Opposed to Employ Media sTLD Charter Amendment

["Shelly Mudd" <shelly@xxxxxxxxxxxxxx>]

July 15, 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
USA

By Email To: jobs-phased-allocation@xxxxxxxxx

RE: Employ Media sTLD Charter Amendment

Dear Chairman Dengate Thrush and Members of the Board:

I am writing on behalf of TopUSAJobs.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.

My organization would be directly and adversely affected by this request as
well as several reputable job boards however I oppose the unilateral
expansion of the .jobs charter to encompass regional and industry-specific
second-level registrations due to the fact that this would create a monopoly
with a company proven to not follow the rules, reduce the value of the TLD
for companies that have already purchased a .Jobs extension due to dilution
and would harm the employment website industry.
 
United States antitrust laws prohibit anti-competitive behavior and unfair
business practices. By allowing Employ Media the right to sell all .Jobs TLD
domains as well as have the first right to purchase thousands if not
millions of sites themselves seems to be a violation of these laws. This is
not something that ICANN or the US Government should allow. It's like 1
university controlling the .edu domain or 1 association controlling the .org
domain. 
 
Under SHRM's provision, Employ Media has already proven their lack of
respect for the process by violating the original charter and launching
several industry and location specific .jobs domains earlier this year.
Employ Media's has already admitted to their plan to sell PPC advertising
and give the paid jobs higher priority on the site. If .Jobs takes off and
gains traction with job seekers and search engines, they have created a
monopoly of which they set the price and they create the rules of the game.
The result will be disastrous for job seekers, employers, associations and
job boards.

Since 1993, the community of online employment service companies--job
boards, associations, staffing firms, newspapers and other publications that
operate job posting and/or resume search databases--has effectively served
working men and women and employers worldwide. These same organizations have
also significantly improved the career prospects of veterans, minorities,
disadvantaged persons and those affected by natural disasters such as
Hurricane Katrina. They have, in every respect, acted as "the Sources of
Success," the trademark of the International Association of Employment Web
Sites ( <http://www.employmentwebsites.org>
http://www.employmentwebsites.org), their only industry trade association.

This community is now threatened by the proposed expansion of the .jobs top
level domain (TLD). The charter holder is attempting to extend the
application of the TLD from its approved community--direct employers--into
the online employment services community by introducing geocentric (i.e.,
Atlanta.jobs, NewYork.jobs, Athens.jobs) and occupation specific (e.g.
<http://logistics.jobs> logistics.jobs,  <http://salesperson.jobs>
salesperson.jobs,  <http://systemsanalyst.jobs> systemsanalyst.jobs) web
sites. It now has a proposal to implement this plan before the governing
board of the Internet Corporation for Assigned Names & Numbers (ICANN). 

This proposal violates both the spirit and the letter of the charter
holder's contract with ICANN and should not be approved. 

Sincerely,

Shelly Mudd

VP of Sales and Business Development

TopUSAJobs.com

shelly@xxxxxxxxxxxxxx