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posted on behalf of Chuck Warren for Overstock

  • To: <biz-alloc-amendment@xxxxxxxxx>
  • Subject: posted on behalf of Chuck Warren for Overstock
  • From: "Marilyn Cade" <marilynscade@xxxxxxxxxxx>
  • Date: Sat, 14 Mar 2009 09:51:41 -0400



Re:  .BIZ 1 and 2 character marketing proposal:  Allocation of .biz single
letter names at the second level 


Neustar, the registry operator of .biz, has proposed to allocation single
and two letter names at the second level for .biz.  My comments are
regarding the allocation of single letters and do not address the allocation
of two letter second level names.   My comments are in support of Neustar's
proposal on single letters at the second level.  They simply do not address
the allocation of two characters. 


The approach proposed by the registry appears, to the best of my knowledge,
to follow the recommendations of ICANN's GNSO Reserved Names Working Group,
which provided for the 'sponsored' registry strings to have the option to
develop additional elements for their allocated string that are suitable to
the circumstances of the string. .biz, while not a fully sponsored category,
is a restricted category, focused on the registration of commercial entities
of any size.


Overstock has indicated its interest in registering and using the single
letter - O - in its online identify and operations, just as it does in its
marketing and business advertising of its core business.  The allocation of
single letters by .biz would enable parties like Overstock to participate in
the proposed RFP process to propose a specific plan for use and promotion of
" o.biz."


While supporting the proposal by NeuStar in general, there is one question
or concern.  Applying for the allocation of and using a single letter in
biz cannot preclude a party from seeking to use a single letter associated
with their trade/brand name in a different gTLD or ccTLD.  In today's
environment, companies often develop unique website or web pages for
different parts of their business, or register and use domain names in
multiple gTLDs and ccTLDs for a variety of reasons. NeuStar's proposal seems
to be a useful approach to limit merely defensive registrations' and to
ensure that the single letters are put into active use.  NeuStar's proposal
appears to require a commitment to use the single letter actively, and not
to merely 'point' the web site to another web site. That is a reasonable
condition, given the objective of deepening the awareness and use of the
biz string; however, such commitment should not preclude the joint
marketing of multiple related addresses in a reasonable manner. Many
companies have website addresses in both gTLDs and ccTLDs, and the
'findability' by consumers/users of the website requires the ability to
provide links between websites, and would require the ability to advertise
for any address that is an active website.  


With the assurance that co-existence of registration and use in more than
one single letter is allowed, as it exists today for other second level
registrations, I support the NeuStar proposal for moving ahead with
allocation of single letters in the manner they have proposed. 


Chuck Warren on behalf of Overstock


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