Uniform Rapid Suspension System (URS) Comments Regarding Typosquatting

["Graham MacRobie" <gmacrobie@xxxxxxxxxxxxxxx>]

In general, I support the effort to refine ICANN policy to help brand owners
respond to the growing and still asymmetric threat of cybersquatting.  In
that regard, I'm optimistic that the IRT's proposed Uniform Rapid Suspension
System (URS) has the potential to significantly reduce trademark abuse in
domain name registrations.

I have not had time to fully digest the proposal, but my initial reading
brings to mind two major concerns:

1)  What stops a third-party entity from intercepting the suspended/error
page and causing parked pages/ads to be delivered instead?  Some browsers
show content (ads) controlled by the browser's manufacturer instead of
standard error pages.  Also, some ISPs intercept nonexistent domain errors
and instead return ads, sometimes powered by services such as Barefruit and
Paxfire.  Having a centralized error page would make it trivially easy for a
browser manufacturer or ISP to become the de facto cybersquatter on all
suspended domains, something that is already happening with nonexistent
domains.  This could be a HUGE boost for them - the currently registered
typosquatting domain names are surely more valuable than the nonexistent
domains (due to years of tasting).  Sure, the brand owners could complain,
but then we're back to where we are now.

2)  Valuable domain names are universally re-registered when they expire and
drop, usually within seconds.  Will the brand owner have to backorder
domains that they suspended and hope to catch them when they drop?  Will
they have to file and pay for another URS for the same domain again and
again, potentially annually?  The proposal states that "brand owners spend
large amounts of money to build up portfolios of domain names they do not
want..." but fails to acknowledge that cybersquatters continue to register
those domains because they generate valuable traffic (particularly
typosquatting domain names).  My guess is that any remedy short of transfer
of the domain name will merely prolong brand owners' aggravating game of
Whac-A-Mole.

To summarize, I like the idea of the URS, but I think the current proposed
implementation has the potential to create a whole new set of problems for
brand owners.

Sincerely,


Graham MacRobie
President and CEO
Alias Encore, Inc.
http://www.aliasencore.com
gmacrobie@xxxxxxxxxxxxxxx