From: Bennett Oprysa 
Sent: Friday, 28 February 2003 10:58 AM
To: Jo Lim
Subject: Transfer Policy

Jo,

Enetica welcomes the change to the transfer policy in regards to 
removing the need to renew at the same time as transferring a domain. It 
will allow domain owners greater control over their domains and will 
encourage greater competition amongst registrars.

We would suggest that there should be some sort of minimal restriction 
on transfers to remove the possibility that registrants will transfer 
domains to the cheaper registrars in order to renew, then transfer back 
to higher priced registrars which provide enhanced domain services for 
the rest of the domain licence, then repeat the process at the next 
renewal time.

We suggest a TransferProhibited status be implemented for a period of 90 
days after a domain registration or renewal.


In regards to the continued requirement of an email confirmation, 
Enetica is very disappointed to see that auDA has failed to take note of 
the almost unanimous support for the removal of this requirement.

You have quoted totally irrelevant developments in the gtld market as 
one of your reasons, and unproven opinions that the domain password is 
not adequate proof of authorisation. The gtld transfer system is 
universally considered a total failure, with transfers coming to an 
almost total stop due to the failed policies of ICANN. The idea that 
auDA is looking for help from this system is extremely scary.

Any serious attempt to 'hijack' a domain would still only need a 
password, as it is enough to change the registrant contact before 
putting the transfer request through. This would still achieve very 
little as neither email nor the password is enough to change the actual 
owner of an .au domain.

This is why the need for an email confirmation from the registrant 
contact is simply a waste of time and effort, and an unnecessary 
overhead in the .au domain system.

If auDA is simply trying to make sure that domain licences are not 
transferred to a new registrar without the registrants knowledge, what 
is wrong with simply making it a requirement that an email is sent by 
the gaining registrar to the registrant contact giving them notice, and 
the option to reject the transfer if they did not authorise it. The 
losing registrar will in most cases also be sending such an email, so 
there is no chance that the domain registrant won't know what is 
happening, unless their email is incorrect.

It is the responsibility of the current registrar for a domain to 
encourage their registrants to keep their details up to date, and to 
provide easy access to domain management tools. A gaining registrar 
should not be disadvantaged by the fact that the losing registrar did 
not have a policy to encourage this, or because they allowed their 
resellers to put themselves down as a contact.


Bennett Oprysa
Chief Operations Officer
Enetica Pty Ltd