RE: .post

["Chicoine, Caroline" <CChicoine@xxxxxxxxxxx>]

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 
along.

        

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