[registrars] Please Respond: Expiry and Create dates in OPoC

[Tim Ruiz <tim@xxxxxxxxxxx>]

All,

As I stated in the meeting on Tuesday, I am concerned with the removal
of the registry whois create and expiry dates.
 
Our experience has been that a number of registrants use that
information as part of their name management. The reason may be that
the registry whois is more reliable, easier to query, whatever. And as
you know, there are a number of popular software products and web based
services that are available for name management, or that provide other
services, that rely on the registry Whois. These will all become broken
once the dates are removed from the registry Whois.

One registrant use for that information that I think has merit is
keeping the registrar honest so to speak. Many registrants know that
what may appear in the registrar whois does not necessarily reflect
what has actually taken place. For example, if you pay for a multi-year
renewal is the registrar putting them through one year at a time, or all
together? 
 
Registrars may also use that information in legitimate ways to make
transfers less problematic for their customers, but I'll admit that
this is a convenience not a necessity. Still, it should be given some
consideration.
 
I think that if the OPoC concept does become policy, some time needs to
be given to see how it works, how it is enforced, how it is received by
registrants, etc. Then we can consider taking it further by removing the
dates from the registry if it becomes necessary. But to remove these
dates at the same time as the implementation of the OPoC concept will
just serve to further confuse registrants, software developers, and web
service providers who have relied on that data for lawful purposes.
 
I am aware of two arguments for removing it from the registry whois. 
 
1. Renewal slamming. But as I've said in the past, removing the registry
dates is not the real solution to this problem. The bad guys are going
to find a way, especially since the worse offenders are often
registrars themselves. 
 
2. The inconsistent expiry dates between registrars and registries due
to the Auto-Renew Grace Period. This can be fixed without removing the
dates, and perhaps a solution could be included as at least advice in
the OPoC proposal.

Based on these concerns I would like suggest the following changes to
OPoC proposal be supported by Registrars:

1. Include the following elements in The Type of Contact Data Published
by Registries;
 -- The date of the initial registration of the domain name (creation
date)
 -- The date of the expiration of the current term of the domain name
(expiry date)

NOTE: I believe these are in the current iteration of the OPoC as
*Proposed.*

2. Include a recommendation that Registries be required to not advance
the expiration date until the end of the Auto-Renew Grace Period unless
the Registrar explicitly renews the domain name.

NOTE: I am not asking that we recommend that Registries not deduct the
renewal fee at the start of Auto-Renew Grace Period. That has other
implications and I am sure Registries would consider that out-of-scope
of the TF's TOR.

If you support the above suggested changes to the OPoC I would
appreciate you're saying so on this list or directly to our Whois TF
reps - Ross Rader, Paul Stahura, Tom Keller, and myself (I am an
alternate rep). The TF's initial report is already in progress so it
would be helpful to gauge support sooner than later. Perhaps we can at
least get these views in as a minority opinion.


Tim