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- To: "jobs-phased-allocation@xxxxxxxxx" <jobs-phased-allocation@xxxxxxxxx>
- Subject:
- From: Steve Rappaport <srappaport@xxxxxxxxxx>
- Date: Wed, 14 Jul 2010 15:46:52 -0400
July 14, 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
USA
RE: Opposition to Employ Media Request to Change sTLD Charter
Dear Chairman Dengate Thrush and Members of the Board:
The Advertising Research Foundation is a membership organization of over 400
leading companies drawn from five categories: major national advertisers (e.g.
P&G, Unilever), media companies (Google, Time Warner, CBS), agencies (creative
and media agencies), research companies (e.g. Nielsen, Kantar), and academia
and associations. The ARF Career Center is the industry's preeminent job board
exclusively for advertising, market and media research professionals.
I am writing on behalf of the The Advertising Research Foundation (ARF) 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 ARF's Career Center job board 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 The ARF 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,
Stephen D. Rappaport
Knowledge Solutions Director
The Advertising Research Foundation
____________________
[1]
http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03.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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