CORRECTED: US Industry Comments to the Second Draft DAG - gTLD Program and Process
<<COTP DAG2 ICANN gTLD Coalition Letter v.3.doc>> The Coalition for Online Trademark Protection To: ICANN (2gtld-guide@xxxxxxxxx) Re: US Industry Comments to the Second Draft DAG - gTLD Program and Process Date: April 13, 2009 NB: The full comments are also attached above; they contain footnotes that may not appear in the text of this email. They are to be considered our official submission to ICANN on this proceeding. Dear Dr. Twomey and Mr. Dengate Thrush: The Coalition for Online Trademark Protection, comprising of corporations, trade associations and business groups that represent thousands of multinational companies and millions of employees and Internet users, submit these comments related to the Second Version of the Draft Applicant Guidebook (DAG) and the new generic Top Level Domain (gTLD) program. Thank you for the opportunity to participate in the on-going process regarding the DAG. We are pleased to see the level of attention that ICANN is affording this significant milestone in its history and are greatly encouraged to see that ICANN has established the Implementation Review Team (IRT) to develop intellectual property rights-protection mechanisms for the new gTLD roll-out. We are hopeful that the recommendations will be given full and thoughtful consideration by the ICANN Board and community. At the same time, we would like to take this opportunity to reiterate some of our prior concerns and highlight new ones that have arisen as this process has continued to unfold. The American business community holds fast to the concept that the stability of the Internet as a global platform for eCommerce is a core concern for businesses world-wide. We look forward to working with ICANN to ensure this stability, especially in these times of great economic uncertainty. Executive Summary ICANN's decision to increase the number of gTLDs has brought a number of issues to the attention of the international business community, and we would like to take this opportunity to address them. Most significantly, our concerns lie in three significant areas: * Protecting consumers across the new gTLDs; * Protecting brand-owners across the new gTLDs; and * The effect of the new gTLD program on ICANN and the Internet. Our comments below highlight these three areas. We suggest that before ICANN proceeds with the new gTLD Program and Process, it should: * Set aside the flawed economic study submitted to ICANN in March 2009 and undertake a comprehensive, empirical economic study of the domain name marketplace, as mandated by the ICANN Board in 2007, as well as an extensive evaluation of whether new gTLDs are needed in the first place given the record of existing new gTLDs; * Establish criteria for the success of ICANN's new gTLD program in the proposed first round - including Internationalized Domain Name TLDs - before moving forward; * Modify the roll-out of the new gTLD program to the limited number of cc IDN TLDs (once the study has been completed and criteria established), treating these cc IDNs as a form of pilot; and * Limit further roll-out until sufficient safeguards are in place to protect Internet users, businesses, and brand-owners alike from any existing and expected acts of cyber-fraud. Until these issues and recommendations can be adequately addressed, we respectfully request that ICANN delay the launch of the new gTLD program. Protecting Consumers Across the New gTLDs The Internet exists for its users, as well as because of its users. Protecting them from harm is incredibly important not only for their sake, but also for the sake of all who create content, do business and facilitate the Internet's day-to-day operations on the network. Preventing Consumer Confusion ICANN has announced its intention to move forward with plans for creating a considerable number of new generic TLDs, including Internationalized Domain Names (IDNs). One of ICANN's justifications for this project is to introduce 'competition' into the domain name system (DNS). Currently, there are over 240 top level registry strings (known as top level domains or TLDs) that include generic names (gTLDs) such as .com, .net; .info; .biz; .mobi; as well as country-code TLDs (ccTLDs), such as .us, .uk, .it, and .cn. Today, in these top level domains, over 175 million domain names already offer significant choice and diversity to end registrants. ICANN's proposed approach to introducing further new TLDs could lead to the creation of over 1,000 or more new gTLDs over the next three years. This course of action would significantly raise the risk of creating confusion in the minds of consumers as to where on the Internet they can find a business or their desired product. By making it increasingly difficult for consumers to enjoy their Internet experience, frustrated consumers would be less likely to engage in eCommerce - at a time when many businesses with online presences can ill afford reduced traffic. Further, there is a significant concern about "community based/sponsored" TLDs that may propose to represent limited geographic areas (such as cities or regions) and commercial communities such as those that that propose to represent certain industry sectors where reliability and security are paramount concerns, such as healthcare or financial services. The concern surrounds the vetting process of these proposed TLDs and whether or not sufficient public safety concerns will be addressed and whether critical consumer privacy and data security safeguards will be put in place to protect consumers. We urge ICANN to hold off on accepting