Re: [dow3tf] TF3 â Revised Proposal prepared by IPC representatives

[sarah.b.deutsch@xxxxxxxxxxx]

I've received the following questions and comments thus far from various BC
members about the proposal.   I look forward to discussing these issues on
our next call, or beforehand by email:


1.  The process appears oriented toward individual registrants rather than
companies or other organizations.  E.g., the mention of a driver's license
or utility bill as proof of identity.

2.  The phrase "the domain name may be placed immediately on hold" is
unclear.  Does it mean that the domain name may not be transferred by the
registrant, that the domain name will be removed from the DNS (deleted from
the TLD Registry's name servers), or something else?

3.  The option to place a domain name on hold based on the failure to
confirm just one of the first two contact methods attempted might be
extreme, again depending on the meaning of "hold."

4.  A 15 day time frame for the registrant to respond may be too short.  An
individual registrant may be on a two week vacation, for example.  Once
again, the meaning of "hold" influences the significance of this concern.

5.  If "hold" simply means suspend transfer capability, what are the next
steps to remove the domain name from the DNS?

6. What is the period of the hold?   Can the registrar "hold" the domain
till it is scheduled to expire or do they release it back to the pool after
a period of time?


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




                                                                                                                           
                      "Brian Darville"                                                                                     
                      <BDARVILLE@oblon.        To:       dow3tf@xxxxxxxxxxxxxx                                             
                      com>                     cc:       gnso.secretariat@xxxxxxxxxxxxxx, roseman@xxxxxxxxx,               
                      Sent by:                  Bruce.Tonkin@xxxxxxxxxxxxxxxxxx                                            
                      owner-dow3tf@gnso        Subject:  [dow3tf] TF3 â Revised Proposal prepared by IPC representatives   
                      .icann.org                                                                                           
                                                                                                                           
                                                                                                                           
                      10/27/2004 09:32                                                                                     
                      AM                                                                                                   
                                                                                                                           
                                                                                                                           




Set forth below is a revised proposal prepared by representatives of the
IPC after a telephone conference yesterday between Bruce Tonkin, Ross
Rader, Steve Metalitz (IPC), Ryan Lehning (IPC) and myself.  As I
understand it, Ross may be preparing a revision to paragraph C in the
following proposal.  We will discuss this proposal on today's call.

Here is the revised proposal:

I. Steps to Verify & Correct Inaccuracy in Response to a Complaint

A.           1.  If a registrar receives a complaint about the accuracy of
registrant data through the Whois Data Problems Reporting System, that
registrar shall take reasonable steps to verify the accuracy of that
data by contacting the registrant through at least two of the following
four methods: 1) email; 2) telephone number; 3) facsimile number; or 4)
postal mail.

                         2. If one method fails (e.g., email bounce-back;
telephone or fax disconnected; or a return to sender message), the
domain name may be placed immediately on hold; or, another method shall
be used.  If both of the two pursued methods fail, registrar shall place
the domain name on hold.  If a pursued method does not fail, registrar
must allow the registrant 15 days to respond with accurate information.
If it is apparent at any point in the process that a registrant has
willfully provided inaccurate contact data, a registrar may immediately
place the domain name on hold without first attempting to (further)
contact the registrant.

B. If a registrant responds to registrar notifications of inaccuracy
within the 15 day time limit, providing updated data, registrar shall
verify the accuracy of at least one of the following three updated data
elements: 1) email; 2) telephone number; or 3) facsimile number.
Verification may consist of the registrar using the updated data to
effectively contact the registrant, confirming the registrant's
correction of its contact data or by requesting that the registrant
provide the registrar with "proof of authenticity" of the contact
information (e.g., a photocopy of a driver's license or a utility bill).
If one element remains inaccurate, registrar may place the domain name
on hold. If one element is accurate, registrar shall verify the second
element.  If both elements remain inaccurate, registrar may place the
domain name on hold or verify the third element.  If the contact
information remains inaccurate or unverified, the registrar shall place
the domain name on hold.

C. Registrars shall make their customers aware of the Whois Data
Problems Reporting System as the means for bringing complaints with
respect to Whois data. [Language to be proposed by Ross Rader for
publicizing the WDPRS in advance of its use as the sole avenue for
making complaints about Whois data].