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Comments on Module 5 by IHG

  • To: <2gtld-transition@xxxxxxxxx>
  • Subject: Comments on Module 5 by IHG
  • From: "Goodendorf, Lynn (IHG)" <Lynn.Goodendorf@xxxxxxx>
  • Date: Thu, 9 Apr 2009 10:37:13 -0400

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


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

Below are our comments on Module 5.


Module 5: Transition to Delegation

Fraud and Malicious Conduct

ICANN should 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.

Contract Terms and Conditions

In order to realize the benefits of new gTLDs, we submit that there is a
need to strengthen and improve terms and conditions in both Registry and
Registrar Agreements.

We recommend the following areas for improvement:

a)            Enforceable Contract Obligations.

b)            Accurate and transparent Registrant or Applicant
Identification and Contact details.

Respectfully submitted,

Ms. Lynn Goodendorf

VP Corporate Risk & Data Privacy




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