Note to ICANN Staff: INTA calls for flooding EOI comment area
- To: draft-eoi-model@xxxxxxxxx
- Subject: Note to ICANN Staff: INTA calls for flooding EOI comment area
- From: Antony Van Couvering <avc@xxxxxxxxxxxxxxxxxxxx>
- Date: Tue, 12 Jan 2010 00:42:29 -0500
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.
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
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
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.
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