Opposed to the inclusion of URS in the .CAT registry agreement

[Nat Cohen <ncohen@xxxxxxxxxxxxx>]

I am writing in regard to the Proposed Renewal of .CAT Sponsored TLD
Registry Agreement issued for public comment on May 28, 2015.

I am strongly *opposed* to the inclusion of the Uniform Rapid
Suspension (URS) in the registry agreement.

All the new gTLD RPMs were implementation details of the new gTLD program
and are not ICANN consensus policies applicable to all registries and
registrars. The URS can become a consensus policy only after a full policy
development process (PDP) engaged in by the entire ICANN community of
stakeholders. The ICANN community has not even received the new gTLD RPM
Issues Report that staff will be providing to the GNSO in September 2015.

Imposing URS on an incumbent gTLD via the contracting process is an
absolutely unacceptable staff intervention into the policymaking process.
Approval of this draft contract would constitute top-down, staff-driven
policymaking in direct violation of ICANN’s stated commitment to the
bottom-up, private sector led policy development process.

The URS is an untested RPM that was incorporated into the launch of
the new gTLDs.  Any registrant of a new gTLD knew that the URS was
part of their registration agreement.  The situation is far different
from those who have registered the hundreds of millions of domains
under .com, .net, .org, .cat, .pro, .travel and other legacy
extensions.  The imposition of URS on these legacy extensions would
weaken the ownership rights to all owners of legacy domains on which
the current robust Internet is built.  It is wholly illegitimate to
undermine the foundation of ownership rights in legacy domains through
staff usurping the role of the stakeholder community to develop
policy.

URS should be removed from the agreement, along with all other
provisions derived from the new gTLD RA that are not established
consensus policies applicable to incumbent gTLDs.

I also write in support of the comments submitted on the .travel
renewal which raises nearly identical issues by Phil Corwin, Jay
Chapman, Rook Media, George Kirikos, Robin Gross and eCorp.

Thank you for your consideration.

Regards,

Nat Cohen
President
Telepathy, Inc.