applications for these TLDs and focus on the much greater need for both generic IDN TLDs and country-code IDN TLDs. Protecting consumers against cyber-fraud With the increased number of gTLDs, the opportunity for cyber-crime to increase is significant. By using domain names to exploit the trust that consumers have in legitimate brands and trademarks, cyber-squatters are able to harm consumers by creating confusion about which web site is the legitimate brand-holder's site that provides the goods or services the user is seeking. Other serious problems exist when these illegitimate sites are used for abusive purposes, such as sending malware to infect a user's computers with viruses and software to steal personal information or for the sale of unwanted counterfeit goods. The magnitude of the problem is shocking. The overall number of domain names under existing gTLDs has more than doubled since 2003, and the growth of cyber-squatting has exceeded that pace. According to MarkMonitor's Brandjacking Index Report from Spring 2007, cyber-squatting increased 248% in 2006. This is of significant concern as cyber-squatting is a tool that criminals use in phishing attacks against unsuspecting consumers. A study released by Gartner, Inc. in 2007 revealed that phishing attacks in the United States alone cost Internet users over $3.2 billion. The problem is growing, with no signs of slowing down. The survey found that 3.6 million adults lost money in phishing attacks in the 12 months ending in August 2007, as compared with 2.3 million the previous year. With the projected number of new gTLDs in the proposed program, the costs of fraud to unsuspecting consumers will undoubtedly eclipse that figure. ICANN's efforts must include consideration of the millions of Internet users who use the World Wide Web to work, play and learn. One recommendation we strongly suggest would have ICANN launch a process, similar to the IRT process, to identify best practices and mandatory rapid response and remediation procedures in appropriate circumstances to minimize consumer harm from fraud and malicious conduct. Strong consumer protection starts with creating tools to thwart brand infringement and protect against such potential and probable abuses in new gTLDs and in IDNs. Protecting Brands Across the New gTLDs There is great concern in the business community that ICANN has not adopted adequate safeguards against systemic brand abuse in new gTLD registrations (including both ASCII and non-ASCII (or IDN) TLDs) prior to moving forward with the new gTLD Program. The current system for addressing brand abuse is the Uniform Domain Name Dispute Resolution Policy (UDRP). Currently, there are almost 250 TLDs available to public, private and governmental institutions. Trademark owners are already compelled to engage in defensive registrations to prevent phishing, fraud, and trademark infringement. As mentioned above, cyber-squatting is not only a problem that impacts consumers and business. The practice is estimated by the Coalition Against Domain Name Abuse to cost brand owners worldwide over $1 Billion dollars a year as a result of diverted traffic, the loss of hard-earned trust and goodwill, and the increasing enforcement expense of protecting consumers from Internet-based fraud. Adding new gTLDs without adding the proper tools to protect Internet users and brand owners will only exacerbate the problem. In sum, the ICANN proposal would vastly increase the costs associated with defensive registrations and mark protection, which are already extremely expensive for trademark owners, even where there are only a finite number of TLDs. We believe that, by adopting the following recommendations, ICANN can strengthen the security and integrity of the DNS while simultaneously protecting consumers and brand-owners. The current and future quality of the WHOIS system Continued access to an accurate WHOIS is essential to protect the stability and security of the Internet and to maintain confidence of consumers in the integrity and safety of eCommerce. Examples of essential characteristics of WHOIS: * Free, accurate, and publicly available access to WHOIS, to quickly identify the registrant of abusive domain names, is critical to the future of the gTLD program; * Applicants committed to maintaining and enforcing WHOIS requirements, including a centralized or "thick" WHOIS; and * True applicant information in proxy registrations should be escrowed until the application is verified against an IP Registry. A mechanism that allows access to the data under the defined conditions should be developed and implemented in a uniform manner. The application process for new gTLDs should require applicants to commit to participate in an open and accurate WHOIS system. Proxy and private registrations frustrate the efforts of trademark owners to identify domain name registrants and should be strongly discouraged, if not prohibited. The growth of online fraud and, in particular, phishing, necessitates stronger action at the registration level to ensure that criminals can be quickly identified and stopped. Even if applicants are not prohibited from anonymously registering domains, at a minimum trademark owners must be able to identify expeditiously the actual entity or individual responsible for registering a domain name that conflicts with one of their marks. Lack of tools for brand owners to protect their brands and their customers As was mentioned above, we are encouraged by ICANN's establishment of the IRT to help move the discussion on protecting intellectual property. We will work with the members of the IRT to recommend policies and