NCUC comments on IRT Report from NCUC IRT Response Team

Robin Gross robin at IPJUSTICE.ORG
Tue Jul 7 00:19:08 CEST 2009


Dear All:

Below please find NCUC's draft comments on the IRT Report.

Thank you to Konstantinos and Kathy for the lion's share of the work  
in drafting these comments!

Please send any feedback and suggestions in the next couple of hours  
because we need to file these today.   Send any comments directly to  
me (and cc Kathy and Konstantinos in case they are still online  
then).  There is no time for major revisions - only minor tweaks to  
improve the existing text.

Thank you,
Robin

---------------------------------------------------------

Noncommercial Users Constituency

Submits its



COMMENTS ON PROCEDURAL ASPECTS OF THE IRT FINAL REPORT—

A SUGGESTED ROADMAP FOR MOVING FORWARD





These are the comments of ICANN’S Non-Commercial User Constituency  
(NCUC), a group which dates back to ICANN’s founding and has actively  
and fully participated in all policy-making proceedings at ICANN  
involving domain names and domain name disputes.



NCUC has 102 members in 40 different countries, including 37  
individuals and 65 organizations as members.  We represent a wide  
array of noncommercial groups, including human rights organizations.   
Our members, and those they represent, often risk their lives and  
their livelihoods to post information about politics, corruption,  
revolution and the pursuit of free and democratic rights by  
individuals and organizations.  In addition, our members use the  
Internet, their domain names and their websites to post free and fair  
critiques of large companies, their products, services and practices  
to the world for lawful discussion and debate.



Our members, and those we have worked with over the 10 years of  
ICANN, are often the target of overbroad trademark claims, abusive  
cease and desist letters, invalid UDRP filings and a pattern of  
practices to shut down their speech by challenging their right to the  
domain names (often well-known, well-linked and well-bookmarked  
domain names).  To shut down the domain name is to shut down the  
speech, the competition and the criticisms.  It is an abuse we call  
“trademark lawyer abuse,” and in the David v. Goliath battles of  
small noncommercial organizations and individuals vs. large  
companies, “trademark lawyer abuse” is, unfortunately, rampant.  (See  
the website www.chillingeffects.org for thousands of examples of such  
abuse documented by the public.)



It became very clear in the NCUC/IRT Team meeting in Sydney, that the  
issue of “trademark lawyer abuse” had not been addressed by the IRT  
Team – and was, rightly, considered a valid and necessary  
counterweight to the domain name registrant abuse upon which so much  
of the IRT Report is premised.  Since the IRT Report was drafted  
behind closed doors by a group of trademark attorneys who represent  
the world’s largest trademark owners and without any representation  
of domain name registrants, it comes as no surprise that the report  
is one-sided and unbalanced in its treatment of issues.



We renew our claims that the IRT process was imbalanced and unfair,  
and repeat our concerns below. At the same time, we recognize that  
even the worst processes sometimes move forward.  Should the IRT  
process continue to move forward, the NCUC has strong recommendations  
to ensure that a similar imbalance of views, experiences and concerns  
does not continue to the next level of use of these materials.




I.     Formation of the Implementation Recommendation Team (IRT) took  
place in a non-inclusive and unrepresentative manner.



The first official document informing the GNSO community of the  
formation of the IRT was in the form of an email, sent by the  
Intellectual Property Constituency on March 11, 2009.  It provided a  
mere 36 hours for groups to express interest in adding members to the  
IPC-formed IRT committee.  Timely responses by the ALAC to add well- 
known attorney Bret Fausett and by the Internet Commerce Association  
to add its president were rejected. Clearly, the views of registrants  
– be it noncommercial, individual or commercial- were considered  
irrelevant.


We note that such a focus on the needs of only one constituency, the  
IPC, is undemocratic and against the traditional values of diversity  
and multi-stakeholderism within ICANN.  Noticeable absent were those  
who represent human rights coalitions, free speech and freedom of  
expression organizations and privacy groups.  Also not invited to  
participate were representatives of domain name registrants – those  
who will actually be impacted by these new rules.  These  
organizations and individuals would have brought to the table  
valuable – critical – information about the balance of trademark law  
and its limits as regards fair use, free speech and freedom of  
expression.



