Please 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

["Sharon Popielewski" <spopielewski@xxxxxxxxx>]

Attached and below find a letter regarding the above subject.

 

 

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:

As the premier medical society for the specialty of physical medicine
and rehabilitation, AAPM&R is the only organization exclusively serving
the needs of practicing PM&R physicians. With more than 7,500 members,
the Academy represents more than 87 percent of US physiatrists and
international colleagues from 37 countries.

 

I am writing on behalf of the American Academy of Physical Medicine and
Rehabilitation 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 American Academy of Physical Medicine and Rehabilitation
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] 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,"[3] 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 like the American Academy of Physical Medicine and
Rehabilitation nor did Employ Media demonstrate the support of online
employment services providers in connection with the .jobs sTLD
Application.




Peter Dengate Thrush, Chairman
Members of the Board of Directors
International Corporation for Assigned Names and Numbers
Internet Corporation for Assigned Names and Numbers
Page 2

 

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, 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."[7] 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,
 
Stephanie E.  Mercado, Associate Executive Director

American Academy of Physical Medicine and Rehabilitation
____________________

[1] 
http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15d
ec03.htm
<http://www.mmsend2.com/ls.cfm?r=285536961&sid=10099808&m=1059179&u=Boxw
ood&s=http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-par
ta-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
<http://www.mmsend2.com/ls.cfm?r=285536961&sid=10099809&m=1059179&u=Boxw
ood&s=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
<http://www.mmsend2.com/ls.cfm?r=285536961&sid=10099810&m=1059179&u=Boxw
ood&s=http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.p
df>  (hereinafter, Employ Media RSEP Request")
6 Id.
7 .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2.
"Community Value Criteria"). 

 


American Academy of Physical Medicine and Rehabilitation (AAPM&R)
9700 W. Bryn Mawr, Ste. 200
Rosemont, IL  60018-5701
Direct: (847) 737-6048
Main: (847) 737-6000
Fax: (847) 737-6049
Mobile: (224) 805-1453
spopielewski@xxxxxxxxx
  
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Attachment: 2010_Letter.pdf
Description: Adobe PDF Document