AT-LARGE GATEWAY
At-Large Regional Policy Engagement Program (ARPEP)
At-Large Review Implementation Plan Development
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DRAFT ALAC Statement on Fake Renewal Notices Report
The ALAC strongly supports immediate action being taken on this issue. The problem has been around for a long time, it has been much discussed, but until this report, no action has been taken.
This problem, although relatively minor compared to some that ICANN and the GNSO must consider, is symbolic of ICANN’s perceived inability to ensure a safe and trusted Domain Name space. Virtually all parties have agreed the Fake Renewal Notice issue is bad, yet we have been unable, or unwilling to take any sort of action to stop it.
ICANN and the GNSO should take this token issue and use it to demonstrate that it can indeed enact change swiftly when it is warranted.
With respect to the potential next steps identified in the Drafting Team (DT) Report:
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1 Add a section to the RAA that addresses Business Practices
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The ALAC rejects this alternative on two grounds:
- It would not take effect for up to five years
- Given the pressure to complete the current round of RAA discussions, it is unlikely that this issue could be included and addressed without delaying the current process – a result that many would consider totally unacceptable.
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2. Add the issue to the current or one of the upcoming IRTP PDPs
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The ALAC would consider it acceptable to add this issue to the current IRTP C PDP, but questions whether this is possible given that it was not included in the Issue Report leading to this PDP.
Adding this issue to the next IRTP D PDP is certainly possible, but the delay before even starting would be considerable. IRTP C is currently scheduled to report to the GNSO Council in October 2012. Even assuming no delays, given the lengthy process associated with GNSO approval and then starting the next IRTP PDP, the new one might optimistically start early in 2013.
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3. Add the issue to the upcoming RAA PDP
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Again, this is possible, but it would be one small item in a large and potentially complicated PDP. It is impossible to estimate how long that PDP would take, again delaying this issue indeterminably.
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4. Refer the issue to the ALAC to encourage better education and awareness
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The ALAC is neither funded nor staffed to undertake such a project. Although At-Large is certainly willing to take the issue and widely disseminate such warnings, any more active action is not possible, and in any case would not likely have the penetration to be even partially successful. As such, the ALAC would be willing to participate in any education and awareness program (regardless of how the overall problem is addressed), it cannot be the main method of addressing the problem.
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5. Raise the issue with the Federal Trade Commission in the US
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Although this may well address an issue with a particular Registrar as long as they are located in the US, it does not seem to be a very robust solution to the problem.
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Alternative Approach
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The ALAC does offer one other alternative that it believes should be carefully considered. Alternative 1, the DT’s preferred approach, is to draft a clause, perhaps patterned after RAA 3.7.3. In fact the DT even goes so far as to try a first draft of the needed clause. The ALAC suggests a dedicated PDP for the Fake Renewal Notice Issue. Although the concept of a PDP seems onerous, if the possible solution is anywhere near as simple as the DT suggests in their preferred solution, such a PDP would require a very minimal amount of work. It would admittedly take about nine months, the minimum estimated elapsed time for the complete PDP process, but the actual staff and volunteer effort would be minimal.
As an alternative, less onerous but still acceptable approach, the current RAA allows the GNSO Council to approve Consensus Policy simply by a 2/3 majority vote, the GNSO could request that a Drafting team including Registrar participants draft suitable language for the RAA for approval by the GNSO.
By taking either such action, the GNSO would demonstrate that it CAN act quickly when required and the situation allows it. Demonstrating that it is not bound by rules that always take several years to set formal any, even minimal, Consensus Policy would send a VERY good and important message to the community.
DRAFT ALAC Statement on Fake Renewal Notices Report - Replaced 10 April 2012
The ALAC supports immediate action being taken on this issue. The problem has been around for a long time, it has been much discussed, but until this report, no action has been taken.
...
With respect to the potential next steps identified in the Drafting Team (DT) Report:
...
1 Add a section to the RAA that addresses Business Practices
...
The ALAC rejects this alternative on two grounds:
...
- Given the pressure to complete the current round of RAA discussions, it is unlikely that this issue could be included and addressed without delaying the current process – a result that many would consider totally unacceptable.
...
2. Add the issue to the current or one of the upcoming IRTP PDPs
...
The ALAC would consider it acceptable to add this issue to the current IRTP C PDP, but questions whether this is possible given that it was not included in the Issue Report leading to this PDP.
Adding this issue to the next IRTP D PDP is certainly possible, but the delay before even starting would be considerable. IRTP C is currently scheduled to report to the GNSO Council in October 2012. Even assuming no delays, given the lengthy process associated with GNSO approval and then starting the next IRTP PDP, the new one might optimistically start early in 2013.
...
3. Add the issue to the upcoming RAA PDP
...
Again, this is possible, but it would be one small item in a large and potentially complicated PDP. It is impossible to estimate how long that PDP would take, again delaying this issue indeterminably.
...
4. Refer the issue to the ALAC to encourage better education and awareness
...
The ALAC is neither funded nor staffed to undertake such a project. Although At-Large is certainly willing to take the issue and widely disseminate such warnings, any more active action is not possible, and in any case would not likely have the penetration to be even partially successful.
...
5. Raise the issue with the Federal Trade Commission in the US
...
Although this may well address an issue with a particular Registrar as long as they are located in the US, it does not seem to be a very robust solution to the problem.
...
Alternative Approach
...
The ALAC does offer one other alternative that it believes should be carefully considered. Alternative 1, the DT’s preferred approach, is to draft a clause, perhaps patterned after RAA 3.7.3. In fact the DT even goes so far as to try a first draft of the needed clause. The ALAC suggests a dedicated PDP for the Fake Renewal Notice Issue. Although the concept of a PDP seems onerous, if the possible solution is anywhere near as simple as the DT suggests in their preferred solution, such a PDP would require a very minimal amount of work. It would admittedly take about nine months, the minimum estimated elapsed time for the complete PDP process, but the actual staff and volunteer effort would be minimal.
By taking such action, the GNSO would demonstrate that it CAN act quickly when required and the situation allows it. Demonstrating that it is not bound by rules that always take several years to set formal any, even minimal, Consensus Policy would send a VERY good and important message to the community.
