Comments on Special Trademarks Issues Report

[Richard Tindal <richardtindal@xxxxxx>]

I support the recommendations in this report and commend the STI working team 
for their successful efforts in consensus making.   Trademark issues are 
arguably the most complex and contentious in the new gTLD process.  Despite 
this the STI Team have built on input from the IRT and the community to reach a 
fair and workable compromise on these difficult issues.

I endorse all recommendations in the report (however I do not support the 
positions in the minority statements).  In particular I’m pleased to see GNSO 
reach consensus on a mandatory URS for rapid takedown in clear-cut cases of 
trademark abuse. I have been a supporter of such mandatory takedown since 
before the IRT was formed and am pleased to see the STI produce detailed and 
sensible procedures for how this takedown should operate.    The report 
proposes important safeguards to reduce abuse of the URS by over-reaching 
trademark holders.  We will need to be vigilant in ensuring these safeguards 
are properly implemented and operated.    

The URS and Trademark Clearinghouse should now enter the DAG and join mandatory 
Thick WhoIs, mandatory Sunrise/IP Claims, and PDDRP to create a suite of 
trademark protections for new TLDs that vastly exceed those in existing TLDs.   
With these protections in place new TLDs will become much safer places for 
trademarks than existing TLDs, such as .COM, where trademark infringement is 
rife.     Consequently, once new TLDs are launched and some market share moves 
to these new TLDs, I believe there will be significantly less trademark 
infringement in the overall domain space. 

Richard Tindal

Washington, DC