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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: Eric Rokobauer
Date: 16 Aug 2022
Affiliation: Newfold Digital
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.

Newfold Digital's family of registrars supports comments provided by the RrSG on this recommendation

Please choose your level of support for Preliminary Recommendation 4.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 4, please indicate the revised wording and rationale here.

Newfold Digital's family of registrars supports comments provided by the RrSG on this recommendation

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.

While adding the IANA ID would be beneficial and informative, Newfold Digital does not find it necessary to be provided in everyday transfers. Having knowledge of the Gaining Registrar's IANA ID at the time of a transfer has not been a request to receive up to this point. If requested, a list of all ICANN-accredited registrars and their respective IANA IDs are already available online.

Separately, if the Gaining Registrar's IANA ID were to be provided, the obligation should be that the Losing Registrar MUST be included in the notification. There is no guarantee that the Losing Registrar would utilize this detail otherwise. 

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 intent with wording change

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

Newfold Digital's family of registrars supports comments provided by the RrSG on this recommendation

Please choose your level of support for Preliminary Recommendation 10.
Support Recommendation intent with wording change

If your response requires an edit or deletion of Preliminary Recommendation 10, please indicate the revised wording and rationale here.

Newfold Digital's family of registrars supports comments provided by the RrSG on this recommendation

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?

Newfold Digital believes the registry is best positioned and refers to comments made by RrSG in response to this question.

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.

Newfold Digital's family of registrars supports comments provided by the RrSG on this recommendation

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.
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.

We look forward to the Working Group's discussions in order to improve the transfer dispute process. If considerations made with respect to improve the process do not align to these Phase 1(a) recommendations, we would be concerned with how registrars and losing registrants respectively would be impacted if a situation arose where a transfer needs to be reversed for legitimate reasons. 

Summary of Submission

Newfold Digital appreciates the opportunity to submit comments in response to the Initial Report on the Transfer Policy Review Policy Development Process - Phase 1(a). We congratulate and thank the efforts put in by the members and leaders of this Working Group. The aspects and functionality of a domain name transfer is a crucial and integral piece for many domain owners. Working towards improving the security and efficiency of transfers will benefit registrars and registrants alike.


In general, Newfold Digital supports most recommendations as written. Where referenced in this submission, Newfold Digital refers to comments made within the RrSG's submission to improve some recommendations.