[registrars] Registrar amendments to IPC draft

[Siegfried Langenbach]

Dear all,

late, but hopefull not too late my remarks

On 14 Oct 2004 at 12:14, Ross Wm. Rader wrote:

Date sent:      	Thu, 14 Oct 2004 12:14:09 -0400
From:           	"Ross Wm. Rader" <ross at tucows.com>
Send reply to:  	ross at tucows.com
Organization:   	Tucows Inc.
To:             	3DOW3tf <dow3tf at gnso.icann.org>
Copies to:      	registrars at dnso.org
Subject:        	[registrars] Registrar amendments to IPC draft

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> Pursuant to our teleconference yesterday, I have created a revised draft
> ~  of the IPC recommendations that I would be comfortable presenting to
> the membership of the Registrar constituency.
> 
> There was one additional change made that we did not discuss at
> yesterday's meeting concerning allowing a registrar the discretion to
> delete a domain name sooner than the time period specified in the event
> that the information is prima facia inaccurate. This discretion
> introduces a degree of liability that I do not consider appropriate.
> Accordingy, I have removed the offending terms from the IPC draft.
> 
> I would also note that there are a number of ambiguities in this draft
> that would need to be clarified prior to ratification.
> 
> If there are any questions, I'd be happy to discuss them via email prior
> to our teleconference next week.
> 
> 
> Draft TF3 Recommendations
> revised 10-13-2004
> by Ross Wm. Rader (ross at tucows.com)
> Status: Draft for comment
> 
> I. Steps to Verify & Correct Inaccuracy in Response to a Complaint
> 
> A. When a registrar receives a complaint about the accuracy of
> registrant data via 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. If one method fails, then another method shall be used. If
> both of the two pursued methods fail (e.g., email bounce-back; telephone
> or fax disconnected; or a return to sender message), registrar may place
> the domain name on hold or cancel the registration but must allow the
> registrant 30 days to respond.

email is the main and most importand channel of communication with 
the registrant. I would not support to impose to the registrar the 
minimum number of channels he must use.


> 
> B. If a registrant responds to registrar notifications of inaccuracy
> within the 30 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 registrants
> correction of its contact data or by requesting that the Registrant
> provide the Registrar with "proof of authenticity" of the contact
> information (i.e. photocopy of drivers license, utility bill, et al). If
> one element remains inaccurate, registrar shall verify one of the other
> elements. If the contact information remains inaccurate or unverified,
> the registrar may place the domain name on hold or cancel the
> registration but must allow the registrant 30 days to respond.

I would not support to impose to registrars that additional work of 
checking the correctness.
I see problems in checking chinese, arabic or iran drivers licence.
I do not see how us-citizens will check the correctness of german 
driver-licenses.
I am not convinced that a returned email is equal to non existend 
email-address.
I see abuse of that process by persons increasing the work of 
registrants and registrars. Its too easy to start a process by simple 
email from a complainant and have others to do work. Why not ask the 
complainant for some kind of proof (for example the return of postal 
services).



> 
> II. Additional Steps to Verify & Correct Inaccuracy in Response to a
> Complaint
> 
> A. Registrar may provide any complainant with the option of expedited
> verification and correction. If this option is chosen, the registrar may
> charge a fee and shall promptly advise complainant of the completion of
> each of the following steps:
> 
> 1. Registrar uses all of the following methods simultaneously to contact
> the registrant:
> 
> a. email;
> b. Telephone;
> c. Facsimile;

may I remember that fax is not a mandatory field

> d. Postal mail; and
> 
> 2. If at least two of the four contact methods fails, registrar
> immediately places domain name on hold, allowing registrant 30 days to
> respond before the domain name is cancelled; or
> 
> 3. If registrant does respond to inaccuracy notifications, registrar
> individually verifies the accuracy of the following updated data elements:
> a. email;
> b. Telephone;
> c. Facsimile; and
> d. Postal mail.
> - --


siegfried
> 
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> ~                       -rwr
> 
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> 
> ~                "Every contrivance of man, every tool, every instrument,
> ~                 every utensil, every article designed for use, of each
> ~                 and every kind, evolved from very simple beginnings."
> ~                        - Robert Collier
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