practices that ICANN may implement in the new gTLD rollout to achieve this goal. We strongly urge ICANN to give the recommendations put forth by the IRT, national governments, consumer protection groups, and industry substantial weight in its deliberations on how to proceed. To that point, we stand behind our comments in our previous filing of the first-round comments, but we would like to take this opportunity to reiterate our concerns and suggestions so that they may be included in the second-round record. Currently, there are few options for brand owners, other than self-policing, use of the U.S. Anti-Cyber-Squatting Act, and the Uniform Domain Name Dispute Resolution Policy (UDRP) to protect their brands over the Internet. To promote the success of the proposed gTLD program, new tools and safeguards could be created by ICANN. We strongly suggest that such mechanisms should be in place before the new TLD application window opens, and all registry applicants should be required to follow standardized processes. One possibility includes a centralized registry of qualified names that would act as a clearing house for "certified" brand-holders, based on objective criteria. This no-cost "global brands reserved list" would be a centralized, validated reserve list of brands that have developed worldwide recognition, documented by objective criteria, such as national registration. This would enable trademark owners to make sure that they can put their own names "on hold" without being forced to register in all these new places either during the so-called "sunrise period," which would be hugely expensive, or after. Further, this global brands reserved list could also serve to prevent third-party registration of confusingly similar strings at the second level. ICANN implicitly recognizes that additional costs will be imposed on trademark owners because it creates a Top-Level Reserved Names List consisting exclusively of ICANN-related names. We believe that ICANN must offer the same solution to brand owners. We note specifically that this list would not constitute a famous mark list but would be open to any trademark owner who could meet certain objective criteria. For instance, the trademark owner would need to establish that they own a national trademark registration in at least one of the five ICANN geographic regions. The trademark owner must also demonstrate through documentation that their marks have been the subject of widespread cybersquatting as established by successful UDRP proceedings or other proceedings brought in national courts of competent jurisdiction. Once these hurdles have been met by a trademark owner, their name would be placed on the reserved list. A prospective applicant who wishes to register a name on the list would have their application automatically flagged, at which point the applicant can bring an expedited administrative proceeding to allow its name to move forward. This proceeding would be administered by the arbitration and mediation center of the World Intellectual Property Organization, which has already been identified by ICANN as a potential dispute resolution service provider (DRSP) and has established expertise in resolving trademark and domain name disputes. In determining whether trademark rights are implicated, the use of algorithms (based solely on visual similarity) in and of themselves, are not a panacea for the protection of intellectual property rights. Algorithms alone cannot be dispositive of string similarity. There must be manual reviews to ensure adequate protection of marks. Visual, aural and semantic similarity should be emphasized in determining whether the registration of various domain names may be implicated. Lastly, the UDRP process can be slow and cumbersome. Trademark owners may suffer harm before they can fully vindicate their rights in a UDRP dispute. To address this concern, some stakeholders have proposed that ICANN consider implementing a notice and take-down procedure for infringing second-level names based on established criteria in the new gTLDS, similar to the U.S. Digital Millennium Copyright Act. Such an expedited take down mechanism could be implemented by immediately locking down the domain name to ensure it cannot be transferred during the challenge period. The process should include appropriate checks and balances to ensure that the registrant has advanced notice before any domain is placed on reserve or transferred. The registrant should be provided with the opportunity to file a counter notice and bring an administrative challenge at the World Intellectual Property Organization, which might adopt a loser pays model to ensure that the mechanism is used judiciously by all parties. Consideration should also be given to the post-delegation procedure proposed by WIPO to allow a party to institute a challenge against registries or possibly registrars who engage in abusive activity after a new TLD has been awarded. In the absence of such a self-help procedure, both businesses and consumers will be left to rely on ICANN to de-accredit its contracting parties, which is a remedy, based on past experience, that would occur under the most extreme of circumstances. Given ICANN's reluctance to enforce its existing contracts against registries and registrars who directly violate the "compliance with laws" provision in their contracts by engaging in domain name tasting, kiting and cybersquatting, a new administrative remedy would be a necessary tool for businesses and consumers to avoid the abuses that will likely occur in the new TLD spaces. The cost of dispute resolution procedures Currently, utilizing the UDRP