[ALAC] IRTP C

[Alan Greenberg]

I was asked to review the Initial Report of the Inter-Registrar 
Transfer Policy Part C PDP WG, and recommend whether the ALAC should 
comment on it, and if so, to draft a comment.

The call for comments can be found at 
http://www.icann.org/en/news/public-comment/irtp-c-initial-report-04jun12-en.htm 
and the Interim Report at English version of the report can be found 
at 
http://gnso.icann.org/issues/transfers/irtp-c-initial-report-04jun12-en.pdf 
(other languages at first link).

The Inter-Registrar Transfer Policy (IRTP) is primarily focused on 
the transfer of a registered domain name from one registrar to 
another. However, at the time of Registrar Transfer, there is often 
also a change of who the registrant is, yet the IRTP is silent on any 
aspect of that. Since transfers of this sort are often associated 
with domain hijacking, it should certainly be of concern to At-Large and ALAC.

The PDP is also looking at a number of other aspects of IRTP 
including how Registrars are identified (currently some registries 
use proprietary identifications).

I strongly recommend that the ALAC comment on this report and my 
draft comment follows. The initial comment period closes on July 5th.

Alan

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The ALAC supports the general direction that the IRTP C PDP WG is 
heading. Specifically, the ALAC strongly supports all measures the 
will reduce the possibility of domain hijacking while still providing 
legitimate registrants the ability to change registrars.

The ALAC similarly supports all efforts to formally define the 
process by which the registrant of record can be changed, with 
implicit safeguards to inhibit hijacking. The ALAC does not have 
strong views as to whether this needs to be a separate consensus 
policy of not, but the overall results and benefits to registrants 
should not be diminished by this decision.

The ALAC supports the requirement to have all gTLDs use the IANA 
Registrar IDs (in addition to any proprietary ones if desired).

Lastly, the report could benefit from a clearer overview describing 
the change of registrar and registrant processes.