[Gnso-ppsai-pdp-wg] Obligation to Respond to Inquiries

Thu May 15 01:07:35 UTC 2014

Steve

Under the IRTP we were focused on situations like the hijacking of a domain name such as Google.com or Amazon.com. We discussed a variety of scenarios at length and spent quite a lot of time deliberating over what exactly constituted an emergency and if such a concept would be restricted to only some domain names. The example of Google.com or Amazon.com are purely illustrative, as the "harm" in changing their DNS is pretty easy to illustrate.

The TEAC is only available to registrars in those situations where they need to undo a transfer very quickly and they cannot get in contact with the registrar via normal channels

It is not the normal transfer contact and should only be used when the losing registrar cannot get in contact with the gaining registrar.

So for example, if a domain was transferred from GoDaddy to Blacknight as a result of a hijack GoDaddy aren't going to need to use the TEAC, as they already know how to contact us and get a response (James and other GD staff have my mobile number :) )

The "normal" transfer contact and other policies and processes for dealing with transfers are always available, though the response times will vary. So if you were, for example, to open a standard transfer query with us on March 17th you probably wouldn't get a response until the 18th at the earliest regardless of which day of the week the 17th fell on.

I'm not sure if the above helps or not

Regards

Michele

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Mr Michele Neylon
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From: gnso-ppsai-pdp-wg-bounces at icann.org [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Metalitz, Steven
Sent: Thursday, May 15, 2014 12:57 AM
To: 'James M. Bladel'; gnso-ppsai-pdp-wg at icann.org
Subject: Re: [Gnso-ppsai-pdp-wg] Obligation to Respond to Inquiries

James, could you explain the basis for the assertion below that inquiries to accredited p/p/ providers would be less time sensitive than those to registrars under IRTP?  I imagine that sometimes this would be true, sometimes not.

One way to shed light on this might be to explain what constitutes an "emergency" under IRTP.

Thanks.

Steve Metalitz

From: gnso-ppsai-pdp-wg-bounces at icann.org<mailto:gnso-ppsai-pdp-wg-bounces at icann.org> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of James M. Bladel
Sent: Tuesday, May 13, 2014 12:09 PM
To: gnso-ppsai-pdp-wg at icann.org<mailto:gnso-ppsai-pdp-wg at icann.org>
Subject: [Gnso-ppsai-pdp-wg] Obligation to Respond to Inquiries

Team:

Today we discussed the question of whether or not P/P services should be required to respond to inquiries/reveal requests.  I raised the idea that we could use something like the TEAC as a model.  Below, I've pasted the applicable text from the transfer policy (IRTP).

The TEAC model applies to our issues in that:

  1.  The accredited registrar is required to respond promptly
  2.  There is no guaranteed outcome as a result of the inquiry, and
  3.  There is an understanding that ICANN will sanction registrars who do not respond, as well as registrars abusing TEAC for non-emergencies.
However, as Michele and others point out, the TEAC model falls short of our needs in a few key areas:

  1.  The TEAC is intended to address time-sensitive inter-registrar transactions, not for the general public to raise complaints.
  2.  Our work would require a more general purpose point of contact for use by third parties, LEA, etc.
  3.  The issues raised will be less time sensitive, reasonable response times would likely be measured in business days rather than hours.
  4.  There would be some penalties for abuse of the contact (e.g. Blocking future requests)

Thanks-

J.

________________________________

Transfer Emergency Action Contact

Registrars will establish a Transfer Emergency Action Contact ("TEAC") for urgent communications relating to transfers. The goal of the TEAC is to quickly establish a real-time conversation between registrars (in a language that both parties can understand) in an emergency. Further actions can then be taken towards a resolution, including initiating existing (or future) transfer dispute or undo processes.

Communications to TEACs will be reserved for use by ICANN-Accredited Registrars,gTLD Registry Operators and ICANN Staff. The TEAC point of contact may be designated as a telephone number or some other real-time communication channel and will be recorded in, and protected by, the ICANN RADAR system. Communications to a TEAC must be initiated in a timely manner, within a reasonable period of time following the alleged unauthorized loss of a domain.

Messages sent via the TEAC communication channel must generate a non-automated response by a human representative of the Gaining Registrar. The person or team responding must be capable and authorized to investigate and address urgent transfer issues. Responses are required within 4 hours of the initial request, although final resolution of the incident may take longer.

The losing registrar will report failures to respond to a TEAC communication to ICANNCompliance and the registry operator. Failure to respond to a TEAC communication may result in a transfer-undo in accordance with Section 6 of this policy and may also result in further action by ICANN, up to and including non-renewal or termination of accreditation.

Both parties will retain correspondence in written or electronic form of any TEACcommunication and responses, and share copies of this documentation with ICANNand the registry operator upon request. This documentation will be retained in accordance with Section 3.4 of the Registrar Accreditation Agreement (RAA). Users of the TEAC communication channel should report non-responsive Registrars to ICANN. Additionally, ICANN may conduct periodic tests of the Registrar TEAC communication channel in situations and a manner deemed appropriate to ensure that registrars are indeed responding to TEAC messages.
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