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Objection to applications for a closed registry in the identity of .CLOUD

  • To: <comments-closed-generic-05feb13@xxxxxxxxx>
  • Subject: Objection to applications for a closed registry in the identity of .CLOUD
  • From: "Andy Burton" <andy@xxxxxxxxxxxxxxxxxxxxxx>
  • Date: Mon, 4 Mar 2013 09:42:13 -0000

Dear Sirs,


We are an industry body representing the Cloud Industry from both a buyer
and supplier perspective.  We represent the interests of our members and we
champion best practice among cloud service providers through a
self-certification process which in turn assists and enables end users to be
make a rational and informed purchase decision for a cloud service.  


We believe that the term 'cloud' in the context of cloud computing is:


1.       A highly generic phrase that is referred to by the industry as a
whole and is not under restriction or ownership by any organisations, but
has become in essence an industry classification.  

2.       Reflective of a nascent and evolving market based upon formal
market research.

3.       Encompassing technology platforms and solutions  that are still
diverging in their innovation.

4.       Giving rise to multiple perspectives in regard to defining cloud
and as such underlines the market confusion and immaturity.

5.       Free from a Trademark in its pure form meaning that it is not
deemed appropriate as a phrase to trademark.  The reasons why cloud could
not be trademarked are sensible to compare to why .cloud should not be
restricted to a single entity. i.e. Trade marks (according to the UK
Intellectual Property Office) are not registrable if they:

a.       describe your goods or services or any characteristics of them, for
example, marks which show the quality, quantity, purpose, value or
geographical origin of your goods or services;

b.      have become customary in your line of trade;

c.       are not distinctive;

d.      are three dimensional shapes, if the shape is typical of the goods
you are interested in (or part of them), has a function or adds value to the

e.      are specially protected emblems;

f.        are offensive;

g.       are against the law, for example, promoting illegal drugs; or;

h.      are deceptive. There should be nothing in the mark which would lead
the public to think that your goods and services have a quality which they
do not.


As such, with the market still nascent and evolving and with a level of
confusion as to what cloud means it would be counter-productive to restrict
the use of .cloud to one organisation.   We reiterate that the phrase cloud
cannot be clearly assigned to any one organisation operating in that market
today and should not be granted as a closed registry.  We are supportive of
the implementation of an open registry for .cloud and any related action
that would enable the use of .cloud domains by any credible cloud service


We request that ICANN only allow registry applications for .cloud that
protects its status as an industry wide classification and enables the
market to continue to evolve and innovate in a healthy competitive


We strongly object to the notion of  .cloud becoming a closed registry.



Yours sincerely,



Andy Burton


Cloud Industry Forum

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email:      <mailto:andy@xxxxxxxxxxxxxxxxxxxxxx> andy@xxxxxxxxxxxxxxxxxxxxxx





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