Recommendations of IRT not acceptable.
Hello ICANN, Please consider the following objections, The Uniform Rapid Suspension (URS) proposal would effectively displace the UDRP at all new gTLDs and substantially diminish registrants’ procedural and substantive due process rights. The extreme low cost of filing complaints (as little as $1.50 per domain in mass filings) and the lack of effective sanctions (abusive complainants barred from the URS for one year, and then only after three separate incidents of abuse, with no monetary sanctions or indemnification requirements) would encourage abusive complaint filings. There is also a lack of effective or affordable substantive appeals procedures for registrants who believe that their domains have been unfairly suspended. Further, trademark interests have already voiced the goal of imposing the URS on incumbent gTLDs, including .com, soon after its adoption for new gTLD. Hope you would take the views of the domaining community and reject the recommendations of the IRT. Yours Sincerely Kulasekaran.