[ALAC] Draft ALAC statement on IRTP-B report

[Alan Greenberg]

Sorry about the long delay in getting this out. I have not had much 
time for ICANN work this last week.

The draft version presented here is identical to that distributed to 
the ALAC during the ICANN meeting, except that there is an enlarged 
introduction and I have now incorporated some specific answers to the 
questions posed under recommendation 1. No comments were received to 
the earlier draft.

Alan

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

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.