Re: Hearst Communications, Inc. Comment on IRTP Draft Report for Trademark Protections for gTLDs Expansion Program

["Nooger, Daniel A" <dnooger@xxxxxxxxxx>]

Dear Sirs:

    With respect to the IRTP Draft Report for Trademark Protections,
Hearst Communications, Inc. offers the following comments for
consideration for the Final Report:

    1)    The proposals for creation of an IP Clearinghouse and a
Globally Protected Marks list are steps in the right direction.
However, more detailed information will be required regarding:

            a)    criteria for inclusion of information in the IP
Clearinghouse database;

            b)    costs information for initial inclusion and annual
validation;

            c)    operational details for the Watch Service and IP
Claims Service;

            d)    operational details for the Globally Protected Marks
list;

            e)    the proposed criteria for inclusion of a mark on the
Globally Protected Marks list should be reviewed.  The currently
proposed guidelines (number of trademark registrations) may in fact be
too high to provide the intended protection for globally recognized
marks.

    2)    The proposal for the Uniform Rapid Suspension System is again
a step in the right direction.  However, more detailed information will
be required regarding:

            a)    operational details for the URSS including:

                1)    details on how the examiner panels will be
constituted; and,

                2)    the qualifications for the individual examiners;

                3)    mechanism for enforcement by the registrars of the
panels' decisions.   

Sincerely,

Daniel Nooger
Paralegal
Office of General Counsel
The Hearst Corporation
300 West 57th Street
40th Floor
New York, NY 10019
PH:   212-649-2019
FX:    646-280-2019
E-mail:    dnooger@hearst <mailto:dnooger@hearst> .com