Module 3 Comments from IHG

["Goodendorf, Lynn (IHG)" <Lynn.Goodendorf@xxxxxxx>]

InterContinental Hotels Group PLC (IHG) appreciates the opportunity to
submit comments on the Version 2 Draft of the Applicant Guidebook for
new gTLDs.   IHG represents 4,150 hotels across nearly 100 countries
operating in seven hotel brand names. We have over 160 million hotel
stays in over 620,000 rooms per year.  

 

Online booking has become a preferred and convenient way to make travel
arrangements.   IHG currently delivers 85% of all online bookings from
its branded websites in 13 languages, well above the industry average,
while also providing the fewest clicks-to-book in the industry. IHG
websites receive over 18 million visits each month and is the largest
search marketer among suppliers in the travel industry.  IHG also uses
online systems to provide services to over 42 million members in our
Priority Club Rewards loyalty program.  And like many companies, IHG
makes use of website presence to post job openings and accept job
applications.

 

We are very concerned that brand abuse and online fraud may likely
increase significantly upon the introduction of an unlimited number of
new gTLDs.  Aside from the cost to our company to protect our brands, we
believe that health and safety of the public use of the Internet is
potentially threatened.  As delineated in the presentations of the
eCrime Summit at the Mexico City ICANN Meeting, domain name abuse
problems are growing both in terms of number of incidents and in the
complexity and ingenuity of the attacks perpetrated.  Ultimately,
consumers are the victims of these abuses and they suffer loss of time,
money and in some instances, health and safety.

 

We are submitting comments on Modules 2, 3 and 5 to support development
of a process that will serve the best interests of everyone who uses the
Internet.

Below are our comments for Module 3.

 

Module 3: Dispute Resolution Procedures

Our company has successfully used the Dispute Resolution Process with
WIPO for the second level domain names.  However, the expense and time
involved to use this process, even under the best economic times,
requires us to be selective as to which registrations are the most
egregious and damaging to us.  This limits our ability to take action on
all types of domain name abuse we have identified at the second domain
level, even now.  The current economic conditions coupled with the
introduction of new gTLDs will force companies to make difficult
decisions regarding our security priorities.

In 3.3.7, we strongly agree that the objection to a gTLD will be
sustained when an applicant fails to pay the estimated cost in advance.
And we strongly support the provision that when a determination has been
rendered that the DRSP will refund any costs paid in advance to the
prevailing party.

Enhanced Dispute Resolution Procedures

We submit that it is beneficial to the entire Internet community to have
robust dispute resolution mechanisms.  These mechanisms need to be
efficient in terms of timeframes, reasonably priced and available
throughout the gTLD application cycle to resolve conflicts for new
gTLDs.

a)      The UDRP should be reviewed and enhanced as appropriate to
respond to planned expansion of the TLD space. 

b)      Streamlined procedures are needed for identifying and
challenging registrations of strings previously found to be
infringing/confusingly similar.  

c)      Efficient, reasonably priced, and standardized mechanisms must
be available to resolve conflicts about second level registrations e.g.,
central list of strings found to be registered in bad faith via UDRP;
automated notice to prevailing party of subsequent registration of
previously adjudicated string; opportunity to require registrant to
demonstrate good faith registration.

Respectfully submitted,

Ms. Lynn Goodendorf

VP Corporate Risk & Data Privacy

IHG

www.ihg.com