    A.  The IRT Team Attempts to Rewrite GNSO Developed Policy



When the Intellectual Property Rights Constituency did not get  
everything it wanted in the GNSO policy development process it  
created the IRT to re-open and re-negotiate the issue to its liking.   
The GNSO carefully considered the issue of protecting trademark  
rights in new top-level domains and included GNSO negotiated  
solutions in its final recommendations.  In particular, the GNSO  
Working Group “Protecting the Rights of Others” Working Group was  
tasked with this objective of protecting trademarks <http:// 
forum.icann.org/lists/gnso-pro-wg/>.  This working group was not able  
to come to agreement and support the proposals of the Intellectual  
Property Constituency that are now re-opened by the IRT Team.  Re- 
opening these issues and throwing out the negotiated consensus that  
was reached between all stakeholders undermines ICANN’s claim of  
“bottom-up” policy-making that involves all stakeholders equally.





B. The IRT Team Operated without Transparency



Contrary to the practices on which ICANN committees are based, the  
IRT Team provided no information about its meetings, and no  
proceedings of the development of its work.  This ‘Masonic’ approach  
is worrying, puts a big question mark to the way substantive policy  
issues have been approached, and sets a precedent for a one-sided  
approach to policy which ICANN should not follow going forward.




C.  ICANN Provided Travel Support and Expenditures for the World’s  
Largest

       Companies and IPC-Members



It is the tradition of the GNSO that individual constituencies pay  
the cost of their representatives to participate in the ICANN  
process. At great cost and difficulty, the NCUC has sent its members  
to participate for years.  We continue to raise an objection to  
ICANN’s singling out support for a single constituency in the GNSO in  
the negotiation of this issue, a constituency comprising the world’s  
largest and wealthiest companies   Asking Internet users to foot the  
bill for the creation and sale of this one-sided policy proposal  
which benefits a single interest (large brand owners) to the  
detriment of all others simply isn’t fair.



Rather than an IRT Presentation in NYC, London and Hong Kong, the  
public forum should provide a balanced presentation of “pro and con”  
views of the IRT Report – with attorneys experienced in trademark  
law, and its limits – with support from ICANN.





II. There is no need to go forward with the IRT Report.



The IRT Report has been roundly rejected by large segments of the  
ICANN community, including NCUC, ALAC, and a significant number of  
members of the Business and Registrar Constituencies.  Even a member  
of the IPC rose at the Sydeny Public Forum to exclaim that trademark  
infringement is not “one of the four horsemen of the  
Apocalypse” (!).  Further, GAC members, including those of France and  
Brazil are questioning the IRT Report findings, and the IRT Team  
composition and process.



Notably, in all 3 straw polls taken by Bruce Tonkin during the Sydney  
IRT Report consultation, the stated consensus from the community was  
against the proposals.  The overwhelming number of comments during  
the Public Forum in Sydney raised objections and concerns to the IRT  
Report, and many more commentators were not able to take the floor to  
raise their objections because time had been called before they could  
reach the microphone.  The overwhelming number of public comments  
submitted thus far in the public comment period weigh against this  
one-sided proposal.   If the general public and non-commercial users  
are to have any say in policy development at ICANN, the IRT Report  
should be rejected since it has failed to provide a solution  
acceptable to the majority of Internet users.



The IRT Report need not go forward. It can stop here. Clearly, the  
IRT Team did not fulfil its mandate – to provide to the ICANN Board  
and the ICANN Committee a report that is reasonable, balanced and  
fair.  To that end, the ICANN Board is free to thank the group for  
its work and continue forward with the rollout of new gTLDs.








III. Should the IRT/IPC process go forward, ICANN needs to ensure  
that the mistakes are corrected – the IRT process needs balance and  
equity among those who review the comments, and incorporate future  
changes into proposals.



