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Opposition to Employ Media Request to Change sTLD Charter

  • To: <jobs-phased-allocation@xxxxxxxxx>
  • Subject: Opposition to Employ Media Request to Change sTLD Charter
  • From: "Sherry Reisman \(RW\)" <sherry@xxxxxxxxxxxxxxxxx>
  • Date: Tue, 13 Jul 2010 09:17:27 -0500

Peter Dengate Thrush, Chairman

Members of the Board of Directors

International Corporation for Assigned Names and Numbers

Internet Corporation for Assigned Names and Numbers

4676 Admiralty Way, Suite 330

Marina del Rey, CA 90292-6601



Dear Chairman Dengate Thrush and Members of the Board:


ASAE is a membership organization of more than 22,000 association executives
and industry partners representing

more than 11,000 organizations. Its members manage leading trade
associations, individual membership societies

and voluntary organizations across the United States and in nearly 50
countries around the world. ASAE

CareerHQ.org is ASAE's career center and the premier job board for
association management professionals.

CareerHQ.org, which began operating online in 1999, has been named a Top 100
Job Board by WEDDLE's, the

world's largest publisher of print guides to job boards and referred to as
the "Zagat" of the online employment

industry by the American Staffing Association. ASAE leads the ASAE
CareerHQ.org Network, a partnership of job

boards run by Societies of Association Executives from across the country.


I am writing on behalf of the Kansas Psychological Association Career Center
Network 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.  Kansas
Psychological Association Career Center, which

would be directly and adversely affected, opposes the unilateral expansion
of the .jobs charter to encompass

regional and industry-specific second-level registrations.


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

6 the Sponsored TLD Community, and that the proposed sTLD enjoys broad based
support of the Sponsored TLD



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 The limited nature of the .jobs Sponsored Community is
reflected by the applicant's commitment to

limit registrations to the legal name of an employer and/or a name or
abbreviation by which the employer is

commonly known. According to the sTLD Application, "due to restrictions set
forth in this proposal, a registration

in the .jobs sTLD will be associated with an employer,"3 and Employ Media
committed to prohibit registration of

occupational and industry, and geographic identifiers."4 The bottom line is
that as proposed by Employ Media and

approved by ICANN, the .jobs sTLD is intended to serve HR professionals and
recruiting firms representing direct

employers only, in each case by using the legal name of such employers as a
registration at the second level. That

community does not include online employment services providers like Kansas
Psychological Association Career Center,

 nor did Employ Media demonstrate the support of online employment services
providers in connection

with the .jobs sTLD Application.


Employ Media's current request for authority to permit the "registration,
use, and promotions of domains that are

not the company names of the registrant"5 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.

Employ Media did not attempt to demonstrate the support of online employment
services providers and their

vendors, and in fact went out of its way to avoid contacting job board
operators about the proposed expansion.6

This is not surprising, given that Employ Media intends to add second level
registrations that will be confusingly

similar to established job boards.


As a material change to the .jobs Registry Agreement, this request must be
reviewed by the ICANN Board based on

applicable criteria from the sTLD RFP. Under those criteria, the request
should be rejected as an attempt 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."7

Approval of the .jobs Phased Allocation Program would threaten the integrity
of the RSEP process and undermine

the credibility of ICANN's commitments in connection with the introduction
of new top level domains in general.



Sherry Reisman

Executive Director

Kansas Psychological Association




Thank you,



Sherry Reisman

Executive Director

Kansas Psychological Association

Phone: (866)860-7313  Fax: (800)784-9034 



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