Concerns regarding URS, Stronger Penalties for Reverse Hijacking attempts

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

Dear ICANN staff, dear community, dear IRT,

While the recommendations of the IRT are initially meant to protect 
trademark holders for the introduction of new TLDs, it seems obvious 
that it would be attempted to adopt similar policies for existing TLDs. 
No matter if for existing or new TLDs, we are against the implementation 
of the IRT recommendations without any significant changes.
Unfortunately it is obvious from the report, that the team only took the 
rights of trademark owners into consideration when preparing their 
report, leaving aside technical needs/requirements, legitimate privacy 
concerns as well as the existing laws already protecting trademark 
owners today.
Our biggest concern in the existing proposal is the suggested Uniform 
Rapid Suspension System (URS). Such a system could affect the stability 
and functioning of the Internet. The suggested implementation clearly 
shows a lack of understanding of the technical details of DNS, since DNS 
does not only serve for resolving websites, but provides many other 
vital functions for the Internet. Thus the implementation of the URS 
would pose a big potential for abuse.
A 14 day notification period and a sole notification via email is not 
sufficient, taking into account potential vacations and current 
email/spam volumes.
If we are considering a reform of the UDRP and related processes, we 
must also review the penalties for entities found guilty of potential 
reverse hijacking attempts of domain names by means of a dispute.
Sincerely,
Frank Michlick
Founder DomainCocoon Inc.
--
DomainCocoon Registry/Registrar Consultants
http://DomainCocoon.com/