The UDRP process of 10 years ago gives us a baseline and a  
precedent.  At the Santiago meeting in 1999, instead of adoption of  
the UDRP, it was clear that deep divisions continued over the UDRP  
recommendations and procedures.  Esther Dyson, then Chairman of the  
ICANN Board, created a diverse committee tasked with creating fair  
and balanced UDRP wording.  The task was difficult, but the group was  
diverse with now well-known representatives of the NCUC, IPC and  
Registrars Constituencies.  The result included the then-new UDRP  
Section 4(c), rights of registrants, for much greater balance,  
fairness and equity.



For the sake of new gTLDs and the ICANN process, should the IRT  
process move forward, ICANN should:

A.            Make the public consultations a debate or at least a  
briefing by two sides, not one.



The IRT report, and its now well-known pitfalls, should be fairly and  
openly presented to those gathered in the Public Consultations  
meetings. This presentation should be by both IRT Committee members  
and those representing views excluded from the IRT Report.



Attorneys for domain name registrants should be given the floor,  
prior to the opening of the public comment period, to present  
PowerPoint slides and widely-agreed upon points of concern and  
dissent with the report.



ICANN should, of course, provide travel support to both sides in the  
interest of fairness and fair presentation.



B.             Create a “Comments-Review Team” with attorneys from  
registrant groups only, or both registrant and trademark groups



As the UDRP process showed, we can only move forward if the reviewing  
group is fair and balanced. Given the IRT Committee’s history of  
rejecting any comments to the IRT Draft Report with which it did not  
agree (see IRT Final Report), it is incumbent on ICANN to bring into  
the process those registrant attorneys with years of experience in  
dealing with “trademark lawyer abuse.” We cannot allow any new  
processes to be gamed, misused and abused by trademark attorneys –  
and the opportunity for such misuse is clear within many of the  
proposals now within the IRT Report.  The best way to limit abuse –  
by both sides—is to have both sides represented in the discussion.





IV. Implementation of the IRT recommendation falls outside ICANN’s  
technical mandate and scope.



ICANN was originally created as a technical entity responsible for  
the day-to-day management of the DNS.  The IRT Report does not fall  
within day-to-day management activities; instead, it is nothing but  
clear policy-making, which may produce future regulatory  
repercussions.  We would like to draw the attention to Esther Dyson –  
first chairwoman of the ICANN Board – who stated:

“The White Paper articulates no Internet Governance role for ICANN,

and the Initial Board shares that (negative) view.

Therefore, ICANN does not ‘aspire to address’ any Internet Governance  
issues;

in effect, it governs the plumbing, not the people [emphasis added].

It has a very limited mandate to administer certain (largely technical)

aspects of the Internet infrastructure in general and

the Domain Name System in particular.”



The IRT recommendations contradict this structural restraint.  It  
seeks to exercise some form of Internet “Regulatory Governance” by  
governing certain aspects of individual behaviour on the Internet.   
NCUC does not oppose trademark rights or their legitimate  
protection.  We oppose the re-tasking of ICANN to expand trademark  
rights in ways trademark law itself does not support.  Trademark  
rights are governed by laws, treaties, legislatures, parliaments and  
other democratic bodies that are appropriately authorized to protect  
those rights; they evolve incrementally, through judicial reasoning.   
ICANN should not set the precedent of inviting the introduction of  
new governance policies that cannot be obtained through legitimate  
means of existing legal regimes.





------------------------------------------------------------------------ 
-------------------------------



These NCUC Comments on Procedural Aspects of the IRT Final Report are  
complemented by a set of NCUC Comments on Substantive Aspects of the  
IRT Final Report, separately submitted in this proceeding.

________________________________________________________________________ 
________________________





Noncommercial Users Constituency

Submits its



COMMENTS ON SUBSTANTIVE RECOMMENDATIONS

IN THE IRT FINAL REPORT—



A CALL FOR RIGHTS OF REGISTRANTS TO BE PROTECTED,

FOR “TRADEMARK LAWYER ABUSE” TO BE RECOGNIZED,

AND FOR IRT/IPC/TRADEMARK PROTECTION PROPOSALS TO

FALL WITHIN THE SCOPE AND MISSION OF ICANN.





