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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: "ACHSA" <achsa@xxxxxxxxxxxxx>
  • Date: Tue, 13 Jul 2010 18:18:07 -0400

July 13, 2010


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 ACHSA Career Center, part of the National
Healthcare Career 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.
The ACHSA 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.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 the ACHSA 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



Willma Miles

Executive Director

American Correctional Health Services Association



2 sTLD Applicant responses to request for further information, at page 48 of


3 Id.

4 Id.

5 http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf
(hereinafter, Employ Media RSEP


6 Id.

7 .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2.
"Community Value Criteria")

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