No to "Closed Generic" gTLD Applications
Dear Sirs As lawyer specialising in technology and the cloud sector, I regularly advise cloud service providers and users. From my discussions with providers and users alike - and in my own view allowing one entity to run a closed a generic TLD such as .CLOUD would create confusion and could distort the market. My cloud provider clients would not be able to register a .CLOUD domain and would have to explain to the market why, as a cloud company, they don't have a .CLOUD domain. My cloud user clients might unfairly prefer a cloud provider simply because it is the owner of a closed .CLOUD domain. The view of DMH Stallard is that allowing one commercial organisation to turn a generic term, cloud, into a closed .CLOUD domain registration scheme could be anti-competitive. A scheme which excludes the wider cloud sector in favour of one organisation is unlikely to "promote competition, consumer trust, and consumer choice" a key tenet of ICANN's Affirmation of Commitments. A new .CLOUD domain should be managed by a not-for-profit registrar as an open domain, allowing all those who operate in the cloud sector to apply to register under the usual processes. Yours faithfully ________________________________ Frank Jennings Partner For and on behalf of DMH Stallard LLP Tel: +44 (0)1293 605018 Mobile: +44 (0)7841 065608 Corporate Law Firm of the Year 2012 Insider Dealmakers Awards www.dmhstallard.com <http://www.dmhstallard.com/> DMH Stallard LLP is a limited liability partnership registered in England (registered number OC338287). Its registered office is at Gainsborough House, Pegler Way, Crawley, West Sussex, RH11 7FZ and it is authorised and regulated by the Solicitors Regulation Authority. The term partner is used to refer to a member of DMH Stallard LLP. A list of the members of the LLP may be inspected at the registered office. Please click here to see our disclaimer <http://www.dmhstallard.com/site/home/Disclaimer.html> Please don't print this email unless you really need to.