Reject the .jobs Amendment!
- To: jobs-phased-allocation@xxxxxxxxx
- Subject: Reject the .jobs Amendment!
- From: David Manaster <david@xxxxxxx>
- Date: Thu, 15 Jul 2010 12:23:03 -0400
July 15, 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
Dear Chairman Dengate Thrush and Members of the Board,
I am the CEO of ERE Media, Inc., a trade publisher that serves HR and
recruiting professionals. My organization has been observing the evolution of
the .jobs TLD since its inception, and we have been reporting extensively on
the proposed amendment at our web site, http://www.ere.net/.
ERE Media, Inc. would not be directly and adversely affected by this request
except in a tangential way, since both HR professionals and job boards are our
customers. I write this letter not to advance my own interests or those of my
organization, but as a concerned citizen of the Internet.
As I read the letters posted as part of the public comment period, I am struck
by how political the process has become, and how transparently the vast
majority of the letters on both sides were driven by their respective trade
Lost in this politicization of the .jobs TLD are fundamental problems with the
1.) The proposed amendment fundamentally changes Employ Media from a domain
order processor to a domain kingmaker.
The discretionary powers that the proposed amendment would give to Employ Media
over the use of the .jobs domains are shockingly broad. They turn the company
from a domain name order processor into a domain kingmaker, who can pick and
choose who develops .jobs domain names entirely at their own discretion. To my
knowledge, this would be a unique role for a registrar, and it is a troubling
precedent for public policy to have one organization able to unilaterally
decide who gets to utilize broad swaths of domains in a TLD.
2.) The proposed amendment is driven by the financial concerns of the
registrar, not concern for HR professionals.
Financially speaking, the .jobs TLD has been a failure. Employ Media sold only
around 15,000 domains since 2005, and because of the disappointing sales they
are pushing for more creative ways to promote and sell .jobs domains. This is
what is driving the proposed amendment, not concern for the profession of HR.
Employ Media has never disclosed the details of their financial relationship
with DirectEmployers, despite repeated inquiries. The SHRM PDP Council minutes
of April 9, 2010 state that the council intended to ask Employ Media about the
financial impact of the proposed amendment on the company, but never got the
opportunity to even ask the question.
3.) The registrar has already violated the .jobs charter.
Employ Media and DirectEmployers partnered to launch the first of their
geographic and occupationally focused websites using the .jobs domain in
October 2009. At the time, these site were a direct violation of the spirit of
the existing .jobs charter, which states ".jobs domain registrations are
limited to the legal name of an employer and/or a name or abbreviation by which
the employer is commonly known." It was not until March 22, 2010 that Employ
Media proposed an amendment to the charter that would allow it to do what it
had already attempted.
4.) SHRM has failed in its oversight responsibilities as the sponsor of the
I am a longtime member of SHRM, and believe that they are well-intentioned and
a positive force for the HR profession. However, they have clearly failed in
their oversight responsibilities. The first PDP Council was managed by Bill
Warren, the Founder of DirectEmployers, and the second included Rhonda
Stickley, the Association's President, people with obvious motivation to see
the amendment pass. Gary Rubin, the SHRM executive who managed the second PDP
Council, was completely unaware of the first public comment period that had
been publicized on Policy.jobs until we questioned him about its details, and
the second attempt at a "public" comment period was conducted by SHRM in such a
way that all of the responses were secret.
Further, SHRM receives a fixed annual payment of an undisclosed amount from
Employ Media for its role as the sponsor of the .jobs TLD, and Employ Media
also advertises heavily in SHRM publications. There is a very strong argument
to be made here that this has resulted in a situation of "regulatory capture",
where the organization that is supposed to be policing behavior by the
registrar, is in fact financially tied to its success.
It is my belief that this amendment is not in the best interests of HR
professionals, and it is not in the best interests of users of the Internet.
The only ones who benefit here are Employ Media, DirectEmployers, and SHRM. I
urge ICANN to not only reject the this amendment, but to reconsider the
governance structure of the .jobs TLD.
ERE Media, Inc.