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RE: Employ Media sTLD Charter Amendment

  • To: <jobs-phased-allocation@xxxxxxxxx>
  • Subject: RE: Employ Media sTLD Charter Amendment
  • From: "Eric Caron" <eric@xxxxxxxxxx>
  • Date: Thu, 15 Jul 2010 15:16:26 -0500

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

By Email To: jobs-phased-allocation@xxxxxxxxx

RE: Employ Media sTLD Charter Amendment


Dear Chairman Dengate Thrush and Members of the Board:

I 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.

My organization would not be directly and adversely affected by this
request, but I firmly believe the jobseekers and employers would be done
a tremendous disservice by the unilateral expansion of the .jobs charter
to encompass regional and industry-specific second-level registrations.

The foundation for this belief can be dissected into five core points:


1) Employ Media's abandonment of the original charter request comes from
mismanagement of a solid, universally-beneficial concept:

Taken from Employ Media's own site
(http://www.employmedia.com/.jobs.domain.is.alive.pdf, mirrored on
Google at http://bit.ly/b94wCd):

"The data is going to have to stay pure. If engineering.jobs,
marketing.jobs, etc. ever get sold in conjunction with statefarm.jobs,
.jobs will have no greater benefit than a .net."

This statement embodies the foundation that Employ Media has marketed to
employers over the last 5 years. Contrary to that public-facing message,
since July of 2008 Employ Media (as seen through inquiries from Ray
Fassett) has had the desire and sought to deploy and profit from .jobs
being used to power vertical niches outside of the original .jobs

These conflicting actions clearly demonstrate that Employ Media did not
have the intention to expand the .jobs TLD as established in their ICANN
charter. Rather than seeking more appropriate methods to establish and
cultivate, Employ Media's actions have proven their preference to
monetize TLD as a personal-property rather than to serve .jobs chief
purpose of serving employers and jobseekers.



2) The proposed amendment offers no method for dispute resolution:

Under the previous domain allocation structure, there was no potential
for cybersquatting. With the proposed 3rd phase of the RSEP, a
registrant could potentially acquire the domain-name implying it is
owned by "Company ABC" - resulting in potential crimes against
jobseekers, damage to the target's brand, and with no speedy, democratic
means of resolution.



3) Phase One of the RSEP's lack of transparency is monopolistic:

There can be no doubt of Employ Media's preferential treatment of
JobCentral/Direct Employers (BusinessWeek covered their partnership in
June 2009). In no other TLD is there potential for a registrar to give a
single, seperate entity right of first refusal for all domains. 


Simply put, this secretive process for preferential domain dispersal
does nothing for the fair market internet economy, and stands to benefit
only Employ Media and Direct Employers. Anything short of a 100%
transparent and open auction system for domain distribution, run by a
completely arbitrary third-party, will set a destructive precedent in a
TLD's right to shape the internet based on their personal preference.



4) Previous branding of .jobs would be in grievous contrast to the TLD's
new foundation:

Since the foundation of .jobs, jobseekers have been told they can
unquestionably trust every job on any .jobs site (see
http://goto.jobs/movie/dotjobs.wmv, mirrored at
http://dl.dropbox.com/u/7539417/dotjobs.wmv). This complete shift from
that original message, without any tremendous marketing effort to change
that perception, puts the public in further danger of falling victim to
identity theft (see



5) Without completely disclosing entire WHOIS information for each
domain and without vetting each domain purchase, there is no longer a
method to prove any .jobs domain's authenticity.


I strongly urge ICANN to reject Employ Media's "Amendment No. 2 to the
dot-JOBS Registry Agreement."

Eric Caron - 952-277-4539 - eric.caron@xxxxxxxxxx
JobDig, Inc.

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