Please Reject .jobs Phased Allocation Program
Please accept the attached comments submitted by SalesGravy.com in opposition to the Employ Media request. We have attached below and as a PDF document. Dear Chairman Dengate Thrush and Members of the Board, I am writing on behalf of my company SalesGravy.com, to urge you to reject Employ Media's request for authority to permit second level registration of strings that do not correspond to an employer's name in the .jobs sponsored top level domain. About My Company SalesGravy.com is a company that I personally founded in 2006. Since that time we have worked tirelessly to build what is now the largest sales specific job board and career website in North America. We have done what every small business most do to grow - sacrificing our time, money and resources to build a business from the ground up. We were unprofitable for our first two years and we did not have the luxury of venture money or angel investors. However, just as our brand recognition is gaining a foothold and we are finally in the black, we find that we face the greatest threat to our business yet. Creates an Unfair Advantage It is not that we oppose competition. I've always believed that competition makes us stronger. But the unilateral expansion of the .jobs charter to encompass regional and industry-specific second-level registrations creates an unfair advantage in the market place that directly and adversely affects our business and livelihood. We believe that this expansion, if allowed, will destroy the business we have worked so hard to build. That hurts our employees, vendors and our families. Under the terms of ICANN's request for proposals for new sTLDs dated 15 December 2003 (the "sTLD RFP"), applicants - including Employ Media - were required to demonstrate that the proposed sTLD addresses the needs and interests of a clearly defined community (the Sponsored TLD Community). In addition, applicants were required to demonstrate that the policy-formulation procedures for the sTLD operate primarily in the interests of the Sponsored TLD Community, and that the proposed sTLD enjoys broad based support of the Sponsored TLD Community.[1] In its application, Employ Media proposed to serve the needs of human resources professionals responsible for human resources management in the corporate setting, and pledged to maintain .jobs as "a name space for employers."[2] It also promised to limit registrations to the legal name of an employer and/or a name or abbreviation by which the employer is commonly known and to prohibit registration of occupational and industry, and geographic identifiers."[3] Employ Media's current request for to permit the "registration, use, and promotions of domains that are not the company names of the registrant"[4] would fundamentally alter the Sponsored Community for the .jobs sTLD and eliminate its pledge not to create second level registrations of regional and industry-specific job boards. Please Reject We strongly disapprove of Employ Media's plans to add second level registrations that will be confusingly similar to established job boards like SalesGravy.com. ICANN should not permit sTLD operators to "route around" the sponsorship eligibility requirements in the sTLD RFP and the protections built into the .jobs Registry Agreement to prevent "abusive registration activities and other activities that affect the legal rights of others."[5] Approval would undermine the credibility of ICANN's commitments in connection with the introduction of new top level domains in general, and "community based" TLDs in particular. [1] http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03 .htm 2 sTLD Applicant responses to request for further information, at page 48 of 177 http://www.icann.org/en/tlds/stld-apps-19mar04/PostAppC.pdf 3 Id. 4 http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf (hereinafter, Employ Media RSEP Request") 5 .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2. "Community Value Criteria") Sincerely, Jeb Blount CEO SalesGravy.com Jeb Blount | SalesGravy.com <http://www.salesgravy.com/> |ReachSales.com <http://www.reachsales.com/> | Jeb's Blog <http://salesgravy.com/JebsBlog/> | Jeb's Podcast <http://sales.quickanddirtytips.com/> | People Buy You <http://www.peoplebuyyou.com/> Office: 706-664-0810 x102 | Fax: 706-664-0811 Email: jeb@xxxxxxxxxxxxxx | Twitter: @salesgravy <http://www.twitter.com/salesgravy> | LinkedIn <http://www.linkedin.com/in/jebblount> | Facebook <http://www.facebook.com/salesgravy> SalesGravy <http://www.peoplebuyyou.com/> People_Buy_You_Cover.jpg The world's number one source for sales talent. _____ [1] http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03 .htm [2] sTLD Applicant responses to request for further information, at page 48 of 177 http://www.icann.org/en/tlds/stld-apps-19mar04/PostAppC.pdf [3] Id. [4] http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf (hereinafter, Employ Media RSEP Request") [5] .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2. "Community Value Criteria") Attachment:
ICANN_0710.doc |