for brand protection is costly and time consuming; under the proposed gTLD Program, the UDRP as a remedy will be impractical and cost prohibitive with the possibility of dozens to hundreds of new gTLDs to police. As far as brand protection in resolving string contention in the new gTLD application process, auctions should be avoided and other improved mechanisms for resolution should be developed. If there are cases in which an auction is necessary, bidders should be required to escrow an amount large enough to deter fraudulent or defaulting bidders. Further, the utilization of auctions and resultant revenues to ICANN need to be assessed regarding implications for affecting ICANN's non-profit status. As mentioned above, given the number of expected TLDs in the first-round alone, the cost-potential for brand-holders to protect their brands is daunting. To help alleviate this burden in the UDRP process, prevailing brand-holders in a dispute should not experience any fees or costs in protecting their brand. This could be accomplished by extending the loser-pays approach of the dispute resolution process to cover all costs and expenses, including attorney fees as well as filing fees paid to the DRSP. This will result in a more fair and equitable dispute resolution process, with the added benefit of curbing registrations used for harassment purposes. Strengthening the dispute resolution system To promote the success of ICANN's proposed gTLD Program, efficient, reasonably priced, and standardized mechanisms must be available to resolve conflicts regarding second level registrations. The UDRP should be reviewed and enhanced as appropriate to respond to planned expansion of the TLD space. Specifically, new registry agreements should ensure operator and registrars are obligated to adopt and enforce obligations of any UDRP enhancements. Also, streamlined procedures for identifying and challenging registrations of strings previously found to be infringing/confusingly similar should be implemented. Further, it is critical that dispute resolution service providers' (DRSP) decisions should be final and binding on ICANN, rather than be viewed as an "expert determination" to be considered by ICANN as a factor in the evaluation of the gTLD application. Further, objections and responses should be made public. To ensure an open and transparent DRP, the rules and procedures that DRSPs will use should be made available and open to public comment. Lastly, objectors in dispute resolution proceedings should not be forced to give up their legal rights, specifically including the right to seek redress in court. The Effect of the New gTLD Program on ICANN and the Internet Concern over the need for new gTLDs Given the unease over the unintended consequences for Internet users and brand-holders alike, a significant question arises over whether or not new gTLDs are needed in the first place. ICANN's previous expansion of gTLDs has largely failed to increase the number of registrants that ostensibly justified the creation of new gTLDs. The .COOP, .AERO, .MUSEUM, and .JOBS gTLDs, for example, have no more than 10,000 registrations each. Other gTLDs, such as .info and .biz have significant numbers of 'defensive' registrations. Our previous comments made note of the fact that there had been no evidence to suggest a compelling demand for the expansion of new TLDs. To that point, the ICANN Board directed its President more than two years ago to commission a comprehensive study on the economics of the domain registration marketplace. In March 2009, Professor Dennis William Carlton and Professor Katherine Dusak Miller submitted two reports to ICANN that purports to satisfy the Board's request. The report correctly addresses the need to protect intellectual property rights, as well as addressing the concerns of potential harm to consumers from confusion, such as requiring "inefficient 'defensive' registrations of domain names on new gTLDs." However, the report contains a number of fatal flaws. Our first concern was how both reports were undertaken, a full three years after the Board made its request for a report. The report that was eventually delivered was devoid of empirical data and lack of statistical analysis; yet the report was conclusory in nature, supporting ICANN staff's contentions that "more competition is better." In doing so, the report was devoid of empirical data and lack of statistical analysis to support the purported conclusions. Further, the report was dismissive of comments and concerns raised by NTIA and DoJ and industry's concerns for consumer safety and well-being. By focusing on competition in general, and not the harm to consumers from online fraud practices such as cybersquatting and phishing that will increase due to the increase of market entrants, the report leaves ICANN blind as to the final net affect on the Internet-using public. With regards to intellectual property protection, the report cites the lack of evidence submitted by "DOJ and others" as to the likely costs to trademark holders, but ignores evidence filed by other experts in the area, such as MarkMonitor in their filings, as well as publicly available materials. It may be further noted that ICANN's goal of promoting competition within the DNS as outlined by the JPA was intended to create more registries, in order to represent more choice for registrants and consumers. This report seems to avoid that distinction, focusing briefly on ICANN's recently stated goals of increasing the number of gTLDs. We believe that flooding the market with these new gTLDs without the requisite safeguards and consumer protections will