RE: Opposition to Employ Media Request to Change sTLD Charter

[Colleen Eddy <eddy@xxxxxxxxxxx>]

July 15, 2010



Peter Dengate Thrush, Chairman

Members of the Board of Directors

International Corporation for Assigned Names and Numbers

Internet Corporation for Assigned Names and Numbers

4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601
USA

RE:  Opposition to Employ Media Request to Change sTLD Charter

Dear Chairman Dengate Thrush and Members of the Board:

Poynter is a nonprofit media organization serving journalists and  
media executives worldwide. Poynter’s  career center and job board is  
for media journalists and professionals.   This career center has been  
established since 2006.
I am writing on behalf of the Poynter Career Center  to urge you to  
reject Employ Media’s request for authority to permit second level  
registration of strings that do not correspond to an employer’s name  
in the .jobs sponsored top level domain.  Poynter Career Center, which  
would be directly and adversely affected, opposes the unilateral  
expansion of the .jobs charter to encompass regional and industry- 
specific second-level registrations.
Under the terms of ICANN’s request for proposals for new sTLDs dated  
15 December 2003, (the “sTLD RFP”), applicants – including Employ  
Media - were required to demonstrate that the proposed sTLD addresses  
the needs and interests of a clearly defined community (the Sponsored  
TLD Community).  In addition, applicants were required to demonstrate  
that the policy-formulation procedures for the sTLD operate primarily  
in the interests of the Sponsored TLD Community, and that the proposed  
sTLD enjoys broad based support of the Sponsored TLD Community.[1]
In its application, Employ Media proposed to serve the needs of human  
resources professionals responsible for human resources management in  
the corporate setting, and pledged to maintain .jobs as “a name space  
for employers.”[2]  The limited nature of the .jobs Sponsored  
Community is reflected by the applicant’s commitment to limit  
registrations to the legal name of an employer and/or a name or  
abbreviation by which the employer is commonly known.  According to  
the sTLD Application, “due to restrictions set forth in this proposal,  
a registration in the .jobs sTLD will be associated with an  
employer,”[3] and Employ Media committed to prohibit registration of  
occupational and industry, and geographic identifiers.”[4]  The bottom  
line is that as proposed by Employ Media and approved by ICANN,  
the .jobs sTLD is intended to serve HR professionals and recruiting  
firms representing direct employers only, in each case by using the  
legal name of such employers as a registration at the second level.   
That community does not include online employment services providers  
like Poynter Career Center, nor did Employ Media demonstrate the  
support of online employment services providers in connection with  
the .jobs sTLD Application.
Employ Media’s current request for authority to permit the  
“registration, use, and promotions of domains that are not the company  
names of the registrant”[5] would fundamentally alter the Sponsored  
Community for the .jobs sTLD and eliminate its pledge not to create  
second level registrations of regional and industry-specific job  
boards.  Employ Media did not attempt to demonstrate the support of  
online employment services providers and their vendors, and in fact  
went out of its way to avoid contacting job board operators about the  
proposed expansion.[6]  This is not surprising, given that Employ  
Media intends to add second level registrations that will be  
confusingly similar to established job boards.
As a material change to the .jobs Registry Agreement, this request  
must be reviewed by the ICANN Board based on applicable criteria from  
the sTLD RFP.  Under those criteria, the request should be rejected as  
an attempt to “route around” the sponsorship eligibility requirements  
in the sTLD RFP and the protections built into the .jobs Registry  
Agreement to prevent “abusive registration activities and other  
activities that affect the legal rights of others.”[7]  Approval of  
the .jobs Phased Allocation Program would threaten the integrity of  
the RSEP process and undermine the credibility of ICANN’s commitments  
in connection with the introduction of new top level domains in general
 Sincerely,


Colleen Eddy, Director,


Poynter Career Center