Opposition to Employ Media Request to Change sTLD Charter
Dear Chairman Dengate Thrush and Members of the Board: The Craft & Hobby Association (CHA) is an international, not-for-profit trade association consisting of thousands of member companies engaged in the design, manufacture, distribution and retail sales of products in the nearly $30 billion U.S. craft and hobby industry. The CHA Career Center is the association's web site where members and non-members can post jobs and resumes that focus on opportunities specifically within the craft industry. I am writing on behalf of the Craft and Hobby Association Career Center 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 Craft and Hobby Association 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. 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 like the Craft and Hobby Association 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" 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 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." 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, Jon R. Krance Marketing Manager Craft & Hobby Association 319 E 54th Street Elmwood Park NJ 07407 Tel: 201-835-1214 (800) 822-0494 Fax: 2018351264 Mobile: (201) 566-1317 <https://www.chashow.org/eWeb/images/CHA/cha_logo.gif> Hope to see you at our upcoming CHA Shows: CHA 2010 Summer Show - Rosemont, IL July 27 - 29, 2010 Craft SuperShow - Rosemont, IL July 30 - 31, 2010 CHA 2011 Winter Show - Los Angeles, CA January 29 - February 1, 2011 CHA 2012 Winter Show - Anaheim, CA January 29 - February 1, 2012 www.chashow.org <http://www.chashow.org/> www.craftandhobby.org <http://www.craftandhobby.org/> www.craftsupershow.com <http://www.craftsupershow.com > The information contained herein is confidential to the Craft & Hobby Association and is protected under trade secret law and the Copyright Act of 1976. Any misuse or misappropriation by unauthorized persons is prohibited and will violate civil and criminal law. © 2009 Craft & Hobby Association. All rights reserved.