domain use or anti-abuse policies) Rationale: Propose moving evidence of fraud part of the recommendation to a reason that a Registrar of Record must deny a transfer. The language for violating the domain use or anti-abuse policy should remain

Please choose your level of support for Preliminary Recommendation 20.
Significant change required: changing intent and wording

If your response requires an edit or deletion of Preliminary Recommendation 20, please indicate the revised wording and rationale here.

Add: I.A.3.8.6 The Registrar of Record has credible evidence of fraud Rationale: Fraud is one example of an abusive activity that registrars must prohibit in their Registration Agreement with Registrants. This language is intended to further empower registrars to deny transfers for abusive behaviour, while also ensuring that the registrar has evidence of the abusive behaviour.

Please choose your level of support for Preliminary Recommendation 21.
Significant change required: changing intent and wording

If your response requires an edit or deletion of Preliminary Recommendation 21, please indicate the revised wording and rationale here.

Add: 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. Rationale: This language is intended to further empower registrars to deny transfers for abusive behaviour, while also ensuring that the registrar has evidence of the abusive behaviour.

Please choose your level of support for Preliminary Recommendation 22.
Support Recommendation as written
Summary of Submission

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.