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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: "Glenda Henning" <GHenning@xxxxxxxxxx>
  • Date: Wed, 14 Jul 2010 12:48:51 -0400

Please see the attached letter in opposition to Employ Media's request
to change sTLD charter (included in email below).



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



RE: Opposition to Employ Media Request to Change sTLD Charter


Dear Chairman Dengate Thrush and Members of the Board:


The American Council for Technology (ACT) is a non-profit educational
organization created by government executives to assist government in
serving the public through the effective and efficient acquisition of
information technology (IT) resources. ACT provides education,
programming, and collaboration opportunities to enhance and advance the
government IT profession. ACT established the Industry Advisory Council
(IAC) to provide an objective, vendor and technology-neutral and ethical
forum where government and industry can collaborate on improving
government through technology.  ACT-IAC serves approximately 7500
individuals and government associates.  Its members are part of the
joint government and industry IT community with the mission of better
government through the use of information technology and collaboration.
The ACT-IAC Career Center (and job board) acts to connect skilled
industry and government IT professionals within a unique marketplace.


I am writing on behalf of the ACT-IAC Career Center 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 ACT-IAC Career Center, which would be directly and
adversely affected, opposes the unilateral expansion of the .jobs
charter to encompass regional and industryspecific second-level


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



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 ACT-IAC 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.





Glenda Henning

Deputy Executive Director












2 sTLD Applicant responses to request for further information, at page
48 of 177


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")



Glenda Henning

Deputy Executive Director

The American Council for Technology and Industry Advisory Council

3040 Williams Drive, Fairfax, VA 22031 .  (703) 208 - 4800 x 203 .



ACT-IAC Career Center:  The place for employment connections in the
government IT community -

Visit  http://www.actgov.org/CareerCenter


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