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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: Owen Smigelski
Date: 16 Aug 2022
Affiliation: Namecheap
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 intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 3, please indicate the revised wording and rationale here.

Namecheap notes that the recommendation refers to the registered name holder (RNH) obtaining the TAC, however for domain names that utilize Privacy/Proxy services, it is possible that the underlying customer may obtain the TAC rather than the RNH. Namecheap notes that according to Section 1.3 of the Specification on Privacy and Proxy Registrations of the 2013 RAA, a Proxy Service is considered the RNH and licenses use of the domain name to the customer. It is impractical for a Proxy Provider to obtain TACs on behalf of customers, and this recommendation should be updated to accommodate Privacy/Proxy service customers.

Please choose your level of support for Preliminary Recommendation 4.
Support Recommendation as written
Question to the community: Should the Gaining Registrar’s IANA ID be provided by the Registry Operator to the Losing Registrar so that it may be included in the Notification of Transfer Completion sent by the Losing Registrar to the Registered Name Holder? Why or why not? Please explain.

Yes, Namecheap prefers that the Gaining Registrar’s IANA ID be provided by the Registry Operator to the Losing Registrar in the Notification of Transfer Completion.

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 intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 7, please indicate the revised wording and rationale here.

Namecheap believes that any additional information in the TAC (such as IANA ID) would be excessive. If the gaining registrar provides the TAC to the registry, and the TAC is validated, there is no need to build the IANA ID into the TAC. This additional information could require significant software and infrastructure development, and would not necessarily result in additional security that would justify such development efforts.

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 intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 9, please indicate the revised wording and rationale here.

Namecheap believes that Recommendation 9.2 should be made future proof. It only references the current RFC, and should be updated to reference future RFCs. This can be in the form of “at least according to the minimum standard set forth in RFC 9154 (or its successors)”.

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
Question to the community: Who is best positioned to manage the standard 14-day TTL – the Registry or the Registrar, and why? Are there specific implications if the TTL is managed by the Losing Registrar?

The registry is in the best position to manage the TTL. If this is done by the registrars, each registrar will have to create systems and processes to manage the TTL, whereas a registry can accomplish this for all domains within a gTLD. It is more efficient to do this at the registry rather than at thousands of registrars. 

Please choose your level of support for Preliminary Recommendation 14.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 14, please indicate the revised wording and rationale here.

The current wording in the Recommendation does not apply properly to domain names that are registered using Privacy/Proxy services- which have data present in the RDDS, but also underlying (masked) customer data. This Recommendation should be clarified to distinguish between the public and underlying data.

Please choose your level of support for Preliminary Recommendation 15.
Support Recommendation as written
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.

Namecheap does not support any restrictions on the RNH to transfer the domain name to a new registrar at any time after initial registration or an inter-registrar transfer. While Namecheap understands the argument that a 30-day lock may prevent some hijacking, a legitimate user should not be penalized for the behavior of some bad actors. In addition, nothing prevents bad actors from using the domains for nefarious purposes with the registrar of record or for eventually hijacking a domain name (for example waiting until the expiration of a 30-day lock period, taking control of a registrant’s account with the registrar, etc). Finally, the proposed 30-day lock does not prevent the issue of credit card chargebacks, as those can be filed within 6 months after a purchase.

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.

Same comment as Recommendation #16

Please choose your level of support for Preliminary Recommendation 18.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 19.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 20.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 21.
Support Recommendation as written
Please choose your level of support for Preliminary Recommendation 22.
Support Recommendation as written
Are there any recommendations the Working Group has not considered? If yes, please provide details below.

N/A

Are there any other comments or issues you would like to raise pertaining to the Initial Report? If yes, please enter your comments here. If applicable, please specify the section or page number in the Initial Report to which your comments refer.

N/A

Summary of Submission

Namecheap submits these comments in response to the Initial Report on the Transfer Policy Review Policy Development Process - Phase 1(a). Namecheap appreciates the opportunity to provide feedback to this policy initiative, which will have significant impact on registrants and registrars. The proposed recommendations will improve the transfer process from a registrant perspective, while additionally improving security of domain name transfers.

Namecheap generally supports the recommendations, except as noted in this submission. Namecheap additionally thanks the working group and leadership team for the efforts.