Letter of opposition to proposed change in .jobs charter

[Brenda Teter <bteter@xxxxxxxx>]

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:

I am writing on behalf of the California Association of Community  
Managers, Inc./Career Network 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 CACM Career Network site 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 California Association of  
Community Managers, Inc./Career Network nor did Employ Media  
demonstrate the support of online employment services providers in  
connection with the .jobs sTLD Application.
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.
Regards,

Brenda K. Teter
Director of Communications
California Association of Community Managers (CACM)
949.916.2226, ext. 16
949.916.5557 fax
bteter@xxxxxxxx / www.cacm.org

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