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[opennic-discuss] Questions on and hints for ".rus" charter as submitted to OpenNIC

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  • From: Philipp Schafft <lion AT>
  • To: "Dmitry S. Nikolaev" <dn AT>
  • Cc: discuss AT
  • Subject: [opennic-discuss] Questions on and hints for ".rus" charter as submitted to OpenNIC
  • Date: Tue, 26 Sep 2017 08:23:10 +0000

Good morning,

I'm refering to at the version of
when this email was written.

I'm not a lawyer. I can not and do not provide any legal services. This
is just my personal opinion. I'm also not speaking for any group or

About the charter, going from top to bottom:
* You write "Registrations is available to everyone and completely
free.". What do you mean by "completely free"? Is that
gratis/free of charge, or is that related to freedom?
* You use "rules" and "notes" that needs to be "considered" by the
user. The difference is not clear to me. Also it's not exactly
clear if they are binding or for discussion (in individual
* You write "domain name must not use words that are contrary to
the public interest, the principles of humanity and morality (in
particular, words of obscene content, appeals of an inhumane
nature, insulting human dignity or religious feelings and so
on);". Can you please define who's definition of "humanity" you
refer to as well as who's standards for "morality"? Please also
see [0].
* In "information at domain pages (and/or files accessible via
domain name) must not include incitement to violence, drugs,
terrorism and other illegal activities condemned by the world
community;" you write about "domain pages". That is not a term I
have ever heard. If I take apart that I think you talk about
HTTP services provided using the domain name in question, I
would guess it's kind of a whois like service. I would be happy
if you could improve this a bit.
* Ibidem you talk about about different terms that require a
definition. You refer to "the world community". But all of the
terms lack of an international definition. And: Who could define
them? There is not a single organization that is both
acknowledged by and acknowledging all nation there are. And this
is not even considering contentious territories.
* About the length of a domain name you write "domain name must be
1 symbol length minimum and not be more than 32 symbols
length;". I just think this is a very open rule. I personally
prefer to reserve short domains for special use. But this is all
personal taste. Also I assume by symbol you mean character in
any encoding that is supported by the relevant standards.
* Next you write about the expire procedure. This is all fine with
me, but I think a native speaker should re-work the sentence
(please split it into smaller ones).
* In "Termination / Revocation" you talk about domain holders to
be considered members. What is a "domain holder"? Is it any
legal entity (private person or legal body)? What about groups
that do not generate a legal body but still work as a uniform
group (such as a German GbR[1]) what about an body and it's
departments? I would prefer something like "any private person
or legal body of any jurisdiction".
* In "Disputes" you write "trademarks". Is this any specific
registration service or any? What about de facto trademarks
(e.g. "OpenNIC")?
* In "Anonymity" you seem to define a "member" (ref: "domain
holder") more closely. However this doesn't really answer my
question above.

Some more general notes about the structure:
* You define several groups that can interact with the system.
(the general public), "domain holders", "members", the
administrative team, "OpenNIC", "OpenNIC community", "legitimate
court", (disputes), ...; I would be glad if you could define
them in a separate section ("Definitions") with all there
properties and then in the rules just refer to them. This would
make it much more easy to read.
* You use "become available for registration" or eq. in several
places. Sometimes with given time periods between steps,
sometimes without. I think it would be good to define this in a
central place. Maybe like "if for any reason a domain becomes
available for registration there is a time of nn days between
the event and the public availability. This time can be used for
anyone to raise a veto or claim the domain based on relevant
* You link at several places services. I thin it would be good to
move this to an individual section like a imprint, OR provide a
imprint along with the charter and only sign the charter.
* There is no date or revision number in the document. It's hard
to reference a specific version.

I hope this input helps you some. :)

With best regards,

[0] email <1501063277.4826.77.camel AT>: Philipp Schafft,
2017-07-26, "Re: [opennic-discuss] TLD policy change discussion"
[1] ยงยง 705 et seqq. BGB

(Rah of PH2)

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