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Username: USTAR
Date/Time: Thu, October 19, 2000 at 12:53 AM GMT
Browser: Microsoft Internet Explorer V5.01 using Windows 98
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Subject: IATA Should Not be Permitted Ownership of ".travel"


The United States Travel Agent Registry (USTAR), representing more than 1000 travel agents throughout the United States, objects to the application by IATA for the TLD ".travel" for the following reasons:

1. The scope of the travel industry as a global marketplace is too wide and diverse to allow a single sector, namely air carriers, to control a broad, all-encompassing TLD like ".travel". Furthermore, airlines already have over-controlled and over-regulated non-airline  travel sectors, initiatives, and businesses (like travel agencies), well beyond the airlines' general mandate. Controlling .travel would be yet another travel industry domination by airlines which should be avoided at all costs.

2. IATA will likely drive subsequent requests to use the .travel TLD as a significant revenue stream. IATA has a history of charging excessive amounts for essential services, and the fear that IATA will charge fees in excess of fair market value for TLD usage is not without foundation. While IATA maintains its status as a non-profit airline trade organization, it is mandated to raise the bulk of its revenues outside of airline membership fees in the association; .travel would become a major revenue source for IATA.

3. It would not be unexpected for IATA to reserve key sub-domains within .travel for its or its members' premier usage. Therefore, those sectors seeking premier domains or preferred domains within .travel may find that these have been already reserved, anti-competitively restricted by IATA, or made available preferentially at exorbitant prices.

4. IATA does not have an inclusive-enough or impartial-enough history of business practices to instill confidence that the .travel TLD would be maintained and administered in a manner which would be as fair and as unbiased as it could be. IATA's proclivity for accreditation standards and criteria which are in many cases heavy-handed and domineering is already well known in the travel agency sector. There is ample reason to fear that IATA's management of .travel would be no less oppressive.

Simply stated, "travel" is far more encompassing than "air travel". IATA should stick to its core mandate and sphere of interest, not attempt to harness control over the Internet identification of the travel industry as a whole.

For these and other reasons, we respectfully request that ICANN reject IATA's application to own .travel, and furthermore request that ICANN assure that any subsequent application by any another party evidence prospective management and administration of the .travel TLD in a fair, unbiased, and commerically equitable manner.         
USTAR appreciates this opportunity to provide comments regarding IATA's application and thanks ICANN for consideration of its position.


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