- To: <stld-rfp-post@xxxxxxxxx>
- Subject: RE: .post
- From: "Chicoine, Caroline" <CChicoine@xxxxxxxxxxx>
- Date: Sat, 6 Oct 2007 23:02:59 -0500
I am the current Vice President for the Intellectual Property Constituency
(IPC) but am submitting these comments on my own individual behalf and not on
behalf of the IPC as I have not had a chance to vet these through the IPC.
Here are my comments and concerns:
1. This proposal does not give any reasoning or indication as to why they
would allow each country's DO to select a second-level domain (such as FRA
instead of FR) instead of using the standard 2-letter WIPO country
designations. It seems that this approach might be confusing to consumers.
2. On page 4, Paragraph 2, the UPU indicates that it will have sponsored
domains. On page 5, the UPU indicates it will also have reserved domains.
However, UPU does not indicate any method for brand owners to challenge a
domain name's designation as a sponsored or reserved domain.
3. Since the UPU has not yet named the Registry Operator, it is impossible
to determine whether brand owners community will have confidence in the one
that is finally selected and thus reserve comment in this regard.
4. Section D on page 7 clarifies that neither the UPU nor the DOs need be
ICANN accredited registrars, yet there are no specifics on who will be
considered a "qualified registrant" for registering domains under sub-division
2 above, nor are there clear policies regarding how the UPU or DOs will handle
domain disputes, or any disputes. The UPU does not clarify on what basis they
will accredit registrars, and does not have a long-standing history of dealing
with domain matters. If the UPU or DOs are not an ICANN accredited registrar,
(which I strongly recommend against), then there needs to be extremely clear
rules, with the same level of specificity as ICANNs rules, governing how the
extension will be run. This is of significant concern given under Section 7(A)
on page 13, they are looking to get out of the responsibility of an
indemnification provision guaranteeing their specific performance.
5. Section E on page 8 clarifies that the UPU has not indicated what they
will charge for domain registrations and makes no guarantees regarding how that
will be determined. They make vague statements about what is likely to happen
with no guarantees.
6. In general, this proposal is lacking in specifics and thus I would hope
that ICANN will require more specificity before the proposal moves further
7. This proposal does not discuss whether UPU has polled its general
membership for member support to better determine whether there is a true need
for this TLD.
8. The guidelines regarding how and why an entity would be considered
"qualified" for purposes of registering domain names, and who has priority of
registration of domain names, needs to be clarified.
Caroline G. Chicoine