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Proposed Renewal of .TRAVEL Sponsored TLD Registry Agreement

  • To: comments-travel-renewal-12may15@xxxxxxxxx
  • Subject: Proposed Renewal of .TRAVEL Sponsored TLD Registry Agreement
  • From: John Poole <jp1@xxxxxxxxx>
  • Date: Mon, 25 May 2015 11:10:30 -0500

Dear ICANN:

Re: Proposed Renewal of .TRAVEL Sponsored TLD Registry Agreement issued for
public comment on May 12, 2015.

This is written in opposition to the inclusion of a modified version of the
new gTLD rights protection mechanisms in Specification 7 of the proposed
RA, especially Uniform Rapid Suspension (URS). ICANN should not further
damage nor contaminate the domain name ecosystem by imposing aspects
of its ill-conceived,
misbegotten, and "horribly implemented" new gTLDs program
<http://www.domainmondo.com/2015/04/the-dot-sucks-conundrum-icann-ftc-oca.html>
upon any of the incumbent or "legacy" gTLDs (generic top-level domains). If
anything, ICANN should be directing all of its time and resources to
remediation of its defective, unpredictable, and unfair UDRP program
<http://www.domainmondo.com/2015/03/icann-hates-fairness-and-predictability.html>
.

All the new gTLD RPMs were implementation details of the new gTLD program
and are *not* ICANN consensus policies applicable to all registries and
registrars. The URS can become a consensus policy only after a full policy
development process (PDP) engaged in by the entire ICANN community of
stakeholders. The ICANN community has not even received the new gTLD RPM
Issues Report that staff will be providing to the GNSO in September 2015.
Imposing URS on an incumbent gTLD via the contracting process is an
absolutely unacceptable staff intervention into the policymaking process.
Approval of this draft contract would constitute top-down, staff-driven
policymaking in direct violation of ICANN’s stated commitment to the
bottom-up, private sector led policy development process. Furthermore,
the public
comment notice posted by ICANN staff
<https://www.icann.org/public-comments/travel-renewal-2015-05-12-en> is
defective in its failure to even mention the URS or its imposition in the
.TRAVEL sponsored TLD Registry Agreement.

Therefore, the .Travel renewal RA should be referred for Board
consideration only after Specification 7/URS has been removed from the
agreement, along with all other provisions derived from the new gTLD RA
that are not established consensus policies applicable to incumbent gTLDs.

Sincerely,

John Poole
Domain Name Registrant *and*
*Editor,* Domain Mondo <http://www.domainmondo.com> *and*
*Managing Director,* Expri Communications LLC

Attachment: dotTravelMay2015.pdf
Description: Adobe PDF document



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