Global Health Council Respectfully Urges ICANN to Reject 'Employ Media RSEP Request'

["Liza Nanni" <lnanni@xxxxxxxxxxxxxxxx>]

  <http://www.globalhealth.org/> 

 

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

 

RE: Opposition to Employ Media Request to Change sTLD Charter

 

Dear Chairman Dengate Thrush and Members of the Board:

 

The Global Health Council is the world's largest membership alliance
dedicated to saving lives by improving health throughout the world. Our
diverse membership is comprised of health-care professionals and
organizations that include NGOs, foundations, corporations, government
agencies and academic institutions that work to ensure global health for
all. 

 

The Global Health Council, formerly the National Council of
International Health, is a U.S.-based, nonprofit membership organization
that was created in 1972 to identify priority world health problems and
to report on them to the U.S. public, legislators, international and
domestic government agencies, academic institutions and the global
health community.

More info: http://www.globalhealth.org/view_top.php3?id=25

 

I am writing on behalf of the Global Health Council's Global Health
Career Network, http://careers.globalhealth.org
<http://careers.globalhealth.org/>  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 Global Health Career Network, 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." 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 [insert Association Name/Job Board Name], 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.

 

(This letter is also attached as a WORD document to this e-mail and a
hard copy is in the mail.)

 

Sincerely,

 

Annmarie Christensen

Director, Publications and New Media

Global Health Council

 

____________________

 

[1] 
http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15d
ec03.htm  

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 Id. 

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

6 Id.

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

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