RE: Opposition to expanding the .jobs charter to encompass regional and industry-specific registration

[Sharon McDonagh <SMcDonagh@xxxxxxxxxxxxx>]

Attached please find a letter signed by CEO James Youngblood indicating that 
the Heart Rhythm Society (the international leader in science, education and 
advocacy for cardiac arrhythmia professionals and patients representing more 
than 5,300 professionals in cardiac pacing and electrophysiology in more than 
70 countries worldwide) opposes the unilateral expansion of the .jobs charter 
to encompass regional and industry-specific second-level registrations. Text of 
the letter is also included below.
______________________

Sharon E. McDonagh, CPS
Manager, Web Communications & Strategies
Heart Rhythm Society
1400 K Street, NW, Suite 500
Washington, DC 20005
(202) 464-3477
__________________________

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
USA

RE: Opposition to Employ Media Request to Change sTLD Charter

Dear Chairman Dengate Thrush and Members of the Board:

I am writing on behalf of the Heart Rhythm Society 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 Heart Rhythm Society is the international leader in science, education and 
advocacy for cardiac arrhythmia professionals and patients and represents more 
than 5,300 professionals in cardiac pacing and electrophysiology in more than 
70 countries worldwide. The mission of the Society is to improve the care of 
patients by promoting research, education and optimal health care policies and 
standards. The goal of the Society's educational opportunities targeting 
healthcare professionals is that they will improve the health of patients with 
or at risk of heart rhythm disorders, with an objective including the elevation 
of career development programs for non-physician care-providers, 
electrophysiology trainees and early career physicians. Another goal is 
ensuring patient access to high quality heart rhythm care and to advocate for a 
productive and sustainable work environment for heart rhythm professionals, 
with one objective being to ensure an adequate workforce for the treatment of 
heart rhythm disorders. The Society's online Career Center, part of the 
National Healthcare Career Network, is a key tool in our communication with and 
advocacy for members and nonmembers alike.

Accordingly, the Heart Rhythm Society, 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 such as the 
Heart Rhythm Society 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,

[cid:image001.jpg@01CB2411.2821AA50]
James Youngblood, CEO
Heart Rhythm Society

Attachment: dotjobs_oppositionletter.doc
Description: dotjobs_oppositionletter.doc