Module 2 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 2.

 

Module 2: Evaluation Procedures

2.1.1.2, Reserved Names Review

Our experience with the dispute process for second level domain names
shows a pattern of abuse by combining our recognized hotel brand names
with other words such as a city name or a general travel destination
word such as "beach".  Decisions are always made in our favor when we
invest the time and expense required by the dispute process.

We submit that a preventive measure that benefits everyone is to
establish a centralized, validated reserve list of brands, as determined
by third party examination of objective criteria.  This list should then
be a part of the Application Evaluation process.

We recommend that ICANN should be responsible for managing the Reserved
Names list and any fees should be cost based.

To support the Reserved Names Review, we submit that there should be a
WIPO operated appeals mechanism for challenging names on the Reserved
Names List, including mechanisms to discourage abuse of Reserved Name
List registration and an appeals mechanism.

2.1.1.1 String Confusion Review

The principle of recognized brand names for the Reserved Names Review
should also apply in the String Confusion Review.  Our experience in
combating abuse at the second domain level has shown that detrimental
user confusion and misrepresentation has resulted from registrations by
unaffiliated parties that include strings that are similar or include
our recognized brand names.  

Respectfully submitted,

Ms. Lynn Goodendorf

VP Corporate Risk & Data Privacy

IHG

www.ihg.com <http://www.ihg.com/>