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Demand Media Comment ­ Rights Protection Mechanism requirements

  • To: "comments-rpm-requirements-06aug13@xxxxxxxxx" <comments-rpm-requirements-06aug13@xxxxxxxxx>
  • Subject: Demand Media Comment ­ Rights Protection Mechanism requirements
  • From: Jeff Eckhaus <eckhaus@xxxxxxxxxxxxxxx>
  • Date: Wed, 18 Sep 2013 08:52:18 -0700

Demand Media Public Comment – Rights Protection Mechanism requirements

Demand Media is grateful for the opportunity to reply to previously submitted 
comments on the published Rights Protection Mechanism (RPM) requirements. 
Specifically we would like to highlight and agree with the comments submitted 
by ARI Registry Services and the issue of Credentials and Testing

Section 1.5 – Credentials and Testing
“Registry Operator MUST NOT accept a Sunrise Registration (as defined in 
Section 2 below) or Claims
Registration (as defined in Section 3 below) from any registrar that has not 
completed Integration
Testing. ICANN and the TMCH Sunrise and Claims Operator will maintain a list of 
registrars that have
completed Integration Testing and make such list available to Registry Operator 
either through
ICANN’s website or the Trademark Clearinghouse’s website. Such list will be 
updated by ICANN on a
daily basis.”

Demand Media questions the reasoning behind this new requirement proposed by 
ICANN and would like to point out that it serves no technical purpose, as there 
is no interaction between the TMCH and a Registrar during the Sunrise period.
The only product of this requirement is additional technical burdens placed on 
Registrars who are already diligently working to implement the requirements of 
the 2013 RAA in time for the launch of new gTLDs.

Let’s remember that ICANN has already mandated in the Registry Agreement that 
to be a Registrar for new gTLDs a Registrar must have signed the 2013 RAA and 
implemented all of the new protections included. As a Registrar, we can state 
that this is not a trivial task, but one that we have accepted to take on for 
the improvement of the ICANN community and for the benefit Internet users.

To be clear, we are asking ICANN to amend the RPM requirements document and 
remove the term “Sunrise Registration” from Section 1.5.  There is no 
demonstrable technical need for this requirement nor is this requirement needed 
to implement any of the trademark protections that are built into the new gTLD 

Best Regards,

Jeffrey Eckhaus

Jeffrey Eckhaus
SVP Corporate Development
O: 425.298.2607
M: 917.750.9890

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