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gTLD registration comments and objections

  • To: <comments-closed-generic-05feb13@xxxxxxxxx>
  • Subject: gTLD registration comments and objections
  • From: "Jason Bere" <JBere@xxxxxxxx>
  • Date: Wed, 13 Mar 2013 15:48:47 -0400

Regarding the upcoming change to the creation of top-level generic TLDs,
we at Fitch Surveillance Systems have a few general observations to make
and one very specific complaint.


In specific, we note the application by Symantec to control the
.security TLD as a closed domain. We are opposed to anyone operating
this domain as closed, because it is not in the best interests of the
security industry. Symantec, a vendor of information systems security,
simply does not represent security in a broad sense. They do not provide
security services such as intrusion alarms, CCTV, access control,
security guards, or many other aspects which could reasonably be
considered part of a .security TLD.  Even if Symantec were to provide
such services however, operating as a closed domain would give them an
unfair competition advantage, giving them the ability to control who can
advertise competing services to their own.  This would be
anticompetitive and against the public interest.


In general, this does not merely apply to Symantec. Our concern applies
to any company that would attempt to register such a diverse term as
"security" as a closed domain.  If a company registers a TLD of
".security", or other generic name, it must be a registration open to
anyone to join, such as exists for current TLDs like .com and .net. We
do not deny corporations such as Symantec the right to register a closed
generic domain, but we would expect such registrations to be similar to
trademark registrations.  They could register the .symantec domain
without worry as that is their trademark, and no one else has the rights
to use Symantec in a computer context.  They cannot register "security"
as a trademark because the word is too generic, and so we would expect
such a word to be too generic for a closed domain.


Using this as an example, we would expect that ICANN reject any request
for a closed generic TLD on any name that is in itself generic, whether
".security" or otherwise.  We would suggest this be made clear as part
of the terms for registering new generic TLDs.  This should be the case
whether the proposed domain is ".security", ".computer", ".sale",
".home" or any other generic name.  All of these, if allowed to be
registered, must be registered as open domains.  If an existing
application has been made for one of these TLDs as a closed domain, the
application should either be rejected outright or required to open the


We firmly believe that any company that wishes to operate a generic TLD
should support the interests of all who might benefit from that domain.
Closed TLDs support only the interests of the company that registers
them, and should be rejected when not also in the public interest.



Jason Bere

Fitch Surveillance Systems Inc.


14 Meteor Drive
Toronto, Ontario
M9W 1A4

P (416) 235-1818 ext. 336
F (416) 235-1226 


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