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[council] Deletes Task Force draft recommendations



Hello all:

Prior to our call tomorrow, I wanted to share the draft recommendations from the Deletes Task Force in their current form. These should already have been circulated to the various constituencies by their task force reps, but I wanted to make sure everyone has a chance to review them in conjunction with tomorrow's discussion.

Please keep in mind that these are draft recommendations and may still be subject to some refinement. In the initial task force report, which I hope to have released soon, there will be considerably more explanatory text surrounding the recommendations.

I look forward to speaking with all of you tomorrow.

Jordyn

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Issue 1: As indicated in the issues paper, the status quo presents an environment in which users may not always understand the deletion process applied to their domain name. While recognizing the need for registrars to pursue their own business models, the task force recommends that certain baseline policies be adopted by all registrars. Specifically:

1. Domain names must be deleted if a paid renewal has not been processed by the end of the auto-renew grace period (generally forty-five days after the domain's initial expiration). As a mechanism for enforcing this requirement, registries may elect to delete names for which an explicit renew command has not been received prior to the expiration of the grace period.

2. Registrars should provide a summary of their deletion policy, as well as an indication of any auto-renewal policy that they may have, at the time of registration.

3. Registrars should provide their deletion and auto-renewal policies in a conspicuous place on their websites.

A special case exists for names that expire during the course of a UDRP dispute. In order to prevent the name from lapsing and being re-allocated during the dispute, the task force proposes that the challenger in the UDRP dispute be provided with the option of paying for the renewal of the domain name in the event that the current registrant elects not to renew the domain name. This policy does not give the challenger in the dispute any special rights, nor does it The policy is described in more detail as follows (it's a bit complicated right now; we're working on paring it down while still covering the edge cases):

1. In the event that a domain under UDRP dispute is likely to expire during the course of the dispute, the dispute resolution provider will notify the challenger of the impending expiration either at the time the dispute is filed, or no later than 30 days prior to the expiration of the domain.

2. In such an event, the challenger will have the option to pay for a one year renewal at the sponsoring registrar's current prevailing rate for renewals.

3. The original registrant will have the option of paying for the domain name at any time up to the relevant registry's renewal grace period PLUS thirty days (which matches the redemption grace period), regardless of whether or not the challenger has paid for the domain's renewal.

3a. In the event that both the registrant and the challenger pay for the renewal, the name will be renewed on behalf of the original registrant in accordance with the registrar's usual policy, and any fee paid by the challenger will be refunded. The order in which the payments are received shall not effect this provision.

4. In the event that only the challenger pays for the renewal of the domain name, beginning no later than the duration of the relevant registry's renewal grace period after the domain's expiration, the registar will:

4a. Place the name on REGISTRAR HOLD and REGISTRAR LOCK, with the result that the name will no longer resolve in the DNS.

4b. Modify the Whois entry for the domain name to indicate that the name is the subject to a UDRP dispute, and to remove all specific ownership information for the Whois record.

4c. If the challenge is terminated prior to a verdict being rendered, but after the domain reaches this state, the domain will be deleted.

5. In the event that the verdict of the UDRP challenge is that the domain is to be transferred to the challenger, the registrar shall transfer the name in accordance with its regular process for such situations.

6. Notwithstanding #3 above, if the verdict of the UDRP challenge is that the domain is to be deleted, the registrar shall delete the name in accordance with the usual UDRP process.

7. In the event that the verdict of the UDRP challenge is that the existing registration be sustained, AND the relevant registry's renewal grace period has expired without the original registrant paying for a renewal, the domain name will be deleted.

7a. In the event that the verdict of the UDRP challenge is that the existing registration be sustained, and the renewal grace period has not expired, the domain name will be subject to the registrar's usual renewal and deletion
processes.

8. Provisions #6, #7 and #7a apply regardless of any payment for renewal by the challenger. With the exception of provision #3a above, the challenger will not receive a refund for any renewal fees paid to the registrar.


Issue 2: Many of the problems raised within the issues paper are already under consideration by the Whois task force. In order to avoid overlap between the two task forces, the Deletes Task force determined that:

1. The scope of the Whois Task Force is to determine under what circumstances a domain name should be deleted for reasons relating to the domain's Whois data.

2. The scope of the Deletes Task Force is to determine what happens to a domain name once it has been deleted for reasons relating to the domains' Whois data.

In most respects, a name deleted for reasons relating to inaccuracy of Whois data is treated identically to a name deleted for any other reason. However, it is important to prevent registrants from using the Redemption Grace Period to simply re-instate names once they have been deleted, without providing accurate Whois information. In order to prevent this, the task force recommends that registrars require that registrants of such names provide new, verified Whois information. This new data should be provided as part of the documentation to the registry in conjunction with the request for the name's redemption.



Issue 3: The task force believes that the recently adopted Redemption Grace Period not only provides registrants with crucial protection in the event of inadvertent deletion or misunderstanding of deletion policy, but also provides significant transparency into the deletion process as lists of names to be purged from the registry's system are published on a regular basis. The task force feels that the Redemption Grace Period provides an adequate level of consistency and transparency in terms of registry deletion policy, and does not recommend any other specific steps be adopted at this time.


Issue 4: The task force has found that this issue is primarily technical in nature. Although both the RRP and EPP protocols lack an "undo" function that would allow for the direct reversal of a renewal without deleting these domains, registries generally have administrative procedures in place that allow for such transactions to be reversed out-of-band. As a result, the task force sees no need to take action on this issue.

In the event that registries or registrars desire this capability to be added to the EPP protocol, the task force believes that these changes are best pursued through technical fora such as the IETF.