Uniform Rapid Suspension System comment

[Alynxco@xxxxxxx]

Dear Sirs,
I am writing today to voice my STRONG opposition  to the ICANN “Uniform
Rapid Suspension System” (URS) proposal for domain name  dispute complaints.
As drafted, this measure would open the door to  numerous frivolous domain
complaints that could strip legitimate domain name  holders of their names,
websites, and possibly their livelihoods.
Strong monitoring and enforcement are necessary  measures to combat blatant
trademark and typo cybersquatting. Those actions hurt  the domaining
community and the target companies. However I believe that there  are other
measures and opportunities to pursue in fighting the inappropriate  ownership 
and
use of such domains by illegitimate domain holders. For example,  having
registries and registrars play a larger role in monitoring new  registrations
and rejecting obvious TM violations would be one avenue to  explore.
Web businesses run by entrepreneurial domain  holders who have full
websites, minisites, or even targeted parking pages on  legitimately registered
domain names could easily lose their rights to hold and  use many domains under
the proposed "Uniform Rapid Suspension System”.
In my analysis, the proposed URS would open the  door widely to what is now
considered reverse hijacking. This is NOT a good  plan. The goals are valid
and important but the proposal is flawed and skewed  heavily towards the
interests of companies and against the practical use of  domains by any domain
holder, website operator, or web developer.
The existing UDRP process works well most of the  time and understandably
might be a longer and costlier process than ideal. There  is room and need
for improvement. But ICANN and the domain community would be  better served by
pursuing and implementing solutions that PREVENT the initial  registration
of blatant trademark infringing names at the point or registration  attempt.

It is not right to penalize the entire domain  registrant community and
legitimate domain entrepreneurs because of fraudulent  actions of a small
percentage of scammers and serial cybersquatters. It is not  right to give
companies a wide open door to immediately shut down a website on  the way to 
grab
a domain they covet from a rightful registrant who is using  a generic term
domain in a legitimate way.
Please do not allow the “Uniform Rapid Suspension  System” proposal to
continue in its highly flawed state.
Thank you.
Sincerely,
Bill Rys
Alynxco, Inc.


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