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Public Comment Summary

  • To: "rproproposal@xxxxxxxxx" <rproproposal@xxxxxxxxx>
  • Subject: Public Comment Summary
  • From: Craig Schwartz <craig.schwartz@xxxxxxxxx>
  • Date: Fri, 11 Apr 2008 15:54:23 -0700

Summary and analysis of public comments for:

RegistryPro Contract Amendments

Comment period ended: 10 April 2008

Summary published: 11 April 2008


The public comment period was created to provide an opportunity for the 
Internet community to voice their feedback on RegistryPro's proposed contract 
amendments that would alter registration restrictions in the .PRO top-level 

In its 12 March 2008 communication to ICANN, RegistryPro stated that, "These 
current restrictions have had a number of unanticipated results: registrants 
and prospective registrants are frustrated by the restrictive nature of the 
TLD; registrars find the requirements so cumbersome and burdensome that they 
are reluctant to offer the
TLD; methods that have been alleged to compromise the spirit and intent of 
ICANN in establishing the .pro TLD have emerged as alternatives to the intended 
mechanisms/mechanics /methods of registration."

The contract amendments proposed by RegistryPro would enable the registry to 
allow registrations in .PRO according to the following parameters:
1.  Third-level registrations under PS-SLDs (e.g., med.pro) would continue to 
be available. However, the list of PS-SLDs offered would be expanded to include 
additional professions.
2.  Second-level registrations would be available to professionals who either: 
a) meet the eligibility requirements for any of the PS-SLDs, or b) are licensed 
by, and in good standing with, a jurisdictional licensing entity recognized by 
a governmental body and requiring its members to be continuously licensed or 
admitted to such body or entity as a prerequisite to providing the relevant 
professional service. A redirect to a corresponding third-level name would not 
be required.
3.  Second-level registrations would continue to be available under .PRO in the 
case where a registrant provides multiple professional services and meets 
eligibility requirements for two or more profession-specific second-level 
4.  When registering a .PRO domain name, all registrants would be required to 
agree to abide by the specified Terms of Use, and to re-sign the Terms of Use 
annually. Current .PRO registrants would also be required to agree to the Terms 
of Use upon renewal.


A total of 29 comments were received. Of the 29, 26 were supportive (KE, CR, 
JD, AC, BS, H/IT, M/BN, MF, RE, A, PL, SM, Andrey, MP, VK, RS, ZK, DH, PF, NS, 
A/DD, WY, AN, PW, CK and TB), one voiced mixed support (CT), one was not 
supportive (KS) and one comment was unrelated to the posting (JV).

Thirteen respondents cited the importance of loosening the restrictions to make 
the TLD available to more registrants from different professional 
classifications in geographically diverse areas.  CR, JD, AC, BS, A, SM, RS, 

Six respondents cited the loosening of restrictions should invariably lead to 
lower registration costs.  AC, H/IT, RE, SM, PF, ZK

Two respondents suggested that failing to loosen the registration restrictions 
would call into question the viability of the TLD. M/BN, RE

Two respondents stated that the current system makes it too cumbersome to 
register names. RE, SM

The mixed response stated it was important to expand the registry to include 
other professional groups and also that the proposed changes have a potential 
to eliminate the core benefits provided by the .PRO domain. The respondent 
stated that the latter impact could result because of nations not having strict 
registration and credentialing guidelines.  CT

The one comment against the proposed changes stated, "It seems it will dilute 
the .pro domain and lead to our company abandoning our registered names." KS


This summary of public comments will be used to inform the ICANN staff 
recommendation about the proposal to the Board of Directors. The proposed 
contract amendments are to be considered by the Board of Directors.

CONTRIBUTORS are in order of first appearance (with abbreviation) and number of 
postings if more than one:

Kelly Elmore (KE) for Elmore Engineering Services
Costa Giorgia Roussos (CR)
Jeff Deacon (JD)
Andrew Campbell (AC)
Ben Schultz (BS)
Haroon (H/IT) for Invision Techs
Mike (M/BN) for BocaNames
Meghan Fournier (MF)
Robert Edmonston (RE)
Aaron (A)
Pierre-Yves Landanger (PL)
Samit Madan (SM) for Emm Interactive
Mikhail Plokhih (MP)
Vas Kapavarapu (VK)
Zurab Kodalashvili (ZK)
David Hellam (DH)
Paul Farkas (PF)
Neal Solomon (NS) for WealthPro, LLC
Andy for The Domain Dominion
Wes Young (WY)
Alexander Nasonov (AN)
Peter Wagner (PW)
Chris Kay (CK)
Thomas Barrett (TB) of EnCirca
Christopher Tindall (CT)
Kevin Snowden (KS) from Snowden Engineering Inc.
Jim Vaglia (JV)

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