Opposition to Employ Media sTLD Charter Amendment

["Sinha, Rathin" <rsinha@xxxxxxxxxxxx>]

July 14, 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:  Employ Media sTLD Charter Amendment

Dear Chairman Dengate Thrush and Members of the Board:



I am writing on behalf of America's Job Exchange (www.americasjobexchange.com), 
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. 
www.americasjobexchange.com<http://www.americasjobexchange.com> , 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]  It 
also promised to limit registrations to the legal name of an employer and/or a 
name or abbreviation by which the employer is commonly known and to prohibit 
registration of occupational and industry, and geographic identifiers."[3]  
Employ Media's current request to permit the "registration, use, and promotions 
of domains that are not the company names of the registrant"[4] 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 does not have the support of online employment service providers 
such as www.americasjobexchange.com to add second level registrations that will 
be confusingly similar to established job boards.  ICANN should not permit sTLD 
operators 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."[5]  Approval would undermine the credibility of ICANN's 
commitments in connection with the introduction of new top level domains in 
general, and "community based" TLDs in particular.

Sincerely,



 Rathin Sinha
 President
 America's Job Exchange
 (A subsidiary of NaviSite)

 978.946.5863 (P) | 978.259.8653 (C)
 rsinha@xxxxxxxxxxxxxxxxxxxxxxx<mailto:rsinha@xxxxxxxxxxxxxxxxxxxxxxx>


________________________________

[1] 
http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03.htm

[2] sTLD Applicant responses to request for further information, at page 48 of 
177 http://www.icann.org/en/tlds/stld-apps-19mar04/PostAppC.pdf

[3] Id.

[4] http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf 
(hereinafter, Employ Media RSEP Request")

[5] .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2. 
"Community Value Criteria")



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