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Letter to Peter Dengate and BOD - Employ Media sTLD Charter Amendment

  • To: <jobs-phased-allocation@xxxxxxxxx>
  • Subject: Letter to Peter Dengate and BOD - Employ Media sTLD Charter Amendment
  • From: "Ted Daywalt" <TDaywalt@xxxxxxxxxxx>
  • Date: Wed, 14 Jul 2010 16:24:27 -0400


Veterans make the best employees



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


RE:  Employ Media sTLD Charter Amendment


Dear Chairman Dengate Thrush and Members of the Board:


I am writing on behalf of VetJobs, the leading military job board on the
Internet in the United States and our 1.5 million military and their family
users. VetJobs urges 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 (DOT JOBS) sponsored top level domain. VetJobs
is certain that veterans nationwide would be adversely affected in their
search for jobs if this is allowed to occur. VetJobs 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]  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 the military online employment
service providers to add second level registrations that will be confusingly
similar to established military and veteran related 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 "military and veteran
community based" sites in particular.


I consider this move by Employ Media to be a violation of the ICANN charter.
In addition to the above information, the move will be very damaging for the
following reasons:


1. There was a solid reason for limiting the use of .jobs and it should NOT
be violated. For ICANN to allow Employ Media to move forward would negate
ICANN's moral authority to properly regulate TLDs and sTLDs.


2. One has to as what will happen if every TLD decides to violate their
ICANN charter in the way Employ Media is proposing to do? The internet would
be flooded with millions of sites causing massive confusion for both
employers/HR and candidates.


3. Contrary to what has been written and said by representatives of Employ
Media, I am know the proposed move by Employ Media will make it even more
difficult for transitioning military, wounded warriors, veterans and their
family members to locate well established job boards that have long focused
on serving the military market. These sites have demonstrated that they
understand and respect the unique culture and needs of veterans, something a
mechanical array of tens of thousands of sub-domains proposed by EmployMedia
could never match. The established sites have over the years earned the
respect of veterans and veteran service organizations by providing the
military related users with effective employment resources and support. This
move by Employ Media will directly hinder the men and women who have served
our country so well. The members of our military deserve better treatment
than what SHRM/EmployMedia proposes. 


4. This move by Employ Media will make employers susceptible to price
gouging. While employers would theoretically be able to post their jobs for
free on .jobs sites, the volume of such postings would virtually require
that they purchase featured listings or other premium services, which only
Employ Media would be authorized to sell.


5. This move by Employ Media would undermine the investment employers have
made in their corporate career sites. Millions of employers now rely on
their own corporate career sites to connect with job seekers. Many have
invested heavily in optimizing those sites for search engines. Indeed, in an
era of constrained resources, relying on search engine results is now a
primary method of attracting job seekers. By pouring tens of thousands of
new .jobs sites into the market, Employ Media will diminish if not destroy
the effectiveness of that outreach effort.


6. This move by Employ Media will create a monopolistic pricing situation
for Employ Media in the marketplace for featured job postings and other
premium services on .jobs sites


7. This move by Employ Media will flood the Internet with .jobs sub-domains
that undermine the value of the licenses purchased in good faith by
employers under the current terms of the .jobs charter; and


8. This move by Employ Media will clog search engine results and thereby
pervert the efforts of employers to raise the search engine ranking of their
own corporate career sites and make it more difficult for candidates to find


If you have any questions, please feel free to give me a call.


With best regards, 


//signed attachement//


Ted Daywalt



P. O. Box 71445
Marietta, GA 30007-1445
o 877.838.5627 (877-Vet-Jobs) 
o 770-993-5117 X222
f 770-993-2875

Veterans make the best employees!
Freedom Is Never Free - Support Our Armed Forces and Veterans!

VetJobs is an appropriate employment service delivery system for EEOC,
VEVRAA/JVA and OFCCP compliance support!

Seven year recipient of AIRS Top Recruiting Site 

Seven year recipient of WEDDLE's User's Choice Award 

Four year recipient of Workforce Management Top 10 Recruiting Sites 

Only military job board selected by Reader's Digest

Only military job board selected by BusinessWeek

VetJobs is a Service Disabled Veteran Owned Small Business











[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")


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