urge you to reject Employ Media's request for authority to permit second level registration

[Richard Thomas <rthomas@xxxxxxxxxx>]

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
USA

RE:  Opposition to Employ Media Request to Change STLD Charter
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 American Anthropological Association 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.  American Anthropological Association's 
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 the Sponsored TLD 
Community, and that the proposed sTLD enjoys broad based support of the 
Sponsored TLD Community.
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."   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," and Employ 
Media committed to prohibit registration of occupational and industry, and 
geographic identifiers."   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 American 
Anthropological Association's 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"  
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.   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."   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
Sincerely,

Richard Thomas
American Anthropological Association
Member Services Division



Thanks,
Richard Thomas
Manager, Member Services
American Anthropological Association
703 528 1902 x 1177