Opposed to the inclusion of URS in the .CAT registry agreement
I am writing in regard to the Proposed Renewal of .CAT Sponsored TLD Registry Agreement issued for public comment on May 28, 2015. I am strongly *opposed* to the inclusion of the Uniform Rapid Suspension (URS) in the registry agreement. All the new gTLD RPMs were implementation details of the new gTLD program and are not ICANN consensus policies applicable to all registries and registrars. The URS can become a consensus policy only after a full policy development process (PDP) engaged in by the entire ICANN community of stakeholders. The ICANN community has not even received the new gTLD RPM Issues Report that staff will be providing to the GNSO in September 2015. Imposing URS on an incumbent gTLD via the contracting process is an absolutely unacceptable staff intervention into the policymaking process. Approval of this draft contract would constitute top-down, staff-driven policymaking in direct violation of ICANN’s stated commitment to the bottom-up, private sector led policy development process. The URS is an untested RPM that was incorporated into the launch of the new gTLDs. Any registrant of a new gTLD knew that the URS was part of their registration agreement. The situation is far different from those who have registered the hundreds of millions of domains under .com, .net, .org, .cat, .pro, .travel and other legacy extensions. The imposition of URS on these legacy extensions would weaken the ownership rights to all owners of legacy domains on which the current robust Internet is built. It is wholly illegitimate to undermine the foundation of ownership rights in legacy domains through staff usurping the role of the stakeholder community to develop policy. URS should be removed from the agreement, along with all other provisions derived from the new gTLD RA that are not established consensus policies applicable to incumbent gTLDs. I also write in support of the comments submitted on the .travel renewal which raises nearly identical issues by Phil Corwin, Jay Chapman, Rook Media, George Kirikos, Robin Gross and eCorp. Thank you for your consideration. Regards, Nat Cohen President Telepathy, Inc.