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Username: dhooker
Date/Time: Fri, November 3, 2000 at 4:04 PM GMT
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Subject: Comments of Thompson Hine & Flory LLP


        November 3, 2000

To Whom it May Concern:

I am the Managing Partner of Thompson Hine & Flory LLP, a national law firm based in Cleveland, Ohio.  We have reviewed dotLaw, Inc.'s proposal for the creation and management of a ".law" generic top level domain name ("gTLD").  I believe that it is premature to vest control of the ".law" gTLD with dotLaw, Inc. at this time.

The law is a self-regulating profession.  As a firm and as individual lawyers, we need to ensure that all potential stakeholders in the proposed ".law" venture have a sufficient opportunity to give input on this proposal and that the interests of the profession as well as the public are adequately presented.  I do not feel there has been sufficient time for that necessary dialog to occur, and therefore the establishment of the ".law" gTLD should be postponed pending further consideration and debate. 

We understand that dotLaw, Inc. has been established as a for-profit corporation, with PricewaterhouseCoopers ("PwC") as its primary shareholder.  We believe that the interests of both the public and the legal profession would be better served through the establishment of a not-for-profit corporation, owned by its members and governed by fiduciary trustees committed to serving the public and the profession.  Indeed, the substantial revenue projections set forth in dotLaw, Inc.'s application are on their face inconsistent with its stated purpose of serving the interests of both the legal profession and the general public.

Although dotLaw, Inc.'s application makes reference to the involvement of certain stakeholders to ensure that the balance of interests is properly struck, it is sufficiently vague regarding management of the proposed ".law" gTLD to call into question its ability to do so.  In particular, the application does not state how the overseers of the ".law" gTLD would be selected—in fact, it admits that the largest representative body of lawyers, the American Bar Association, has not yet endorsed the proposal or agreed to participate.  Without significantly more detail and commitment by affected parties, it is difficult to endorse this project as it is presented.

Finally, the composition of the ownership of dotLaw, Inc. and its management raises difficult questions concerning the role of PwC in this venture.  The issue of the role of accounting and consulting firms engaging in the provision of legal services has proved vexing and has engendered considerable debate at both the national and state levels.  To permit PwC and several of its members to assume a primary role in the creation and management of the ".law" gTLD could allow it to make an end-run around the important debate now occurring regarding the proper role of accountants and consultants in the market for legal services and ultimately could undermine dotLaw, Inc.'s ability to effectively manage the ".law" gTLD.

The establishment of a ".law" gTLD could serve the interests of both the legal profession and the general public, if done correctly.  At this time, however, I respectfully request that ICANN not grant dotLaw, Inc.'s proposal until other stakeholders have spoken and other legal structures are considered.

Very truly yours,

David J. Hooker, Esq.
Managing Partner
Thompson Hine & Flory LLP
3900 Key Center
127 Public Square
Cleveland, Ohio 44114


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