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Employ Media sTLD Charter Amendment

  • To: jobs-phased-allocation <jobs-phased-allocation@xxxxxxxxx>
  • Subject: Employ Media sTLD Charter Amendment
  • From: Rita Bocchinfuso-Cohen <ritab@xxxxxxxxxxxxx>
  • Date: Thu, 15 Jul 2010 16:00:09 -0700 (PDT)

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 am writing on behalf of Career Services at California State University, 
Fresno, 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. I became aware of this proposed 
charter amendment today via a forwarded email (included below), which raises 
many valid issues and concerns. I am especially concerned about the interests 
of the jobseekers with which we work on a daily basis, as this proposed 
change is likely to compound their confusion, thereby negatively impacting 
their career prospects. 


A lthough I've had limited time to research the issues surrounding this 
proposal, it is clear that this proposal violates both the spirit and the 
letter of the charter holder's contract with ICANN and is likely to grievously 
harm the online employment services community as well as the job seekers and 
employers who have long been the customers of the community. I strongly oppose 
any unilateral expansion of the .jobs charter to encompass regional and 
industry-specific second-level registrations. 


I honestly do not understand how the proposed change is expected to benefit 
anyone other than the managing entity via vastly expanded potential revenue 
streams. Tons of regional and industry-specific job-oriented registrations 
already exist in the .com domain. Job search-oriented identity theft and fraud 
has already increased with the downturn in the economy. The threat of increased 
confusion, duplication and frau d with an expansion of the .jobs charter is 
palpable . In these difficult and desparate economic times, jobseekers will 
benefit most by increased effeciency and transparency, as will those of us who 
counsel them. 





Rita Bocchinfuso-Cohen 
Director, Career Services 
California State University, Fresno 
559.278.2381     559.278.6483 fax 
Office Web Site 

From: "Daryl Fitzgerald" <dfitzgerald@xxxxxxxxxxxxx> 
To: "ritab" <ritab@xxxxxxxxxxxxx> 
Sent: Thursday, July 15, 2010 9:51:17 AM 
Subject: Fwd: False Information Regarding .jobs Scandal 

From: "CollegeRecruiter.com" <steven@xxxxxxxxxxxxxxxxxxxx> 
To: "Daryl Fitzgerald" <dfitzgerald@xxxxxxxxxxxxx> 
Sent: Wednesday, July 14, 2010 10:44:59 AM 
Subject: False Information Regarding .jobs Scandal 

Daryl Fitzgerald 

Hopefully you've had an opportunity to read through the email that I sent to 
you a couple of days ago regarding the request being made by Employ Media to 
expand its charter over the .jobs top level domain so that it could use or 
otherwise help create hundreds of thousands and perhaps more than a million new 
job boards. 

Shortly after sending out that letter and posting a related blog article to 
CollegeRecruiter.com, I was contacted by a member of the DirectEmployers 
Association who was furious that I mistakenly wrote that the non-profit 
DirectEmployers owned the for-profit Employ Media. I took him at his word and 
corrected the blog article while talking with him and also sent out a 
correction to my 150,000+ Twitter , Facebook , and LinkedIn connections. Dan 
Jordan, chief counsel to DirectEmployers, then sent the attached demand letter 
to me via FedEx. As you can see, he stated that "Employ Media is not, nor ever 
has been, owned by DirectEmployers." That's good enough for me and I take him 
at his word. My apologie s, Dan. 
It is clear from some on-line research that Employ Media is at least partially 
owned by Second Generation Ltd. of Cleveland, Ohio. If you're not familiar with 
them, that's likely because they don't have much of a presence in the 
employment world outside of Employ Media. A couple of their other companies are 
Partners, "a direct marketing company with over 400 salespeople coast to coast 
selling matted framed art to businesses" and USA Parking, a "parking and real 
estate company." 

But the point of the blog article and my email to you wasn't the ownership 
structure of DirectEmployers or Employ Media. The point was the lack of 
openness and transparency in the efforts of a number of players to 
fundamentally revolutionize the way that the .jobs domains can be used and the 
process that is being used to accomplish that dubious goal. Five years ago, 
ICANN -- the international governing body of domain names -- provided SHRM and 
Employ Media a charter to sell .jobs domains to employers such as XYZ Corp. so 
that they could tell job seekers to go to XYZCorp.jobs if they want to go 
directly to the employment information on the XYZ Corp. web site. That was a 
good idea. Unfortunately, although there are some 13 million employers in the 
U.S. alone, only 15,000 employers worldwide bought a .jobs domain and many of 
those who did just re-directed it to their already existing career page. 

