[registrars] Registrar Constituency Input re: Best Practices
On May 4 I submitted substantial comments regarding the then current draft of the best practices (http://gnso.icann.org/mailing-lists/archives/dow3tf/msg00167.html). It is now May 17 and I have not heard nor seen any discussion of this submission or any comments on it from any other member of this task force. For the record, I reiterate them here and request that we discuss them during our regularly scheduled call tomorrow. Section 1 - This clause forces substantial and inappropriate liability on registrars. Inclusion of the language included in the redline I submitted on May 4 is not acceptable to the Registrar Constituency. Striking this language will be key if the Task Force wishes to have Registrar Constituency's support of their recommendations. Section 2 - These recommendations are wholly out of scope for both this task force and the GNSO. Section 3 - This recommendation inappropriately limits the scope of consideration by the GNSO. This is unlikely to supported by the GNSO Council and should be replaced by the original text that was proposed by the Registrar Constituency. Section 4 - Specific recommendations regarding the inclusion of various whois data elements is out of scope for this task force. For the third time I reiterate my objection to their inclusion in this document. Section 5 - See my comments on Section 1.Section 6 - Again this requirement is out of scope for the GNSO and if implemented with negatively impact competition by limiting the manner by which registrars currently offer these services on a free market basis. Section 7 - This section is redundant and simply restates the requirements of the policy development process. I am at somewhat of a loss as to how we should proceed with this. No commentary on these very important issues over the past two weeks indicates to me that either a) this task force is dealing with a foregone conclusion that would be better dealt with at a council level or b) we no longer have the committment of the task force membership required to fulfill our obligations to the Council. I sincerely hope that neither is the case. Making solid progress on these points during tomorrow's call would definitely put me in a more positive frame of mind regarding our chance of success as a Task Force.
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-rwr
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