These are the comments of ICANN’S Non-Commercial User Constituency  
(NCUC), a group which dates back to ICANN’s founding and has actively  
and fully participated in all policy-making proceedings at ICANN  
involving domain names and domain name disputes before now.



I.              A Few Opening Thoughts



Sydney IRT and Public Consultations



ICANN has now heard loudly and clearly from the ICANN community.   
Throughout the microphones of the Sydney meetings, in forums loud and  
small, the opinions echoed: the IRT Report is not reasonable, is not  
balanced, is not fair and is not just.  In short, the IRT Report is  
not a workable solution.



In the Sydney IRT Consultation, the ceiling rang with a significant  
number of heartfelt and deeply founded, concerns of noncommercial  
registrants, individual registrants, commercial registrants,  
registrars and those speaking for Internet users.  Comment after  
comment from NCUC, ALAC, Registrars and even IP attorneys speaking in  
opposition to the IRT were heard (with many more deep concerns  
expressed in the hallways).



All 3 straw polls, conducted by Bruce Tonkin, on the major pillars of  
the IRT Report in a main IRT presentation (Wed. afternoon) showed  
that not a single major pillar of the report had the support of even  
a bare majority of the community in the room.  In all 3 polls, there  
were more hands raised in opposition to the ITR Report proposals than  
in favor.



To the extent that the IRT Team was called upon to create something  
reasonable and balanced, it has not done so.  Its work should  
conclude without aftermath.  To the extent that its work continues in  
some form, then this work must be done in a manner reflecting the  
diversity of the GNSO and ICANN, and with an expertise and concern  
for the abuse of domain name registrants as well as the policing of  
trademarks.  Such a new group must fairly and in a balanced manner  
represent all constituencies in the GNSO and operate in the  
traditional ICANN open and transparent manner.  (Please see the NCUC  
Procedural Comments on the IRT Final Report, separately submitted.)




Our Goals



These Substantive Comments are devoted to NCUC’s severe, substantive,  
legal and judicial concerns with the proposals of the IRT Report.  We  
will share how the substantive IRT recommendations take ICANN far  
afield of its technical scope and mission, create substantive new  
trademark rights (beyond existing law), gut existing safeguards and  
fair procedures for domain name registrants in the Uniform Dispute  
Resolution Policy (“UDRP”), and create an unbounded situation for  
abuse by trademark lawyers and those representing trademark owners.



We address our significant concerns with all major aspects of the IRT  
Report below.





Two Opening Observations



A. Domain name registrants are not bad.  To read the  
characterizations of the IRT Report, and the comments of the  
committee, domain name registrants are inherently bad.  We are all  
guilty until proven innocent.  We merit no fair or actual notice of  
trademark infringement allegations.  We are not entitled to just or  
fair time to respond.  Following legal due process safeguards is just  
too expensive and time consuming for brand owners.



In fact, as so many pointed out in Sydney, domain name registrants  
are Internet users.  We are amazingly diverse, large and small, in  
developing countries and developed ones.  We are noncommercial  
organizations, commercial companies small and large, individuals –  
registrants include my parents and your children, everyone’s civic  
organizations and parenting groups, our Scouting associations and  
other recreation and hobbies, and human rights groups around the  
world.  We want domain names in our languages and scripts.  We have  
tens of millions of ideas to share, products and services to market  
and discuss, and political ideas to convey – and we register domain  
names to do so.



Domain name registrants (Internet users) pay 100% for ICANN’s  
operation.  It is our billions of domain name registration fees which  
pay the registrars and the registries, who in turn, fund ICANN.   
Domain name registrants everywhere are the broad base of the pyramid  
atop which ICANN rests.



NCUC, along with so many others in Sydney, proclaimed the right of  
all domain name registrants to be treated with fairness and equity,  
justice and process.  We are entitled to respect in the ICANN  
relationship and fundamental fairness before a mere allegation of  
trademark infringement results in the loss or suspension of our  
domain name registration and the underlying speech (noncommercial/  
commercial) it conveys.