Although at times this month Employ Media has denied that it has a partnership 
agreement with DirectEmployers while simultaneously promoting their alliance , 
at the end of the day what matters is that the process they've followed stinks. 
Plain and simple. Even though I'm an owner of job board CollegeRecruiter.com 
and therefore will be directly impacted by Employ Media's desire to create 
hundreds of thousands and perhaps a million apparently cookie cutter job boards 
like Government.jobs, University.jobs, Nursing.jobs, Diversity.jobs, 
SeattleSoftwareEngineer.jobs, and more, I'm okay with that. I'm okay with the 
creation of new job boards because we've been around since 1996 when there were 
about 200 j ob boards worldwide and there are now about 100,000. I've seen that 
we can more than hold our own even though there are many new boards. What I'm 
concerned about is the process. It is clear from reading the request by Employ 
Media to expand the .jobs charter that it wants to take the use of the .jobs 
domains out of the employer community to which it is restricted by its current 
charter (the one it requested and was then granted five years ago) and into 
other communities such as recruiting agencies, staffing companies, job boards, 
career services, and more. I'd be fine with this if Employ Media were simply 
functioning as a seller of the .jobs domains and anyone else could buy them at 
the same terms as anyone else like happens with .com and .net addresses. But 
that's not what's being proposed. 
If Employ Media is granted the expansion of the charter, you'll almost 
certainly see hundreds of thousands and perhaps a million new job boards spring 
up almost overnight. Employers will be able to post their jobs to them for free 
just like they can now with many, many aggregators  such as Indeed.com, 
SimplyHired.com, JuJu.com, and LinkUp.com. Job seekers will continue to use 
Google, Bing, and other search engines to find relevant job boards and employer 
sites but now they'll have another million sites to sift through. Employ Media 
and the owners of these so-called "free" sites will charge premium pricing to 
employers who want their results to appear at the top of the search results -- 
just like Indeed, SimplyHired, JuJu, and LinkUp -- and employers who work with 
the "free" sites know that their jobs are essentially invisible unless they pay 
for those premium listings. 
If I were Employ Media, I'd be the most excited about my ability to suck in 
huge amounts of job seeker traffic using the free content I'm getting from the 
members of the DirectEmployers Association and other employers and then 
leveraging that traffic to generate revenues from on-line and other schools 
when job seekers are asked if they want to continue their education, get their 
credit ratings checked, become members of on-line survey panels, and other such 
pay-per-sale, pay-per-lead, and pay-per-click offers that litter many job 
boards. Those "sales," "leads," and "clicks" are sold by job boards and others 
for widely varying sums but the education leads alone are typically worth about 
$10 to $20 per pop. If the only revenue Employ Media generates are education 
leads and they generate only one per day per board, that's about $10 million 
per day or $3.65 billion per year. No wonder Employ Media wants this so badly. 
Other than the ability to post jobs for free to a bunch of new job boards, it 
is difficult for me to understand why DirectEmployers is taking such an active 
role in this process and why any organization other than Employ Media would be 
excited about this. I trust that there's no secret, financial relationship 
underlying the "alliance" between DirectEmployers and Employ Media given their 
written statement earlier this month that they have no partnership agreement. 
If this bothers you even a fraction as much as it bothers me, it is critical 
that you take action today as the deadline for ICANN comment period is 
tomorrow. Fortunately, it is very easy for you to voice your opinions. Simply 
send an email to jobs-phased-allocation@xxxxxxxxx . You can even forward this 
one. Be sure to include your contact information and organization you 
represent, if any. If you want a template to follow, I posted one in my blog 
article . Oh, and please cc me on the email. That will allow me to see that my 
efforts have in some way made a difference. 

Steven Rothberg | Chief Executive Officer 

CollegeRecruiter .com | College Career Connector 
Selected by WEDDLE's as a Top Job Board 2007, 2008, 2009 and 2010 
Proud to be a woman-owned, small business 

Web: http://www.CollegeRecruiter.com 
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