Comment regarding extension of new gTLD's

["Nooger, Daniel A" <dnooger@xxxxxxxxxx>]

Dear Sirs:

1.    From the point of view of a media company owning many trademarks,
the overall value from a marketing point of view of the availability of
new gTLD's  which could be based on various trademarks (for example, a
".cosmopolitan" extension) does not appear to have been clearly
established.       

    2.    The costs associated with the suggested application fee plus
maintenance fee structure proposed for such new gTLD's is extremely
high, and again, does not appear to comport with any purported value of
such extensions as marketing tools.  It has been suggested by various
prospective registrants that there should be a mechanism for
registration of multiple extensions by the same company at a reduced or
"bulk" rate, however, ICANN does not appear to intend to proceed along
these lines.

    3.    The proposed mechanism for protecting trademark owners from
third parties such as domain brokers and speculators seeking to register
various companies' registered trademarks as new gTLD extensions is, in
general, overly vague, and appears that it will operate in a cumbersome,
slow and expensive manner.

    4.    The technical requirements for owners of such new gTLD's to
operate as domain registrars appears to virtually guarantee that such
owners will have to outsource the operation and maintenance of the new
gTLD's to their domains management companies.  The costs for these
operations has not been clearly established but will clearly be
substantial. 

    5.     Generally, we see no commercial value in the proposed
extension of gTLD's for businesses like ours, but we could be forced to
expend considerable sums to buy up domains on a protective basis. 

Sincerely,

Daniel Nooger
Paralegal 
Office of General Counsel
The Hearst Corporation
300 West 57th Street
40th Floor
New York, NY 10019
PH:   212-649-2019
FX:    646-280-2019
E-mail:    dnooger@hearst <mailto:dnooger@hearst> .com 
 
***************************************************************************************************************
This e-mail message is intended for the personal use of the recipient(s) named 
above. If you are not an intended recipient, you may not review, copy or 
distribute this message. If you have received this communication in error, 
please notify the Hearst Information Services HelpDesk (helpdesk@xxxxxxxxxx) 
immediately by e-mail and delete the original message.