B. Cybersquatting has not been proven to be on the rise.  Throughout  
the IRT Report and Sydney, it was proclaimed that cybersquatting is  
on the rise because WIPO UDRP filings were up by 7% in 2009.  But on  
investigation, confrontation with facts, and tough questioning from  
the floor, it was shown that the facts don’t correspond to the  
conclusion.



In 2008, domain name registrations were up by 16 percent. Yet, WIPO  
UDRP filings were up by only 7% -- a percentage-wise reduction  
overall in WIPO UDRP filings. A number of legitimate reasons were put  
forward in Sydney for the slight rise of WIPO UDRP filings (about 200  
in 2008), including:



1. Forum shopping – trademark complainants are choosing WIPO because  
its decisions favor trademark owners;

2. Expansion of UDRP scope – trademark complainants are choosing WIPO  
because its panelists are allowing not policing the traditional  
boundaries of the UDRP as closely as other forums;

3. A huge number of new domain name registrations!



In anything, the many decisions in favor of Respondents (Registrants)  
in the 2008 WIPO UDRP decisions show that the UDRP system works – it  
saves important domain names and the speech and communication for  
which they are used.





II. Detailed Commentary on the Substantive Issues of the IRT Final  
Report and its Proposals


“The IRT recommendation should not usurp or replace

the existence of legal institutions and systems

that are intended to establish the scope of legal rights

(e.g., existing laws and national courts).

IRT Final Report, p. 12.



The recommendation should protect the existing rights of trademark  
owners,

  but neither expand those rights nor create additional legal rights.

IRT Final Report, p. 11.





1. Globally Protected Marks List



Summary: The Globally Protected Marks List (“GPML”) is an  
exceptionally weak part of the IRT Report.  It is not grounded in law  
or practice.  It creates rights to a string of letters, unbounded by  
goods, services, or use, in a way far beyond trademark law.  The  
proposal would limit the right of individuals, noncommercial  
organizations and Internet entrepreneurs to use basic dictionary  
words in the manner to which they have always been entitled by law,  
by fair use and by rights of all to language.





Analysis and Comment

A. The Globally Protected Marks List – the GPML database- is a matter  
well beyond ICANN's scope and its core competence.  In fact, the  
determination of famous marks is a matter of great dispute among  
trademark lawyers and scholars, and one that takes considerable time  
for courts.



B. The GPML is a list far larger than even famous international  
brands.  The GPML, as drafted, may well include hundreds of esoteric  
scientific and technical terms which, while in international use, may  
be completely unknown, unrecognized and unused outside their limited  
technical areas.  To grant such words elevated status in all new  
gTLDs, at top and second levels, defies reason and goes far afield of  
existing trademark rights.



C. The scope of the GPML protection defies the limits of trademark  
law.  The IRT Team proposes that GPML marks will be blocked for  
registration in all new gTLDs – even those intended for noncommercial  
use, criticism or journalism, and for the myriad of other ways in  
which law allows even famous trademarks to be used by others under  
principles of free speech and freedom of expression, fair use and  
noncommercial use.  The IRT Team ignores the simple fact that  
trademark rights do not regulate noncommercial speech and it attempts  
to apply commercial rules to all noncommercial speech.



D. The GPML pushes ICANN, a technical body, into the cutting edge of  
the most difficult trademark law evaluations.  Even national courts  
are wrestling with these issues – with many different results.  A  
Spanish court protected a local “NIKE” brand owner, over the  
internationally known brand; the Canadian Supreme Court found that  
even famous marks are not necessarily entitled to absolute or  
extensive protection -- even over other commercial marks.  (See,  
e.g., Canadian Supreme Court, Mattel, Inc. v 3894207 Canada, Inc.  
2006 SCC 22;  Veuve Cliquot Ponsardin v. Boutiques Cliquot Ltee, 2006  
SCC 23.) This is not the work of ICANN.



