Comment on Proposal for .brand Specification 13

[Stefan Pleyer <stefan.pleyer@xxxxxxxxxxxxxx>]

Dear ICANN,

thank you for the opportunity to comment on the proposal for Specification
13.

SDS, the applicant for .LIDL, .SCHWARZ and .SCHWARZGROUP is supportive of
many of the comments submitted by or on behalf of various prospective
brand-TLD registries.

In particular, SDS:

1) does not see the value of implying the trademark clearinghouse in any
way in determining whether or not a TLD is functioning as a "brand-TLD",
because this is outside the mandate of the trademark clearinghouse;

2) is of the opinion that it suffices to provide ICANN with supporting
materials (like a trademark registration) if the applicant has made a claim
that its TLD will be a brand-TLD;

3) requests ICANN to exempt brand-TLD registries that qualify under
Specification 13 from using the trademark clearinghouse in its capacity of
registry. Since the new Specification 13 requires a brand-TLD registry to
only allow domain name registrations by the registry itself, affiliates
and/or licensees, we think that the risk of cybersquatting in these TLDs
will be low, if not non-existing. The objective of the trademark
clearinghouse is to prevent - to a certain extent - cybersquatting in the
start-up phase of a new gTLD. This concern is, in our view, removed by the
requirements currently set out in Specification 13.


Respectfully submitted,

Max Killinger



Schwarz Domains und Services GmbH & Co. KG, Stiftsbergstraße 1, 74172
Neckarsulm
Kommanditgesellschaft, Sitz: Neckarsulm, Registergericht Stuttgart HRA
727242