Call to Action: Employ Media and .jobs

[Jim Haynes <jhaynes@xxxxxxxxx>]

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 Amend its sTLD Charter



Dear Chairman Dengate Thrush and Members of the Board:



I am writing on behalf of the Arizona Hospital and Healthcare Association 
AzHealthjobs.com<http://www.azhealthjobs.com> to urge you to reject Employ 
Media's request to amend its sTLD Charter 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 Arizona Hospital and Healthcare 
Association AzHealthjobs.com<http://www.azhealthjobs.com>  ("AzHHA") is an 
association representing over 100 hospitals and health systems and which 
provides an online employment board for all of its members.  AzHHA and its 
members would be directly and adversely impacted by Employ Media'a proposed 
changes  and opposes Employ Media's  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]  The 
limited nature of this .jobs Sponsored Community is reflected by Employ Media'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 
Employ Media's  sTLD Application, "due to restrictions set forth in this 
proposal, a registration in the .jobs sTLD will be associated with an 
employer,"[3] and  "Employ Media is committed to prohibit registration of 
occupational and industry, and geographic identifiers."[4]  The bottom line is 
that as proposed by Employ Media and approved by ICANN, the .jobs sTLD Charter 
is intended to serve the .jobs Sponsored Community comprised of human resources 
professionals and recruiting firms who represent direct employers, by using the 
legal name of such employers as a registration at the second level.



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"[5] 
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.[6]  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, Employ Media's 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."[7]  Approval of  
Employ Media's proposed amendment to its sTLD Charter will not only adversely 
affect its .jobs Sponsored Community but will adversely threaten the integrity 
of ICANN's registry service evaluation process and undermine the credibility of 
ICANN's commitments in connection with the introduction of new top level 
domains.



Sincerely,



James F. Haynes

Vice President and Chief Financial Officer

Arizona Hospital and Healthcare Association

2901 N. Central Avenue, Suite 900

Phoenix, AZ  85012

________________________________

[1] 
http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03.htm

[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] Id.

[5] http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf 
(hereinafter, Employ Media RSEP Request")

[6] Id.

[7] .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2. 
"Community Value Criteria")