E. The GPML extends the protection of trademark words into  
noncommercial or fair use – far beyond where trademark law allows  
such protection to go.   Such overbroad trademark restrictions will  
inevitably stifle the free flow of information and chill freedom of  
expression on the Internet.  It will also have a detrimental effect  
upon innovation and use of domain names by entrepreneurs and  
individual users.



F. The GPML extends protection of trademarked words into completely  
unrelated lines of goods or services, which traditionally remain  
protected for use by others, even under trademark law (e.g., the use  
of one’s last name in a professional capacity and as a company name,  
such as McDonalds, C.P.A. or McDonalds Accounting).



G. The GPML standard, as applied to top level domains, contradicts  
trademark law itself.  The implications of a “confusingly similar”  
analysis boggle the mind.  A “goggle” GPML listing might be used to  
block a future “Google” gTLD application; a “lego” GPML listing might  
block a future “logo” gTLD application (a children’s programming  
language created by MIT in the 1960s).



H. The NCUC, as final drafter of the UDRP notes that the IRT Report  
uses UDRP Paragraph 4(c) in a manner which it was never drafted nor  
intended—and in a way completely outside the bounds of law and  
language.  UDRP Paragraph 4(c), rights of registrants, was drafted as  
a defense to cybersquatting.  It was never intended to incorporate  
all rights of a new registrant to a domain name – nor to require  
registrants to justify their right to use ordinary words or common  
names.  We may name our children any name we like, without regard to  
“existing rights;” we may pick the names of our new products without  
any right to the terms we choose (other than avoiding clear  
confusion).  Benjamin Franklin named his almanac “Poor Richard’s  
Almanac” without any existing right or interest in “Richard.”  The  
IRT Report turns this notion of rights on its head and shifts the  
burden of proof onto the registrant.



NCUC supports the right of all Internet users, now and in the future,  
to use all words – the basic building blocks of language- in any  
manner not proscribed by law and without any need to prove some  
existential right.  Apple Computer, Inc. did not have to provide such  
a right, Google did not have to prove a right – neither must those  
individuals, noncommercial organizations and entrepreneurs who follow.



I. The attempt to create the GPML has already revealed numerous  
substantial challenges, opposition, lack of definition and complete  
lack of agreement.  The GMPL’s development, should it be allowed to  
go forward, will delay, rather than speed, the implementation of new  
gTLDs.



Overall, we recognize the problem the IRT/IPC Team is grappling  
with.  At some future point, when legitimate criteria are in place or  
any legitimate body has come to a determination as to which marks  
should be entitled global protection, ICANN should consider  
appropriate ways to incorporate the list into registration  
practices.  Until then, the creation of such a list by ICANN is  
completely outside the scope and mission of the organization, as well  
as outside its expertise.  To do so will delay the process of gTLDs  
forever.





2. Uniform Rapid Suspension System Policy (URSP)



Summary:  For those who have participated so long and so well in the  
GNSO process, the supplanting of the UDRP by the URSP comes as a  
complete surprise.  To the extent that the UDRP needs reform, then  
let’s sit down and evaluate it together with the entire GNSO and  
ICANN community.



As drafted, the proposed USRP supplants the UDRP with its broad  
access by nearly every trademark owner to the USRP instead of the  
UDRP.  The URSP, further, guts the UDRP’s protection of domain name  
registrants by removing reasonable notice provisions and the basic  
time necessary to prepare a response by registrants.  It further  
opens the domain name dispute policy to gaming, bad acts and abuse by  
trademark attorneys.



Should the IRT/IPC Team have a much narrower set of particularly  
egregious bad acts it would like to share for discussion, the NCUC is  
willing to listen and discuss those truly bad acts.



Analysis and Comment



A. Criticism of and opposition to the URSP was nearly universal in  
Sydney.  Noncommercial users, individuals, commercial users and their  
representatives rose to speak separately and together against the  
URSP as a proposed system that provides rights for only one side –  
the trademark owner – and virtually no rights for domain name  
registrants.



