Note to ICANN Staff: INTA calls for flooding EOI comment area

[Antony Van Couvering <avc@xxxxxxxxxxxxxxxxxxxx>]

ICANN staffers reading EOI comments should be aware that the International 
Trademark Association (INTA) sent out an anti-EOI message to its membership 
(full text below), exhorting them to comment, suggesting that merely 
registering their opinion would be sufficient as a "comment."  This letter was 
followed by predictable results: the last four messages among the EOI comments 
are brief, opinionated, lacking in analysis of the issues, and anti-EOI.  

INTA members are not unanimous in their viewpoint.   For example, Minds + 
Machines is an INTA member and we support the Expressions of Interest 
procedures. Surely the INTA leadership's call to spam the comment area flouts 
the spirit of the comment process, where comments are solicited to elicit ideas 
and analysis, not the parroting of a party line. The INTA-inspired comments to 
date are dashed-off "anti" messages without consideration or analysis. 

Trademark owners who participate at ICANN, and have listened to the concerns of 
the many stakeholders in the process, are by no means united against EOIs, and 
some welcome it as a useful compromise. 

We look forward to the eventual legitimate comments of INTA, but their spam 
campaign only weakens the viewpoint they champion. One depressing result of 
INTA's action is that others with strongly-held views will feel compelled to 
follow suit and bombard the comment area with unhelpful noise. 

We can only hope that ICANN tabulators do not give undue weight to these 
one-line "me too" comments.  They are to reasoned comments as deep-fried 
twinkies are to a healthy dinner -- lots of calories, no protein, and 
ultimately very unhealthy.  

Sincerely,

Antony Van Couvering
CEO, Minds + Machines



For the record, here is the blast from INTA to its membership:

Dear INTA Members,

The following notice is to bring to your attention two Internet domain name 
system developments that warrant your consideration and potential action.

     1. ICANN is Soliciting Input: Should it Proceed with Pre-Registrations for 
New gTLDs?

The Internet Corporation for Assigned Names and Numbers (ICANN) is seeking 
community views, including input from trademark owners and their 
representatives, on whether it should begin accepting "pre-registrations" for 
new generic Top Level Domains (gTLDs). Please click here for the ICANN 
announcement.

INTA's Internet Committee will submit comments opposing pre-registration, but 
it is important that ICANN also hear from trademark owners directly. Your 
comment can be as brief as stating whether you do or do not support ICANN 
accepting pre-registrations for new gTLDs.

ICANN is accepting input from the community on the proposed pre-registrations 
until Wednesday January 27, 2010.

Please submit your input to ICANN by sending an email to 
draft-eoi-model@xxxxxxxxx and make sure to follow the email confirmation 
process after submitting your comment.

Background

ICANN continues to set no limits on the number of new gTLDs it intends to add 
to the Internet's addressing system.  Due to complexities in implementing its 
unlimited new gTLD program, ICANN recently announced it would no longer 
estimate when it would accept applications.

However, at the same time, ICANN is now seeking community input on whether it 
should proceed with accepting pre-registrations for new gTLDs, at the rate of 
US $55,000 each.  According to the draft model's terms, only those entities 
that participate in pre-registration will be eligible to apply for a new gTLD 
in the first round.

ICANN has publicly committed to resolving what it considers to be the 
overarching issues with its unlimited new gTLD program, including trademark 
protection, economic demand and impact, root zone scaling, and malicious 
conduct, before it would introduce any new gTLDs.

However, INTA continues to believe these overarching issues remain unresolved 
and that ICANN has not done the necessary work to demonstrate that the 
potential benefits of its unlimited new gTLD program outweigh the risks, harms 
and costs to the domain name system and to the public. Therefore, INTA believes 
that it is premature for ICANN to accept pre-registrations, and that the 
proposed pre-registration process will have harmful ramifications such as 
forcing trademark owners to defensively pre-register to protect their 
trademarks.

<snip>