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Oppose .jobs Phased Allocation Program from Brokerhunter.com

  • To: <jobs-phased-allocation@xxxxxxxxx>
  • Subject: Oppose .jobs Phased Allocation Program from Brokerhunter.com
  • From: "Jeff Testerman" <jeff@xxxxxxxxxxxxxxxx>
  • Date: Thu, 15 Jul 2010 13:51:58 -0400



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 www.BrokerHunter.com 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.  Brokerhunter.com 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.[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 online employment service
providers such as Brokerhunter.com to add second level registrations that
will be confusingly similar to established 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 "community based" TLDs
in particular.





Jeff Testerman


Vice President 

Toll Free - 888-955-6795 ext. 202

Local - 770-781-2629 ext. 202

Fax - 770-888-5611

 <mailto:jeff@xxxxxxxxxxxxxxxx> jeff@xxxxxxxxxxxxxxxx









[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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