B. In its Joint Statement on the IRT Report from members of ALAC and  
NCUC, the two groups jointly presented the following severe critique  
of the URSP:



“We have serious issues with the Uniform Rapid Suspension Service  
(URS) as proposed. For instance, the URS mechanism subverts  
conventional UDRP practice as it gives entirely insufficient time for  
notice to the registrant of the pending dispute.  Thus, the  
registrant is unfairly limited in his/her right of response and the  
process is missing the fundamental principle of due process.”



C. After 10 years in operation, we all have concerns with the UDRP  
and aspects we would seek to change.  If the IRT/IPC has problems  
with the UDRP, then let’s investigate them together.  To start the  
discussion, the NCUC would like to know:

1. When was it decided that the UDRP is insufficient to deal with  
cybersquatting?

2. Which parts of the UDRP are problematic?



D. Domain name Registrants are entitled to fair notice and a fair  
time for response.



a.     Registrants need actual notice.  NCUC representatives wrote  
into the UDRP the broadest method of notice to work towards “actual  
notice” – in which the registrant actually knows a proceeding is  
taking place against her/his domain name.  The URSP has no such goal.



b.     Registrants need adequate time to respond. As we discussed in  
Sydney, trademark owners have all the opportunity here: as much time  
as they choose to prepare a complaint, and an open calendar for  
submission. Gaming is invited – with complaints likely to be  
submitted in December or August and decisions made before a  
vacationing Registrant even knows the complaint was filed.



c.     As the URSP provides insufficient notice and time, no  
Registrant or Attorney will be able to provide a proper response ---  
critical speech will be lost.



E. The URSP operates on the same premise for which the UDRP was  
created –- to create a cheap and fast system of resolving trademark  
conflicts online.



Ten years ago trademark owners danced in the aisles of the ICANN  
meeting because the UDRP was far cheaper and faster than actions in  
local courts.  We see nothing in the IRT Report to indicate the UDRP  
is not working.  We see much in our NCUC evaluation of UDRP cases to  
illustrate the opposite—that the UDRP actions in favor of registrants  
are protecting important noncommercial, individual and commercial  
domain name use and speech online.



We further note that UDRP decisions show that trademark owners seek  
to use the UDRP to silence criticism, stop competition, control  
discussion, and seek access to words and domain names to which they  
are not entitled by law.  While the UDRP provides some balance for  
the potential of abuse on both sides (trademark complainants and  
registrants), such balances is completely lacking from the URSP.



F. “The URS is not intended for use in any questionable proceedings,  
but only clear cases of trademark abuse.”



The IRT recommendation suggests that the Uniform Suspension System is  
necessary to fight cybersquatting. Around 10 years ago, the exact,  
same issue justified the creation of the UDRP. "Except in cases  
involving ‘abusive registrations’ made with bad faith intent to  
profit commercially from others’ trademarks (e.g. cybersquatting and  
cyberpiracy) the adopted policy leaves the resolution of disputes to  
the courts and calls for registrars not to disturb a registration  
until those courts decide.  The adopted policy establishes a  
streamlined, inexpensive administrative dispute-resolution procedure  
intended only for the relatively narrow class of cases of "abusive  
registrations". Second Staff Report on Implementation Documents for  
the Uniform Dispute Resolution Policy (October 24, 1999), available  
at <http:www.icann.org/udrp/udrp-second-staff-report-24oct99.htm



What is really the reason behind the creation of the URSP?  What is  
on the mind of the IRT Team?  Is this the way of the IRT Team to tell  
us that ten years of UDRP case law have been unsuccessful?  But, the  
report itself states that the UDRP has been successful: “The UDRP has  
unquestionably been an important and successful mediation tool for  
trademark owners and domain name registrants alike”.  (IRT Report, p.  
25).  The justifications behind the URSP are not convincing enough  
and seek to address concerns of no substance or reasoning.  And some  
members of the IPR community are already calling for URSP to apply to  
existing domain names and to replace the UDRP.







