Another Million Job Boards to post/sort through

[Barbara Whelan <jerrywhelan7@xxxxxxxxx>]

Dear Sir or Madam,
 
I am writing on behalf of the Intercom Research 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. Poynter Career Center, 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.”[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 Poynter 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

 Sincerely,


Jerry Whelan
904-264-6061 Office
skype: Jerry.whelan7
Jesus loves you.