Re: [dow3tf] Vote on Preliminary Report

[sarah.b.deutsch@xxxxxxxxxxx]

The BC votes in support of the Best Practices section of the Preliminary
Report in the overall interest, at this late date, of moving a preliminary
report forward for public comment.  This vote is cast, however, with some
reservations, which do not affect our general support to place the
preliminary report for open, public comment.

In particular, we are troubled by the level of detail in Item 8, which
recommends that a domain name be put on hold for a period of 15 days and
requires that the domain name be cancelled if the registrant fails to
correct the registration within that time frame.  We question whether the
report should be dictating any specific time frames at this stage and
serious consideration must be given into whether the 15 day strict
cancellation policy can be reasonably implemented.

In item 10, requiring that a domain name registration be cancelled or
suspended, etc. for
false contact data, along with all other registrations with identical
contact data, needs additional clarification.  This suggestion requires
further study into how it can be reasonably implemented without imposing
strict monitoring obligations on registrars or imposing undue costs on any
stakeholder.

On behalf of the BC, I'd like to acknowledge everyone's hard work on these
difficult issues. We look forward to working with you all, as always, in a
constructive manner as we strive toward reaching consensus policy.

Sarah


Sarah B. Deutsch
Vice President & Associate General Counsel
Verizon Communications
Phone: 703-351-3044
Fax:      703-351-3670
sarah.b.deutsch@xxxxxxxxxxx