Demand Media Comment Rights Protection Mechanism requirements
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 http://forum.icann.org/lists/comments-rpm-requirements-06aug13/msg00005.html 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 program. Best Regards, Jeffrey Eckhaus [cid:78139159-F125-47AC-A905-1C77B3A800A1] –––––––––––––––––––––––––––––– Jeffrey Eckhaus SVP Corporate Development www.demandmedia.com<http://www.demandmedia.com> eckhaus@xxxxxxxxxxxxxxx O: 425.298.2607 M: 917.750.9890 ________________________________ Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Demand Media, Inc. Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you.