Hi,

According to paragraph 24:

http://www.icann.org/gnso/transfers-tf/report-12feb03.htm

"24. ....Therefore,  Losing Registrar may deny a transfer request only
in the following instances;
....
A domain name is in the first 60 days of an initial registration
period.

A domain name is within 60 days (or a lesser period to be determined)
after being transferred (apart from a transfer back to the original
registrar)."

The first 60 day rule (after initial registration) was a registry rule,
from what I understand (at least for com/net/org).

The 2nd 60-day rule isn't in effect at present, e.g. a name transfers
to OpenSRS from NSI, after being at NSI for 4 years, can be transferred
to Register.com immediately.

According to the language above, it is "may deny", and not "MUST DENY".
Does OpenSRS intend to deny the transfers if they are the losing
registrar? It would add some pain and illiquidity to domain sales, if
that happened...

As a compromise, perhaps in that 60 day window, if the registrant
explicitly accepts the transfer (via a followup email that OpenSRS
would send, i.e. in addition to the one from the Gaining Registrar),
the transfer would be permitted?

Also, for paragraph 25, can one enter into a blanket agreement with
OpenSRS, to block all outgoing transfers unless the losing registrar
confirmation is accepted? (i.e. personally, I think it adds to domain
security if the double-confirmation system is in operation) Or, other
more secure methods (e.g. some registrars have even higher security
options, although they are more labour intensive, but would protect
high-value domain names better than just a "registrar-lock"). By
default, double-confirmation would be off, but one could then opt-in to
it, if desired (i.e. for sophisticated/paranoid domain registrants).

One other thing I'd like to mention -- it would be nice if the transfer
disputes were all made public. Then, one can see whether certain
registrars have a high propensity to make inappropriate (*cough* Steal
domains *cough*) transfers. It adds to the transparency of the system,
and can help uncover patterns of fraud.

Sincerely,

George Kirikos
http://www.kirikos.com/

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