From:	Brad Slade-Smith 
Sent:	Friday, 27 May 2011 5:18 PM
To:	lujia.chen@auda.org.au
Subject:	Comment on Issues Paper

Dear Lujia,
Once again thank you to auDA for welcoming public comments. I have given mine below regarding the 
six month prohibition on transfers and the Registrant transfer process.
1. Registrant transfer process and fees
I agree with the working panels comments. It would be great to gain greater transparency on the fees involved 
and it would also be good to see some consistency between the registrars. Indeed auDA should advise people 
that it is permissible for a registrant to transfer their domain name to another registrar before processing the 
COR.  This would certainly be of great benefit to newcomers that are less likely to be aware of the 
alternatives and help facilitate more competition between the various players.

2. Six month prohibition on transfers
I agree with the working panels comments. The 6 month block is an unnecessary safeguard and should 
be removed.

The 6 month rule, while admirable in its stated purpose, is not effective in achieving its objective of 
preventing illegitimate registrations given the ease of which circumventing the rules can be facilitated. It 
has been mentioned before, however, domain holders need not even change the name servers (let 
alone the registrant name) to hand over control to another party. How would auDA ever police that? 
Given the lack of workability of enforcement of the 6 month rule it seems to only add more red tape to 
genuine cases where a domain transfer is required within first the 6 months of new and dropped 
registrations. 
Best Regards,
Brad