lead to fear, uncertainty and lack of confidence in the safety of using the Internet, and ultimately of ICANN's management of the DNS. Our final concern is with the lack of academic rigor exemplified in the report, as there is a dearth of statistical data or empirical facts substantiating the conclusions put forth. This misstep significantly undercuts the report's utility to ICANN, as well as its credibility. ICANN staff has acknowledged these difficulties with the report and the position it has placed ICANN within the larger Internet community, and has wisely put the report up for public comment. We will provide ICANN with further comments and specific data in that proceeding. We strongly suggest that a complete and through economic analysis be undertaken by an independent, outside consulting firm of international reputation, which would focus on the critical issues demanded by the Board in its 2006 request. Further, this new report should focus on the affect of the rollout on both consumers and intellectual property owners, backed by empirical analysis and the wealth of publicly available data. We would also recommend the report devote significant attention to the impact of releasing the new gTLDs without the appropriate pricing mechanisms, consumer safeguards and intellectual property protections in place. A report prepared by Michael Palage for the Progress and Freedom Foundation asserts that the negative externalities placed on both industry and consumers would be tantamount to a new "tax on the Internet." Both businesses and consumers alike would be forced to account for the cost of new defensive registrations and the increased expenses concomitant with consumer fraud protections. Such a study would be invaluable for crafting a new gTLD launch in a way that maximizes the competitive benefits and decreases costs on consumers. We strongly recommend the study should be started immediately and prior to moving forward with the new gTLD Program. If competition is found to be lacking, the next logical step would be to assess potential causes of the lack of competition, as well as address remedies and their impact on the Internet community as a whole. We also have concerns with the price-cap report, and the recommendations it makes regarding whether price caps or ceilings should be implemented as part of the process for introducing new gTLDs. The report states that the imposition of price caps on registries for new gTLDs could inhibit the development and marketplace acceptance of new gTLDs. While we would agree in general that price caps in a perfect marketplace would inhibit competitive and innovative pricing, it is obvious that the marketplace described by the new gTLD rollout is far from perfect. An example drawn from the report that justifies its conclusion mentions that the new gTLDs would face competition from existing TLDs such as .com, .net, as well as sponsored TLDs such as .museum and .travel. The distinction must be made, however, that in the case of the established gTLDs, some new gTLDs could de facto encourage massive growth of defensive registrations, and without price caps, leverage extortionate rents from businesses by playing on their fears of brand dilution or the potential for consumer fraud. At the very least, a responsible tack would be to introduce pricing protections for bona fide defensive registrations and renewals. This would address the absence of market-based controls with respect to defensive registration, based upon standardized criteria for such registrations (e.g., as evidenced by redirection to existing site or election to register as non-resolving name). In the example of sponsored TLDs, it was established early on that those TLDs would be maintained by recognized stewards of their respective communities, and would not be amenable to price caps, as they serve a finite and discrete community. In the .museum case, the domain is limited to bona fide museums, their professional associations and individual members of the museum community. The .travel domain is managed by the Tralliance Corporation, who is partnered with the non-profit Travel Partnership Corporation, which is comprised of leading travel and tourism associations. In these situations, price caps are recognized to be inappropriate as the need to recover domain management costs are high and the possibility of abuse is low due to industry self-policing. However, with the potential addition of hundreds of new gTLDs in the near term, the possibility of abuse is heightened as exceedingly broad gTLDs may be adopted, compounded by ICANN's already-stretched compliance resources. While we will address the issue of price caps in detail during the competition report comment period, we are highly skeptical that the distinctions drawn from these highly specific examples can be used to justify a recommendation to eschew protective price caps. There is a lack of published data at this time regarding competition between the .com domain and other gTLDs, but experience of brand holders is that they are not able to leave their .com brand and move into another gTLD. In the absence of price caps, entities that wish to migrate to a more specific domain, such as .mfr or .auto, would be subject to opportunistic pricing. The increases in Internet usage cited by the report are not dispositive of protections against opportunistic pricing, justifying the recommendation against price caps. If anything, it highlights the increased number of potential victims of predatory pricing, and thus brings to our attention the greater need for restrictions. Moreover, the absence of price caps may trigger the large