RE: Opposition to Employ Media Request to Change sTLD Charter

["Jessica Romano" <jromano@xxxxxxxxxxxxx>]

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:

The Alliance for Continuing Medical Education (Alliance) is an international
membership organization of more than 2,500 individuals devoted to designing
and implementing certified continuing medical education (CME) activities for
physicians. The Alliance provides professional development opportunities for
individuals working in the CME profession, advocates for CME and the
profession, and strives to improve health care outcomes. Officially launched
in March 1975, the Alliance, representing every sector of the CME community,
is the recognized leader and go-to resource regarding issues within the CME
community. The CME Career Center began operating online in 2008, and has
successfully grown into the premier job board for professionals in the CME
field.

I am writing on behalf of the Alliance's CME Career Center 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 Alliance's CME Career Center, 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 Alliance's CME Career Center, 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.

Sincerely,

Jessica Romano

Manager, Program Development/Marketing

Alliance for Continuing Medical Education

____________________

[1]
http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03
.htm
<http://www.mmsend2.com/ls.cfm?r=148769134&sid=10099808&m=1059179&u=Boxwood&;
s=http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec
03.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=148769134&sid=10099809&m=1059179&u=Boxwood&;
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=148769134&sid=10099810&m=1059179&u=Boxwood&;
s=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"). 

____________________

 

Jessica Romano

Manager, Program Development/Marketing

Alliance for Continuing Medical Education

Southcrest Building, Suite 105

1025 Montgomery Highway

Birmingham, AL 35216

Tel: (205) 453-0439

Fax: (205) 824-1357

 <http://www.acme-assn.org/> www.acme-assn.org

 

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