From: Simon P. Delzoppo 
Sent: Monday, 3 March 2003 12:20 AM
To: jo.lim@auda.org.au
Cc: ceo@auda.org.au; Adrian Kinderis
Subject: PROPOSED TRANSFER POLICY CHANGES



Hello Jo,

RE: PROPOSED TRANSFER POLICY CHANGES

I offer the following comment in regard to proposed changes to the existing 
transfer policy and specifically to replace the transfer and renew requirement 
with a "free" transfer.

I have identified a number of issues with the proposed changes to the existing 
policy and would suggest that auDA conduct further research before proceeding 
with suggested changes. I might also point out that the existing transfer and 
renew requirement was implemented after carefully considering all of the 
ramifications of a "free" transfer policy, the following is a list of some 
of the potential problems with a "free" transfer policy-

1. Customer could register with a cheap “poor service” registrar, then move to 
a good “complete service” registrar and them move back to the “poor service” 
registrar to renew the domain and so on..  the “complete service” registrar would 
receive no money

2. Registrants may be spammed by registrars and resellers to gain business, this 
may create bad press for auDA and the domain industry

3. There will be no cost barrier to curb excessive transfers amongst registrars 
or payment to the registrars for their work

4. Free transfers only work in the GTLD space because an extra year minimum is 
added to the domain term

5. Other examples in the market use a similar procedure if you break a contract 
term

Brief analysis of transfers processed by AusRegistry show the following -

1. Currently approximately 1000 transfers/renews occur per month

2. Majority of transfer/renews are done outside of the 3 month domain renew 
period

I would suggest that the figures are further analysed and a sample group of 
registrants that have completed a transfer are contacted. This will help auDA fully 
understand why registrants transfer their domain and potential underlying issues.

I would also suggest that should auDA wish to remove the need to renew a domain at 
transfer, that the registry (upon consultation with auDA) and registrars impose a 
transfer fee and auDA not impose a requirement on a winning registrar not to charge 
a fee. I would suggest that competition amongst registrars will look after itself on 
this issue and if a winning registrar would like to charge a fee they should be 
allowed to do so.

Regards,

Simon Delzoppo
CEO
AusRegistry Pty Ltd