Comments on Draft Report: Rights Protection Mechanisms Review

[amcadory <amcadory@xxxxxxxxxx>]

Hello,

First and foremost, unless ICANN can produce a letter of approval from the
Department of Commerce Contracting Office Representative for the changes to the
Rights Protection Mechanisms beyond those in the Applicant Guidebook, I believe
ICANN is in violation of DOC contract SA1301-12-CN-0035 dated 2 July 2012.  A
contract which also does not allow ICANN to use sub-contractors like Deloitte,
IBM and Verisign for primary functions required to fulfill the requirements of
the contract.

Second, these rights protection mechanisms are ineffectual at best and are
contradictory to ICANN's established practice of requiring Registry Operators to
block the names of parties with standing such as the Red Cross and NGOs. Why
should Red Cross be blocked and not the over 30,000 verified and registered
trademarks such as my own Atgron which is not generic and there would be no
reason for an entity to register the name other than malfeasance.  All non-brand
Registry Operators should be given a list and required to block the non-generic
names of trademarks holders at all levels. This will decrease the cost of
running registries and Registrar businesses because we will not be subject to
endless cease and desist letters and decrease the cost in the market due to far
less UDRP and URS cases.

Warm Regards,
Adrienne McAdory
President & CEO
Atgron, Inc.
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