AIM comments on Module 5

["Philip Sheppard" <philip.sheppard@xxxxxx>]

We recommend the following changes.
 
Trademark claims
6.1.1 New gTLD Registry Operators must provide Trademark Claims services AT ALL
TIMES for marks in the Trademark Clearinghouse.
(Once set up, to continue to use this service will add large benefit at small
cost).

Sunrise
6.2.1 This notice will be provided to holders of marks in the Clearinghouse that
are an Identical Match OR CONFUSINGLY SIMILAR to the name to be registered
during Sunrise
(Sunrise will only be effective if it matches the behaviour of fraudsters)

URS
2.2 A limited "loser pays" model has not been adopted for the URS. Complaints
listing fifteen (15) or more disputed domain names will be subject to an
Response Fee
which will be refundable to the prevailing party.
(The figure of 26 is arbitrary and does not match the experience of our
members.)




Philip Sheppard
AIM - European Brands Association
9 avenue des Gaulois
1040 Brussels
+32 2 736 0305 www.aim.be