Recommendations of IRT not acceptable.

[kannan <primuskannan@xxxxxxxxx>]

Hello ICANN,

Please consider the following objections,

The Uniform Rapid Suspension (URS) proposal would effectively displace the
UDRP at all new gTLDs and substantially diminish registrants’ procedural and
substantive due process rights. The extreme low cost of filing complaints
(as little as $1.50 per domain in mass filings) and the lack of effective
sanctions (abusive complainants barred from the URS for one year, and then
only after three separate incidents of abuse, with no monetary sanctions or
indemnification requirements) would encourage abusive complaint filings.
There is also a lack of effective or affordable substantive appeals
procedures for registrants who believe that their domains have been unfairly
suspended. Further, trademark interests have already voiced the goal of
imposing the URS on incumbent gTLDs, including .com, soon after its adoption
for new gTLD.

Hope you would take the views of the domaining community and reject the
recommendations of the IRT.


Yours Sincerely
Kulasekaran.