.PARIS Launch Program

[Francois Seguy <francois.seguy@xxxxxxxxxxx>]

Dear Madam, Dear Sir,


IP TWINS is an ICANN accredited registrar based in Paris. Founded in 2002, our 
company has been created in order to provide trademark owners and their 
representatives, services to protect their intellectual property assets in the 
digital area. The launch of a new extension dedicated to the French capital is 
of course a great source of joy and pride for us as French, as Parisians and as 
registrar.

However, our main concern is linked to the Dot PARIS Launch program. Indeed, it 
seems that the Sunrise Period plans a priority system within the Sunrise period 
like other Registries have already done (cf. Dot London Registry). But, if we 
understand correctly, the specificity of this Sunrise will be to give priority 
to (French) non-TMCH trademarks over TMCH trademarks. To the best of our 
knowledge, such a priority has never been applied by another registry yet and 
we would like to express reservations about this draft.

Even if we can easily understand that it is a logical way to advantage the 
trademark owners with a stronger relationship with France and Paris, we are 
afraid that this particularity will be taken as a retroactive change of an 
ICANN policy, not to say as a breach of ICANN rules as the TMCH would be thus 
be bypassed.

In other words, we are that much fans of .PARIS that we fear that such a 
measure would taint its reputation and future success.

Since the launch of the new gTLDs and even before, IP TWINS like the other 
registrars, is working hard to warn and teach Trademark owners about the 
advantages and also the possible dangers of the launch of hundreds of new 
extensions. The TMCH was easily perceived as a mean of protection. Therefore, 
we consider that this change will be very hard to understand for the majority 
of Trademark owners.

Since this proposition undermines a fundamental principle of right protection 
mechanisms (required by Trademark owners), we believe that it should not be 
accepted by ICANN.

To conclude, may we draw your attention to the fact that the acceptation of 
such a change, in setting a precedent, may weaken the TrademarkClearingHouse in 
its role of mechanism of Trademark owner protection and may also create legal 
uncertainty.

Hoping that our opinion can be taken into account.

Respectfully,

Sylvain Hirsch,
President, IP Twins

IP TWINS
6 rue du Conservatoire
75009 PARIS
Phone : +33.1 42 78 93 12
www.iptwins.com<http://www.iptwins.com>
sylvain.hirsch@xxxxxxxxxxx