existing TLD operators to invoke the "equal treatment" clause in their registry agreements with ICANN. Operators of existing large TLDs, including must-have addresses ending in .com and .net, should not be able to take advantage of a flaw in new TLD policy to increase costs for renewing important domain names owned by trademark owners in existing spaces. Assessing the success of the new gTLD Program Given the scope and size of the current undertaking, there should be significant delays in between application rounds to understand a number of issues critical to the health of the DNS, such as: * Whether trademark owners will be able to vindicate their intellectual property rights given the introduction of any new gTLDs; * Whether the costs associated with preventing customer fraud and protecting brands are justified by the benefits realized by registrants and users of the new gTLDs; and * Whether the new gTLDs, in fact, do yield any tangible benefits to the broader Internet community. The impact of new gTLD new revenue streams on ICANN's non-profit corporation status The proposed new gTLD Program stands to increase ICANN's coffers significantly. Prior to issuing its 2007 annual report, ICANN maintained an $18 million balance. As a result of its revenue streams in 2007, ICANN now maintains a $35 million balance. There are serious concerns that ICANN is not fulfilling its charitable purposes under U.S. law by building up large reserves, far beyond the "Basic Cost Recovery Principle" set forth by ICANN ten years ago. In effect, ICANN has transformed itself from a cost-based revenue model to one where its revenue will grow with every domain registration and renewal. In this new model, ICANN has an inherent financial incentive to encourage new registrations. Moreover, ICANN continues to grow its revenue by generating demand for registrations whose only real purpose is to prevent cybersquatting and consumer fraud. Moreover, non-profits have recently been subject to increased scrutiny by the IRS and Congress for effectively hoarding their endowments at the expense of achieving the underlying missions that give rise to their tax-exempt status. To avoid any unwanted scrutiny, ICANN should not use the additional revenues it will gain as a result of this new gTLD system for any purpose other than the stated purposes in its Charter and Bylaws. Industry strongly believes that with the new revenue streams created by new gTLDs, ICANN should commit to expending additional resources to ensure the security, stability and integrity of Internet commerce. Such measures should include establishing mechanisms to ensure that trademark holders have adequate and effective tools to protect their intellectual property rights. Summary In viewing the new gTLD Program in light of the existing system, observers have noted that ICANN may not have the ability to manage the possible flood of new gTLD application process. In fact, adding numerous TLDs that may result in large numbers of failing registries to the Internet may actually produce the unwanted and unintended consequence of creating instability and insecurity in the Internet infrastructure. Our comments above highlight the areas of greatest concern. We look forward to working with you, the ICANN Board of Directors and the ICANN staff in strengthening the DNS, and if found to be necessary, helping to explore ways to increase competition without creating the above noted negative externalities. Given the above issues, we suggest that before ICANN proceeds with the new gTLD Program and Process, it should follow these recommendations: * Set aside the flawed economic study submitted to ICANN in March 2009 and undertake a new, comprehensive empirical economic study of the domain name marketplace as mandated by the ICANN Board in 2007, as well as an extensive evaluation of whether new gTLDs are needed in the first place given the record of existing new gTLDs; * Establish criteria for success of ICANN's new gTLD program in the proposed first round - including Internationalized Domain Name TLDs - before moving forward; * Modify the roll-out of the new gTLD program to the limited number of cc IDN TLDs (once the study has been completed and criteria established), treating these cc IDNs as a form of pilot; and * Limit further roll-out of new gTLDs until sufficient safeguards are in place to protect Internet users, businesses, and brand-owners alike from any existing and expected acts of cyber-fraud. We respectfully request that the launch of the new gTLD program be delayed until these issues and recommendations can be adequately addressed. Sincerely, Marc-Anthony Signorino Director, Technology Policy National Association of Manufacturers For The Coalition for Online Trademark Protection The Coalition for Online Trademark Protection is an ad hoc coalition comprised of corporations, trade associations and business groups that represent thousands of multinational companies and millions of employees and Internet users, both in the U.S. and abroad. The Coalition includes the Aerospace Industries Association, The American Advertising Federation, the Consumer Electronics Association, the National Association of Manufacturers, and the U.S. Chamber of Commerce. _____________________________________ Marc-Anthony Signorino Director, Technology Policy Direct: (202) 637-3072 Cell: (202) 494-1290 Email: msignorino@xxxxxxx <mailto:mdavenport@xxxxxxx> National Association of Manufacturers 1331 Pennsylvania Avenue, NW Suite 600 Washington, DC 20004-1790 Check out our blog at www.shopfloor.org <http://www.shopfloor.org/> Attachment:
COTP DAG2 ICANN gTLD Coalition Letter v.3.doc |