ALAC - Statement on the Inter-Registrar Transfer Policy Part B Working Group Proposed Final Report - March 2011

The public comment announcement is available at: Inter-Registrar Transfer Policy Part B Working Group Proposed Final Report 

----ALAC Statement on the Inter-Registrar Transfer Policy Part B Working Group Proposed Final Report - DRAFT

The ALAC supports all of the recommendations in the Inter-Registrar Transfer Policy Part B Working Group Proposed Final Report.

Individuals who register domain names are arguably the registrants who are most vulnerable to problems being addressed in this PDP. They often have little technical or domain-industry knowledge and are ill-prepared to deal with hijacking or the subtleties of domain name transfer.

 Moreover, the ALAC has specific comments on two of the recommendations:

 Recommendation 1.

 The ALAC strongly supports the Emergency Action Channel. With regard to the specific questions, we offer the following comments on several of the questions:

 - Within what timeframe should a response be received after an issue has been raised through the Emergency Action Channel (for example, 24 hours - 3 days has been the range discussed by the WG)?

>As a prime use of the Emergency Action Channel is to reverse domain hijacking, we support as short a period as practical. The target should be well under 24 hours.

 - What qualifies as 'a response'? Is an auto-response sufficient?

An automated response is not considered acceptable as it eliminates the intent of establishing communications between the registrars.

- Should there be any consequences when a response is not received within the required timeframe?

The Emergency Action Channel would have no meaning if there were not consequences to no response.  Consequences should include a provision for the registry unilaterally reversing the transfer and possibly fines.

- Is there a limited time following a transfer during which the Emergency Action Channel can be used?

We support a reasonably long period but have no specific suggestion. We defer to the registrars who regularly must respond to hijacking as to what time period they find acceptable.

Who is entitled to make use of the Emergency Action Channel?

The Emergency Action Channel may be useful for a number of registrar issues. Those are likely outside the scope of this PDP, but other uses should not be precluded.

 Recommendation 2.

The ALAC supports the concept of increased and improved registrant education. Although it is not clear that the ALAC should be designated as the prime channel for such activities, it may be considered one of the possible channels, factoring in the limited ICANN budget at its disposal for such activities and the limited control over volunteer time that it exercises.