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GAC Advice re Safeguards and Community

  • To: comments-gac-safeguard-advice-23apr13@xxxxxxxxx
  • Subject: GAC Advice re Safeguards and Community
  • From: Shaul Jolles <sjolles@xxxxxxxxxxxxxxx>
  • Date: Mon, 13 May 2013 14:39:56 -0500

In the interest of participating in the bottom up model adopted by the
Internet Corporation for Assigned Names and Numbers (ICANN), please accept
these comments on behalf of Dot Registry, LLC with respect to the Section
IV.1.b – Safeguard Advice for New gTLDs and the associated Annex I
(Safeguards) and IV.1.e-Community Support for Applications, of the
Government Advisory Council’s (GAC) Beijing Communique issued on April 11,

Dot Registry, LLC has applied for the extensions “.CORP”, “.INC”, “.LLC”,
“.LLP”, and “.LTD” to be used as business identifiers.  It is the opinion
of Dot Registry, LLC that the Safeguards proposed by the GAC is in the best
interests of registrants, Internet users, and those charged with managing
business registrations.  The benefits achieved by the Safeguards as
proposed by the GAC outweigh the costs, and should be implemented as

ICANN is based on a bottom-up, multi-stakeholder, consensus-driven policy
model.  At the base of this model is the end user.  To disregard the GAC
Safeguards with respect to the business entity identifying strings is to
put the business interests of the Registry operators above the best
interests of those impacted by the new top-level domains. Question 18(b) of
the Applicant Guidebook asked each applicant to detail how the proposed
gTLD will benefit registrants, Internet users, and others, the GAC
Safeguards serve to mitigate the potential harm that would result from the
wide-open use of these business entity identifiers.

With respect to the “.CORP”, “.INC”, “.LLC”, and “.LLP strings, the GAC
Safeguards simply provide clear steps that a Registry operator must
undertake.  Many applications for these strings contain a number of
ambiguous, open-ended restrictions or verification procedures, which cannot
be viewed as being long-term beneficial to registrants or Internet users.
The particular extensions are directly associated to business entity
registration types and represent a clearly defined community in the United
States. Both consumers and businesses readily recognize these abbreviations
as denoting a registered business. Assumptions are made by consumers by
seeing these abbreviations in conjunction with a business name. These
strings are not in need of new definitions created at the discretion of
applicants nor should their importance be taken lightly. The government
officials that manage the legal standing of businesses, business
registrations and corporate filings do not need the added task of
protecting their constituency from business identity theft or
mis-representation online created by the unmonitored, unstructured issuance
of these extensions.  Further, to ensure the long-term integrity of these
extensions we would encourage ICANN to issue these strings under community
designations, which is the only way to provide the necessary securities and
enforcement mechanisms to protect the US registered business community.

Considering the well intentioned yet exceedingly vague commitments made by
a number applicants for the “.CORP”, “.INC”, “.LLC”, and “.LLP” strings, it
is understandable that the GAC would take action and that the action of the
GAC would be received with such resistance.  It is disappointing that those
familiar with the bottom-up, multi-stakeholder, consensus-driven policy
model of ICANN would need a directive to give due consideration to the
businesses and those agencies tasked with managing registering them,
essentially, the true stakeholders and bottom of the model. The fact is, by
applying the GAC Safeguards to strings that designate a business entity you
will insure that the Internet serves the user and strengthens the value
proposition of these strings, creating integrity and confidence for end

Shaul Jolles
Dot Registry, LLC

Attachment: DR_GAC_Beijing_Communique_Public_Comment.docx
Description: Microsoft Office

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