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  • To: "comments-travel-renewal-12may15@xxxxxxxxx" <comments-travel-renewal-12may15@xxxxxxxxx>
  • Subject: Opposition
  • From: "domains@xxxxxxxxxxxxxxxx" <domains@xxxxxxxxxxxxxxxx>
  • Date: Fri, 22 May 2015 18:42:09 +0200


I am writing in regard to the Proposed Renewal of .TRAVEL Sponsored TLD 
Registry Agreement issued for public comment on May 12, 2015.

I am strongly opposed to the inclusion of a modified version of the new gTLD 
rights protection mechanisms in Specification 7 of the proposed RA, especially 
Uniform Rapid Suspension (URS).

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 ICANNs stated commitment to the bottom-up, private sector led 
policy development process.

Therefore, the .Travel renewal RA should be referred for Board consideration 
only after Specification 7/URS has been 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.

Thank you for your consideration of my views.

Zdenek Kubik, CEO

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