I commented in another email just sent to the list that people might be
better off focusing their energies on real 'here-and-now' issues, rather
than speculating on hypotheticals.

Speaking of here-and-now issues, how's everyone going with their review and
comments on auDA's draft document for transfers of 'Registrar of Record'
which is available at http://www.auda.org.au/docs/auda-transfers-draft.pdf??

This is a significant issue that affects:

* All would be Registrars - and the document appears to make attempts to
minimise the actions of unscrupulous Registrars / Re-sellers, which alone
should make it worthy of scrutiny to all those on the list who've been
commenting on such issues
* All would be Registrants

and will affect them from the day of the introduction of competition - i.e.
long before any new 2LD proposals are evaluated.

This is a major issue, and the closing date for feedback on the draft is
Monday 29 April - two days away.  So how's everyone's evaluation going??



I can say that a colleague and I spent the better part of Friday afternoon
trying to analyse the document, and work out:

* what it was trying to do in each section
* what the actual effect would be of the proposed solutions
* what the 'best' solution would be in each part


To be honest, I, at least, didn't find it easy to get a really good
understanding of all of the above, and it was rather an intellectual
struggle before I (and I think my colleague) were comfortable we really had
a good feel for the implications.



It would be cruel of me to point out (so I won't) that if it was an
intellectual struggle for my colleague and I, then some of those on this
listserver - based on the quality of their postings - have no chance.



I'm still trying to document my thoughts on the draft Registrar of Record
Transfer procedure, but here's a quick summary just to get the discussion
going:

* The document is unclear and imprecise in many areas and doesn't properly
set out the objective it trying for, and the proposals its making to attempt
to meet that objective.  This makes it difficult to provide meaningful
feedback.

For example, some parts appear to be trying to deal with the problem of
unscrupulous Registrars/Resellers (i.e. 3.2 b) and other parts with
unscrupulous impersonators of Registrants (i.e. 4.1b).  But since the
reasoning / objective of these points isn't stated, that makes it difficult
to recommend a better solution to achieve the objective.

* The document needs some clarification to ensure it doesn't directly
conflict with policy developed by the Policy Review Panels.  For example,
4.1 c requires eligibility checking, while the Name Policy panel supported
'grandfathering' at renewal time (otherwise many existing domain names
couldn't be renewed, causing all sorts of problems to those entities using
those domains for web sites / email addresses, etc.

* Overall, the document is acceptable as a rough first draft, but nowhere
close to being a finished document.

* Despite my view that the document overall rates as unsatisfactory, I
believe that Section 3.2 b, which states:

  "the registrant must renew their domain name licence when the transfer
takes
  place (i.e.. the registrant receives a new 2 year domain name licence from
the
  gaining registrar)."

is a stroke of minor genius, and I commend whoever thought of it.  I'm still
not quite sure I've worked thru all the implications of this (so I'm
reserving my opinion just a tad), but so far the more I think about it the
more impressed I am and I take my hat off to the author of this clause.

There, that shows I can throw bouquets as well as brickbats!


If you think about the implications of Section 3.2 b,  I think you come to
the realisation that it actually makes the whole document obsolete.  i.e. if
Section 3.2 b is going to be the way changes of Registrar of Record are
done, then the whole concept of having a separate Registrars Transfers
Policy becomes pretty silly.  I'm sure y'all will work out why! :)



I'll leave it there for now - and try and get my thoughts / comments sorted
out better and in more detail :)



Regards, Mark

Mark Hughes
Effective Business Applications Pty Ltd
effectivebusiness§pplications.com.au
www.pplications.com.au
+61 4 1374 3959
























Regards, Mark

Mark Hughes
Effective Business Applications Pty Ltd
effectivebusiness§pplications.com.au
www.pplications.com.au
+61 4 1374 3959