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Opposition to the .jobs Phased Allocation Program

  • To: "jobs-phased-allocation@xxxxxxxxx" <jobs-phased-allocation@xxxxxxxxx>
  • Subject: Opposition to the .jobs Phased Allocation Program
  • From: "Gilison, Steve" <steve.gilison@xxxxxxxxxxxxxxxxxx>
  • Date: Wed, 14 Jul 2010 10:47:04 -0700

The comments below and attached are submitted by Internet Brands, Inc. in 
opposition to the Employ Media request:

Dear Chairman Dengate Thrush and Members of the Board:

I am writing on behalf of Internet Brands, Inc. 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.  As the owner of several niche job boards such as 
Hospitaljobsonline.com, Nursingjobs.org, Aviationemployment.com, 
ClassAdrivers.com and Groovejob.com, we would be directly and adversely 
affected by the unilateral expansion of the .jobs charter to encompass regional 
and industry-specific second-level registrations. In no uncertain terms, we are 
opposed to the proposed expansion of the .jobs charter.

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]  It 
also promised to limit registrations to the legal name of an employer and/or a 
name or abbreviation by which the employer is commonly known and to prohibit 
registration of occupational and industry, and geographic identifiers."[3]  
Employ Media's current request for to permit the "registration, use, and 
promotions of domains that are not the company names of the registrant"[4] 
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 does not have the support of online employment service providers 
such as Internet Brands, Inc. to add second level registrations that will be 
confusingly similar to established job boards.  ICANN should not permit sTLD 
operators 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."[5]  Approval would undermine the credibility of ICANN's 
commitments in connection with the introduction of new top level domains in 
general, and "community based" TLDs in particular.


Steve Gilison
Director, Online Business Operations
Internet Brands, Inc.
909 N. Sepulveda Blvd, 11th Floor
El Segundo, CA 90245




[2] sTLD Applicant responses to request for further information, at page 48 of 
177 http://www.icann.org/en/tlds/stld-apps-19mar04/PostAppC.pdf

[3] Id.

[4] http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf 
(hereinafter, Employ Media RSEP Request")

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

Attachment: Opposition to .jobs phased allocation program 7-14-2010.pdf
Description: Opposition to .jobs phased allocation program 7-14-2010.pdf

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