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: Ephraim Percy Kenyanito
Date: 2 Aug 2022
Affiliation: ARTICLE 19
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Yes

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ARTICLE 19

Summary of Attachment

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 transfer. Our analysis shows that, primarily, the document contains several positive and commendable provisions, such as those related to ensuring that Registrants have the ability to easily transfer domains between Registrars.  

We also welcome the updates to terms that have been made to ensure that terms are easily understandable by Registrants and also welcome the implementation of data protection provisions through the Transfer Policy. 

ARTICLE 19 notes that this Policy process is the first step toward a review of the Transfer Policy. We look forward to the next two processes including:

Phase 1(b): Change of Registrant (including EPDP Phase 1, Recommendation 27, Wave 1 Change of Registrant issues).

Phase 2: Transfer Emergency Action Contact and reversing inter-Registrar transfers, Transfer Dispute Resolution Policy (including EPDP Phase 1, Recommendation 27, Wave 1 TDRP issues), ICANN-approved transfers.

ARTICLE 19, therefore, urges ICANN to consider the recommendations below, which would help align the ICANN Status ICANN Initial Report on the Transfer Policy Review - Phase 1(a) more closely with international law and best practice.

Summary of Submission

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 transfer. Our analysis shows that, primarily, the document contains several positive and commendable provisions, such as those related to ensuring that Registrants have the ability to easily transfer domains between Registrars.  

We also welcome the updates to terms that have been made to ensure that terms are easily understandable by Registrants and also welcome the implementation of data protection provisions through the Transfer Policy. 

ARTICLE 19 notes that this Policy process is the first step toward a review of the Transfer Policy. We look forward to the next two processes including:

Phase 1(b): Change of Registrant (including EPDP Phase 1, Recommendation 27, Wave 1 Change of Registrant issues).

Phase 2: Transfer Emergency Action Contact and reversing inter-Registrar transfers, Transfer Dispute Resolution Policy (including EPDP Phase 1, Recommendation 27, Wave 1 TDRP issues), ICANN-approved transfers.

ARTICLE 19, therefore, urges ICANN to consider the recommendations below, which would help align the ICANN Status ICANN Initial Report on the Transfer Policy Review - Phase 1(a) more closely with international law and best practice.