Seriously Opposed to Employ Media Request to Change sTLD Charter

[Rick Myers <rickm@xxxxxxxxxxxxx>]

Dear Chairman Dengate Thrush and Members of the Board:

I am writing on behalf of Talent Zoo 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 company, and many others, would be directly and adversely affected by
this request. 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, and do so with a company
proven to not follow rules, while reducing the value of the TLD for
companies that have already purchased a .Jobs extension.

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 is a violation of these
laws.

Granting Employ Media this monopoly is not something that ICANN or the
US Government should allow.  It is the equivalent of one university
controlling the .Edu domain or one 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.

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), 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.
logistics.jobs, salesperson.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).


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

Cordially,

Rick Myers

CEO,

Talent Zoo

www.TalentZoo.com