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Re: [ga] Advisory: Availability of Bulk Transfers in Individual gTLDs

  • To: Marika Konings <marika.konings@xxxxxxxxx>, Accountability Headquarters <ga@xxxxxxxxxxxxxx>
  • Subject: Re: [ga] Advisory: Availability of Bulk Transfers in Individual gTLDs
  • From: Andy Gardner <andy@xxxxxxxxxxxxxxx>
  • Date: Thu, 8 Oct 2009 14:18:44 -0500



Thank you Marika.

On reading that document I can find no language that prevents the gaining Registrar "accidentally" obtaining the losing Registrar's entire historical customer list, including customers who no longer have an active relationship with the losing registrar.

As many of the recent losing Registrar's appear to have been boutique registrars set up mainly for organisations like Snapnames to game the deletion process, where Registrants likely transfer the names out 60 days after registration, it could be that 90% of the losing Registrar's customer database is no longer active.

When is the next periodic review of the "effectiveness of this De‐ Accredited Registrar Transition Procedure" going to take place?

When it does take place, I ask that you review the transfer of customer data to Directi in previous instances and ascertain whether they obtained ex-customer data, and what they used that data for. Please pay attention to Directi's "ResellerCLub" and emails sent from them to ex-custoemrs of losing Registrars.

I know of at least one ex-customer who was signed onto Directi's "Reseller Club" without ever having signed any agreement or contract.

Such evidence was emailed to zupke@xxxxxxxxx, but no reply or explanation was forthcoming - which is suspicious in itself.

Regards,




On Oct 8, 2009, at 9:21 AM, Marika Konings wrote:

Andy, when a registrar fails, ICANN gathers all possible data to protect registrants. More details about those efforts are published in ICANN’s De-Accredited Registrar Transition Procedure, which is posted at: http://www.icann.org/en/processes/registrars/de-accredited-registrar-transition-procedure-01oct08.pdf .

With best regards,

Marika

On 06/10/09 09:55, "Andy Gardner" <andy@xxxxxxxxxxxxxxx> wrote:




Hi Marika,

When an ex-Registrar's customer database is passed on to the gaining
Registrar, do you just hand the whole thing over, or do you strip out
the data belonging to old customers who no longer have names registered?

I ask this because when databases were handed over to Directi in the
past, it appeared that they then used that information to spam old
customers of the ex-Registrar.

That's not good.

Regards,

On Oct 6, 2009, at 2:12 AM, Marika Konings wrote:

> Danny, in response to your first question, the advisory is the
> implementation of one of the recommendations made by the Inter-
> Registrar Transfer Policy Part A PDP Working Group. This
> recommendation was adopted by the GNSO Council in its resolution
> 20090416-2: the GNSO Council ‘Recommends that ICANN staff
> communicate to registries and registrars that the current bulk
> transfer provisions do apply to cases requiring the transfer of all
> names in one single gTLD under management of a registrar’. For
> further information, please see the IRTP Part A PDP Final Report on http://gnso.icann.org/issues/transfers/irtp-final-report-a-19mar09.pdf
> .
>







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