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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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Name: Alexander Levit
Date: 16 Aug 2022
Affiliation: Dynadot
Are you providing input on behalf of another group (e.g., organization, company, government)?
Yes

If yes, please explain.

Dynadot LLC

Please choose your level of support for Preliminary Recommendation 1.
No opinion
Please choose your level of support for Preliminary Recommendation 2.
No opinion
Please choose your level of support for Preliminary Recommendation 3.
No opinion
Please choose your level of support for Preliminary Recommendation 4.
No opinion
Please choose your level of support for Preliminary Recommendation 5.
No opinion
Please choose your level of support for Preliminary Recommendation 6.
No opinion
Please choose your level of support for Preliminary Recommendation 7.
No opinion
Please choose your level of support for Preliminary Recommendation 8.
No opinion
Please choose your level of support for Preliminary Recommendation 9.
No opinion
Please choose your level of support for Preliminary Recommendation 10.
No opinion
Please choose your level of support for Preliminary Recommendation 11.
No opinion
Please choose your level of support for Preliminary Recommendation 12.
No opinion
Please choose your level of support for Preliminary Recommendation 13.
No opinion
Please choose your level of support for Preliminary Recommendation 14.
No opinion
Please choose your level of support for Preliminary Recommendation 15.
No opinion
Please choose your level of support for Preliminary Recommendation 16.
Recommendation should be deleted

If your response requires an edit or deletion of Preliminary Recommendation 16, please indicate the revised wording and rationale here.

See attached letter.

Please choose your level of support for Preliminary Recommendation 17.
Recommendation should be deleted

If your response requires an edit or deletion of Preliminary Recommendation 17, please indicate the revised wording and rationale here.

See attached letter.

Please choose your level of support for Preliminary Recommendation 18.
No opinion
Please choose your level of support for Preliminary Recommendation 19.
No opinion
Please choose your level of support for Preliminary Recommendation 20.
No opinion
Please choose your level of support for Preliminary Recommendation 21.
No opinion
Please choose your level of support for Preliminary Recommendation 22.
No opinion
Summary of Attachment

1-page comment from registrar Dynadot LLC opposing Preliminary Recommendations 16 & 17.

Summary of Submission

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 restrict users’ rights to port their digital services to competing platforms. Indeed, the Interim Report’s executive summary recognizes portability as the prime concern of the Transfer Policy:

The goal of the Transfer Policy was to provide for enhanced domain name portability, resulting in greater consumer and business choice and enabling registrants to select the Registrar that offers the best services and price for their needs.

 

At the same time, no material evidence has been offered to support the rationales listed in the Initial Report. On the contrary, ICANN compliance stated on many occasions (as far back as at least ICANN69) that the incident rate of DNS abuse as against total TLDs has been decreasing. The principle of evidence-based policy making therefore suggests that, prior to considering adopting Preliminary Recommendations 16 & 17, the following questions must be answered with significant certainty: whether the Transfer Policy meets the expectations of RNHs, whether credit card fraud is prevalent in the purchase of domain names, transfer restrictions’ effects on the integrity of ICANN’s UDRP process and the principle enabling factors of domain name theft.

 

While Dynadot recognizes the significant challenges facing RNHs victimized by domain name theft, there is no imperative to introduce policies with such deleterious effects on RNHs. Preliminary Recommendations 16 & 17 should be deleted.

 

Thank you for considering Dynadot’s comment.