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Request for modification in document language



I am extremely concerned about the following language in your
documents and would request that they be removed or amended
immediately. Thank you:


"You agree that we may, in our sole discretion, delete or
transfer your
domain name at any time."


Revocation-with-no-cause-and-no-due-process language, and the
language
that supports and/or mandates it, needs to be removed from
these
document.


Paragraph 3 of  the Uniform Domain Name Dispute Resolution
Policy 
http://www.icann.org/udrp/udrp-policy-29sept99.htm says, "We may
also
cancel, transfer or otherwise make changes to a domain name
registration
in accordance with the terms of your Registration Agreement or
other
legal requirements."


Paragraph 7 says it again:  "Maintaining the Status Quo. We will
not
cancel, transfer, activate, deactivate, or otherwise change the
status
of any domain name registration under this Policy except as
provided in
Paragraph 3 above."


As such, domain names can be canceled, deleted or transferred at
any
time, with no due process, as written in all of the existing
Domain Name
Registration Agreements:


Network Solutions (NCI)
http://www.networksolutions.com/legal/dispute-policy.html 
Revocation. The registrant agrees that Network Solutions shall
have the
right in its sole discretion to revoke, suspend, transfer or
otherwise
modify a domain name registration upon thirty (30) calendar days
prior
written notice, OR at such time as Network Solutions receives a
properly
authenticated order from a court of competent jurisdiction, or
arbitration award, requiring the revocation, suspension,
transfer or
modification of the domain name registration.


CORE - Council of Internet Registrars (global)
http://www.corenic.org/dispute-policy/CORE-dispute-policy.htm 
Revocation. The registrant agrees that CORE shall have the right
in its
sole discretion to revoke, suspend, transfer or otherwise modify
a
domain name registration upon thirty (30) calendar days prior
written
notice, OR at such time as CORE receives a properly
authenticated order
from a court of competent jurisdiction, or arbitration award,
requiring
the revocation, suspension, transfer or modification of the
domain name
registration.


Domain Bank
http://ru.domainbank.net/reg_agreement.cfm 
Breach and Revocation. ... You also agree that Domain Bank shall
have
the right in its sole discretion to revoke, suspend, transfer
or
otherwise modify a domain name registration upon seven (7)
calendar days
prior written notice, OR ... 


A+Net/ABACUS America, Inc. (United States)
dba Names4Ever
http://www.names4ever.com/dp.html 
Revocation. The registrant agrees that A+Net shall have the
right in its
sole discretion to revoke, suspend, transfer or otherwise modify
a
domain name registration upon thirty (30) calendar days prior
written
notice, OR ... 


NameSecure
http://www.namesecure.com/services/registration_agreement.cfm 
REVOCATION. ... You agree that we may, in our sole discretion,
delete or
transfer your domain name at any time.


Register.com
http://register.com/service-agreement.cgi?1|142560921 
Breach and Revocation.  You also agree that register.com shall
have the
right in its sole discretion to suspend, cancel, transfer or
otherwise
modify a domain name registration upon seven (7) calendar days
prior
written notice.


This language is in place in *every* registrar/registrant
agreement,
because the existing ICANN Registrar Accreditation Policy
mandates it in
"Business Dealings, Including with SLD Holders":


"The SLD holder shall agree that its registration of the SLD
name shall
be subject to suspension,  cancellation, or transfer by any
ICANN
procedure, or by any registrar or registry administrator
procedure
approved by an ICANN-adopted policy, (1) to correct mistakes by
Registrar or the registry administrator in registering the name
or (2)
for the resolution of disputes concerning the SLD name."


********

This language and any language like it, in the ICANN Registrar
Accreditation Policy, ICANN Registrar Accreditation Agreement,
in the
ICANN Uniform Dispute Resolution Policy, and in Domain Name 
Registration Agreements, should be removed immediately and
permanently.