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Opposition to Employ Media Request to change sTLD charter

  • To: <jobs-phased-allocation@xxxxxxxxx>
  • Subject: Opposition to Employ Media Request to change sTLD charter
  • From: "Stephen DuFaux" <stephen.dufaux@xxxxxxxxx>
  • Date: Wed, 14 Jul 2010 18:13:56 -0500

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: Opposition to Employ Media Request to Change sTLD Charter
Dear Chairman Thrush and Members of the Board:

While I am in agreement that America has been founded on its ingenuity,
creativity and pursuit of innovative concepts - I am not in agreement that
inappropriate and unethical extensions of "permissions" should be granted to
ventures that will clearly thwart or negate existing or planned initiatives
for businesses and entrepreneurs.


I am writing on behalf of the National Staffing & Recruiting Industry
Association (NSRIA) and a planned launch of a new venture which cannot be
disclosed at this time; 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 future success of planned initiatives on my behalf will be directly and
adversely affected, and I oppose the unilateral expansion of the .jobs
charter to encompass regional and industry-specific second-level
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. 
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."  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," 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, nor did Employ Media demonstrate the support
of online employment services providers in connection with the .jobs sTLD
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" 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. This is not surprising, given that
Employ Media intends to add second level registrations that will be
confusingly similar to established jobboards.
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."  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
Ted Dewalt, the President of Vetjobs and a fellow colleague in the Industry
clearly defined substantial rationale in his letter to the ICANN; for
rejecting Employ Medias request; which I would like to quote and support.
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 ask 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. 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.
4. 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.
5. 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
I look forward to your unanimous rejection of Employ Medias request and to
receive confirmation that it has been declined.


Stephen DuFaux  

 <mailto:stephen.dufaux@xxxxxxxxx> stephen.dufaux@xxxxxxxxx



National Staffing & Recruiting Industry Association.. found on "Linked in"








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