Opposition to Employ Media sTLD Charter Amendment
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. 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." 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." Employ Media's current request to permit the "registration, use, and promotions of domains that are not the company names of the registrant" 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." 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> ________________________________  http://www.icann.org/en/tlds/new-stld-rfp/new-stld-application-parta-15dec03.htm  sTLD Applicant responses to request for further information, at page 48 of 177 http://www.icann.org/en/tlds/stld-apps-19mar04/PostAppC.pdf  Id.  http://www.icann.org/en/registries/rsep/jobs-proposal-09jun10-en.pdf (hereinafter, Employ Media RSEP Request")  .jobs Registry Agreement, Appendix S Part VII: Other Provisions (2. "Community Value Criteria") ________________________________ This e-mail is the property of NaviSite, Inc. It is intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential, or otherwise protected from disclosure. Distribution or copying of this e-mail, or the information contained herein, to anyone other than the intended recipient is prohibited.