From: Personal injury Lawyers.com.au - Australia 
Sent: Sunday, 19 January 2003 1:54 AM
To: jo.lim@auda.org.au
Subject: Attn: Jo Lim re: Transfers (Change of Registrar) Policy 

Dear Jo

Re: Comments - Transfers (Change of Registrar) Policy 

As per the other statements you have received to date, I fully concur with all 
comments relating to both :-

  a.. The re-charge of Registration renewal fees (in effect double dipping) when 
simply transferring a Domain from one (1) Registrar to another. From our research 
and understanding of all other major Country policies in this area, Australia 
appears to be the only country still practising in this 'Non-sensible' process. 
If, as a matter of covering administration costs only, a much smaller and 
specifically applicable Transfer fee could be applied, plus the honouring of 
exisiting time on every domain transferred. This would not only appear to be 
'equitably reasonable' but also provide obvious good business sense (given the 
opportunity for the New Registrars to gain 'Repeat Business' in future processes) and

  a.. On the point of 'Registrant' Transfers from one to another, it is respected 
that the applicable bodies are currently considering a more adaptable approach to 
this process, but I must re-iterate the thoughts of not only our company, but also 
many of our clients, who believe this point 'must become' the Rule rather than the 
exception, ie: when allowing companies, businesses, and other entities to transfer 
the domain of their current registration to another party (given that this purpose is 
more likely due to circumstances of business association rather than the benefit of 
assumed 'Cybersquatting' etc..).

Thankyou again for the opportunity to make comment on these Topics.

Kindest Regards

.............
Jeff Marr
CEO
Personal injury Lawyers.com.au
A Division of Online Referral Networks Australia
ABN 97 980 899 574