RE: Employ Media sTLD Charter Amendment
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 By Email To: jobs-phased-allocation@xxxxxxxxx RE: Employ Media sTLD Charter Amendment Dear Chairman Dengate Thrush and Members of the Board: I 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. My organization would not be directly and adversely affected by this request, but I firmly believe the jobseekers and employers would be done a tremendous disservice by the unilateral expansion of the .jobs charter to encompass regional and industry-specific second-level registrations. The foundation for this belief can be dissected into five core points: **** 1) Employ Media's abandonment of the original charter request comes from mismanagement of a solid, universally-beneficial concept: Taken from Employ Media's own site (http://www.employmedia.com/.jobs.domain.is.alive.pdf, mirrored on Google at http://bit.ly/b94wCd): "The data is going to have to stay pure. If engineering.jobs, marketing.jobs, etc. ever get sold in conjunction with statefarm.jobs, .jobs will have no greater benefit than a .net." This statement embodies the foundation that Employ Media has marketed to employers over the last 5 years. Contrary to that public-facing message, since July of 2008 Employ Media (as seen through inquiries from Ray Fassett) has had the desire and sought to deploy and profit from .jobs being used to power vertical niches outside of the original .jobs charter. These conflicting actions clearly demonstrate that Employ Media did not have the intention to expand the .jobs TLD as established in their ICANN charter. Rather than seeking more appropriate methods to establish and cultivate, Employ Media's actions have proven their preference to monetize TLD as a personal-property rather than to serve .jobs chief purpose of serving employers and jobseekers. 2) The proposed amendment offers no method for dispute resolution: Under the previous domain allocation structure, there was no potential for cybersquatting. With the proposed 3rd phase of the RSEP, a registrant could potentially acquire the domain-name implying it is owned by "Company ABC" - resulting in potential crimes against jobseekers, damage to the target's brand, and with no speedy, democratic means of resolution. 3) Phase One of the RSEP's lack of transparency is monopolistic: There can be no doubt of Employ Media's preferential treatment of JobCentral/Direct Employers (BusinessWeek covered their partnership in June 2009). In no other TLD is there potential for a registrar to give a single, seperate entity right of first refusal for all domains. Simply put, this secretive process for preferential domain dispersal does nothing for the fair market internet economy, and stands to benefit only Employ Media and Direct Employers. Anything short of a 100% transparent and open auction system for domain distribution, run by a completely arbitrary third-party, will set a destructive precedent in a TLD's right to shape the internet based on their personal preference. 4) Previous branding of .jobs would be in grievous contrast to the TLD's new foundation: Since the foundation of .jobs, jobseekers have been told they can unquestionably trust every job on any .jobs site (see http://goto.jobs/movie/dotjobs.wmv, mirrored at http://dl.dropbox.com/u/7539417/dotjobs.wmv). This complete shift from that original message, without any tremendous marketing effort to change that perception, puts the public in further danger of falling victim to identity theft (see http://cnn.com/2009/LIVING/worklife/07/15/cb.avoid.job.scams/). 5) Without completely disclosing entire WHOIS information for each domain and without vetting each domain purchase, there is no longer a method to prove any .jobs domain's authenticity. **** I strongly urge ICANN to reject Employ Media's "Amendment No. 2 to the dot-JOBS Registry Agreement." Sincerely, Eric Caron - 952-277-4539 - eric.caron@xxxxxxxxxx JobDig, Inc.