Acronym domains are widely used and should not be reserved for IGOs and INGOs

[Nat Cohen <ncohen@xxxxxxxxxxxxx>]

Subject:  Draft Final Report on Protection of IGO and INGO Identifiers in
All gTLDs

Thank you for the opportunity to submit a comment on this topic.

The proposal to reserve commonly used acronyms for IGOs and INGOs in
established TLDs is a tremendous overreach by International Organizations.
 In essence, the organizations are claiming all the IP rights to short
acronyms that are in widespread commercial use by a entities around the
globe.  These international organizations have no greater claim to these
acronyms than any other legitimate user.

International organizations have available for their use .int and .org
extensions that are associated with International Organizations and
non-profit organizations.  There is no need to seize turf on what is
traditionally the commercial internet of .com and .net by claiming
exclusive rights to acronym domains under these extensions.

Many of the organizations in the list of acronyms under consideration for
special protections are obscure and their acronyms are not well known to
the public.    There is no basis or justification to privilege the
interests of the Int'l Organizations over other users of these acronyms.
 This is a strikingly misguided initiative that takes a well grounded
interest in avoiding confusing misuse of the names the world famous
organizations, the Red Cross and the Olympics, to launch a groundless
seizure of all domains associated with the acronyms for hundreds of
international organizations.

There is a very good reason why historically the protections afforded to
the Red Cross and the Olympics are restricted to these particular
organizations that are well known to hundreds of millions of people
worldwide.  The rationale for the special protections for these two
organizations does not extend to every obscure international organization
ever created, and certainly not to acronyms that these organizations share
with hundreds or thousands of other entities.

By way of example let us take a look at some of the acronyms used in the
text of the Overview of the Report and the use made of the dot-com domain
based on those acronyms-

igo.com - maker of accessory chargers for travelers
ingo.com - an arts and cultural organization
pdp.com -  producer of gaming accessories
ioc.com - media storage company

This small example demonstrates that acronyms have many concurrent
legitimate uses.  IGOs can adequately protect their intellectual property
and reputations without adopting a policy that prevents the long-standing
and legitimate use of acronym domains by commercial users.

I also write in favor of the comments submitted by George Kirikos and Alex
Lerman.

Respectfully submitted,

Nat Cohen
President
Telepathy, Inc.