Re: eUDRP proposal

["Frank Michlick (DomainCocoon)" <frank@xxxxxxxxxxxxxxxx>]

Dear ICANN staff, dear WIPO staff,

Thank you for bringing the eUDRP proposal to our attention. While our 
company, a consultant to registrants, registries and registrars, usually 
likes avoiding wasting paper, we do oppose the eUDRP as proposed.
As George Kirikos already writes, there need to be safeguards in place 
in order to protect registrants from default decisions based on 
non-response, since email may potentially be identified as spam/UCE and 
may never reach the recipient, thus preventing him from filing a 
response. If no response is received after notification via email, the 
registrant should be informed by other means, such as by fax or a 
letter. Considering the complainant is given as much time as they like 
to prepare their complaint, a response time of 20 days is inadequate.
As stated before, if we are updating the UDRP, we must not forget to 
address the recent rise of "reverse hijacking" cases and the lack of 
penalty for those entities that try to gain access to generic domain 
names by means of filing UDRPs. In addition, provisions should be added 
to prevent a complainant from repeatedly filing claims for the same 
domain name.
We also agree with George Kirikos when it comes to introducing a 
standardized format for electronic UDRP filings, allowing the 
development of services for monitoring complaints.
Best regards,
Frank Michlick on behalf of
DomainCocoon Inc.