Meditations on Domain Name Transfers: Final Call for Comments To ICANN

Today I submitted comments on behalf of my company (Leap of Faith Financial Services Inc.) to ICANN regarding proposed changes to domain name transfer policy. You can read those comments in this PDF, or at ICANN’s public comment forum along with those of others such as the Internet Commerce Association. If you’d like to submit your own comments, the deadline is Tuesday August 16, 2022 at 23:59 UTC.

I’ve written multiple blog posts in the past few weeks, warning about the negative ramifications should their recommendations be adopted. See here, here, here, here and here for those past articles on the topic.

The comment submission reiterates and expands on those past articles. I also took a deep dive into each of the recommendations. It was a considerable effort (at least 40 hours, if not more) in a compressed time frame. It was truly stressful given the deadline would not be extended to mid-September (or beyond) as requested, to be a more reasonable schedule for the amount of work involved. As I note on page 5 of the submission, I could have used more time to reorganize, restructure and condense the material (which amounts to 60 pages!). Consider this a “draft” that wasn’t intended for publication, but is as good as it’s going to get in the time that was provided.

As I note in the conclusion, the most important section is Section E (generate a transaction ID at the gaining registrar, to input at the losing registrar; this way, we can eliminate the TAC). Also, retaining the “Losing FOA” (Section F), at least on an opt-in basis, to preserve the ability to ACK/NACK a pending transfer is critical. Those are the two big counterproposals, although lots of other stuff was important and needed to be said.

The unbalanced nature of the working group composition (registrars dominating) should concern everyone, as registrants’ interests are not being protected.