Support

[mheltzer@inta.org]

INTERNATIONAL TRADEMARK ASSOCIATION
1133 Avenue of the Americas
New York, NY 10036
_______________________________________________________________

September 4, 1998

Joe Sims, Esq.
Jones, Day, Reavis & Pogue
Metropolitan Square
1450 G Street, N.W.
Washington, D.C.  20005-2088

Re: INTA Support of IANA Process

Dear Mr. Sims:

    The International Trademark Association (INTA) is a not-for-profit
membership organization of over 3,500 members which is open to businesses owning
trademarks and those who serve such businesses.  All of INTA's members,
regardless of their size or international scope, share a common interest in
trademarks and a recognition of the importance of brand identity to the
businesses that own trademarks, to the general public, to a competitive economy
and to the global marketplace.  It is in this capacity, as a representative of
the business sector, that INTA has taken a leadership role in protecting
trademarks on the Internet. 

    INTA takes this opportunity to offer its support to you, Dr. Jon Postel, and
IANA, for your continued efforts in developing a new not-for-profit corporation
(NewCo.) to administer the domain name assignment system (DNS).  We consider
your activities in the creation of by-laws for NewCo. to be the most fruitful
and well-considered of all the initiatives presented to the Internet community
thus far.  INTA stands with you in the formation of an entity which is
representative of all the stakeholders who have made an investment towards the
enhancement of the World Wide Web.

    While INTA supports the overall efforts by IANA in the development of
NewCo.,we cannot however, endorse, as such, the third draft of the proposed
by-laws which was made available to the public on August 24, 1998.  This draft
does indeed go further than previous iterations. However, it falls short in
select areas which must be addressed before NewCo. can begin operations.  

    The selection of Interim Board members, more specifically, the manner in
which they will be chosen, remains a critical concern for INTA.  We strongly
urge you to consider individuals who embody significant experience in business
operations, display an understanding of the important role that the Internet
plays in the continued development of the global economy, and possess a strong
background in protecting the interests of consumers.

    The same holds true for the nine At-Large Directors who will serve as
members of the permanent Board.  There must be consideration of the substantial
investment made by business with respect to the growth of the Internet.  As we
noted to you in our August 17, 1998 letter, the U.S. Department of Commerce
predicts that electronic commerce will surpass U.S.$300 billion by the year
2002.  Given this staggering figure, there must be an assurance that there will
be At-Large members who have an understanding of what has gone into creating
this phenomenon. This, of course, would include the importance of brand identity
both to businesses and consumers around the globe who use the Web to satisfy a
number of their everyday needs. 

    Finally, we urge that there be greater clarification with respect to the
role of Supporting Organizations vis-a-vis the Board of Directors.  INTA
believes that the Supporting Organizations must be given the necessary freedom
to operate and develop initiatives.  However, we also believe that it should be
the Board which renders the final decision and sets policy.
  
    Once again, INTA is pleased to offer its support to you, Dr. Postel, and
IANA for your efforts to develop NewCo.  We look forward to working with IANA as
it strives to get NewCo. "up-and-running" by September 30.  Please continue to
forward draft by-laws or other subsequent documents for our review.  Be assured
that we will respond in a prompt manner, as we recognize that the so-called
"deadline" is less than four weeks away.

Sincerely,

Michael E. Heltzer
Government Relations Program Coordinator

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