RE: [ga] Revised Registrar Data Escrow Specifications Posted

[Danny Younger <dannyyounger@xxxxxxxxx>]

Hello Chuck,

This was the portion of the document that really
bothered me:

?	"Registrars that allow registrants to register
domain names through Whois privacy or proxy services
that effectively prevent escrow of the beneficial
domain name users' contact information may optionally
include additional fields in the text file to escrow
the names, addresses, telephone/fax numbers, and email
addresses of the beneficial users."

I wrote directly to Mike Zupke, ICANN's registrar
liaison about this issue (asking why "optional"
instead of "mandatory").  He replied:

"Under the current RAA, there is no provision
requiring registrars to escrow underlying customer
data when a privacy service is the registrant.  (The
registrant - for whom data must be escrowed
- is the registrant listed in whois.)  That's
something that should be addressed in the RAA revision
process, but until it is, the Registrar
Constituency has suggested that registrars at least be
allowed to escrow such data.  Registrars have
generally expressed that they intend to take
advantage of the option to escrow underlying customer
data as many believe their customers would want it
that way.  In the short term, we will have to
come up with a way to notify registrants which
registrars are escrowing underlying customer data and
which are not so consumers can at least make an
educated decision."

I don't find Mike's response to be sufficiently
satisfying.  If anything, the underlying "real
registrant" data is that which should be escrowed.  If
we only escrow the proxy data then we will conceivably
run into real issues in the event of a registrar
calamity (think RegisterFly and their ProtectFly
service).




--- "Gomes, Chuck" <cgomes@xxxxxxxxxxxx> wrote:

> Danny,
> 
> A critical element in these specifications is the
> definition of the
> 'Registered Name Holder'.  It is my understanding
> that, in some cases
> where proxy services are used, the 'Registered Name
> Holder' may be the
> proxy service provider.  My only point is that it is
> important that
> everyone has the same understanding of what is meant
> by 'Registered Name
> Holder' and that sufficient data is escrowed to
> allow for ongoing
> registration support in case of registrar failure. 
> It is also important
> to recognize that, except in cases where the
> registrar is providing the
> proxy services directly, the proxy service provider
> probably has no
> contractual obligations to ICANN. 
> 
> Chuck Gomes
>  
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> 
> > -----Original Message-----
> > From: owner-ga@xxxxxxxxxxxxxx 
> > [mailto:owner-ga@xxxxxxxxxxxxxx] On Behalf Of
> Danny Younger
> > Sent: Monday, April 23, 2007 11:32 AM
> > To: ga@xxxxxxxxxxxxxx
> > Subject: [ga] Revised Registrar Data Escrow
> Specifications Posted
> > 
> >
>
http://regbits.info/wp-content/uploads/registrar-data-escrow-s
> > pecifications-crev3.doc
> > 
> > Comments?
> > 
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