G.   “Trademark Lawyer Abuse” must be taken into account.



Everyday, the NCUC and its members see the flip side of  
cybersquatting --- “Trademark Lawyer Abuse.”  There are bad acts,  
unsubstantiated threats, overbroad claims and misuse of the UDRP  
process, cease and desist letter and other methods of threatening  
domain names.  See the website www.chillingeffects.org for thousands  
of examples of such abuses documented by Internet users.  Often  
trademark lawyers use the UDRP to manipulate the system, take  
advantage of their Goliath v. David position.  They seek to use the  
UDRP to remove domain names for reasons that have nothing to do with  
cybersquatting – but instead to remove competition, to take down  
criticism, or merely to expand a DN portfolio.



The URSP proposals fails to take into account the bad faith, gaming,  
misuse, misinterpretation and abuse of trademark lawyers.  Until the  
proposals are balanced  to include concerns from both sides, they  
cannot be considered for implementation.



H. An Invitation for Future Discussion



The NCUC issues the following invitation: if there are extraordinary  
cases of domain name registration abuse which merit consideration for  
immediate revocation, we urge the IRT Team to bring them forward.  We  
are willing to consider the possibility of extraordinarily and  
egregious cases, and appropriate action to address such legitimate  
concerns.  Such circumstances exist in other settings, and might  
possibly exist here.



But the scope of the net the URSP catches cannot include legitimate  
domain name registrants, good actors – it cannot result in the loss  
of legitimate domain names and the critical speech and free flow of  
information for which they are used.





3.  Post-Delegation Dispute Mechanism as Revised by the IRT



NCUC argues that the IRT Team’s foray into this area fall far outside  
the scope of  the IRT Team’s mandate, which is limited to only  
commenting on issues of trademark law.  The IRT Team’s  
recommendations about ICANN’s contractual clauses with Registries/ 
Registrars should not be considered.



4. WHOIS



In proposing a thick Whois for all new gTLDs, the IRT Team does not  
provide any explanation as to why such a massive amount of data  
should be allocated to only one registry for new gTLDs.



Like trademark law, privacy law is territorial in nature.  Different  
countries have different laws, and many countries protect the  
personal data of their citizens.  Some countries, including the  
United States, protect the right of anonymous political speech as a  
democratic principle.  Registrars are more likely to know the privacy  
and data protection laws which protect their registrants, and the  
practices of their regions.



As NCUC and ALAC together presented in their Joint Statement on the  
IRT Report:



We are opposed to the IRT proposal´s policy recommendation to move to  
a Thick Whois without doing a privacy analysis, nor taking into  
account national laws nor International Privacy Standards, such as  
1980 OECD Guidelines, the Privacy Convention 108 and the EU Data  
Protection Directive.



5. IP Clearinghouse



Summary: The IP Clearinghouse takes ICANN far outside its scope and  
technical mission.  It is an intellectual property rights structure  
that has no barrier to creation in the private sector, and is  
consistent with the types of private sector services, including  
monitoring and alert, now being offered.  Further, the creation of  
such a superstructure of ICANN, a single monolith, will attract such  
lobbying from brand owners that the rollout of new gTLDs may be  
further delayed for years!



To the extent that private IP Clearinghouses emerge in the various  
regions of the world to support the various languages of the world,  
and practices of the various national trademark laws, we agree.  Such  
private structures, or one supported by national Trademark Offices,  
are consistent with the territorial bounds of trademark law, the  
diversity of trademark rights and practices and the separate bounds  
and limits on trademark rights under national laws.





Analysis and Comment



NCUC understands from its consultations with IRT attorneys and  
potential new gTLD applicants that the IP Clearinghouse concept is  
designed to prevent redundancy and create efficiencies.  It may come  
as a surprise that we have no objection to the general concept – we  
all support efficiencies, provided they are bounded by the  
traditional limits of trademark law and provide the new gTLD  
Registries and Registries with the necessary data to make informed  
and accurate decisions regarding whether an asserted trademark right  
truly falls with the scope of a new gTLD.



NCUC further submits that – in the strongest terms – we contest and  
discourage ICANN from creating the proposed IP Clearinghouse as a  
single massive monolithic database of ambiguous trademark rights.   
For every reason imaginable, including ICANN’s technical mission and  
specific areas of technical expertise, such an entry into the  
intellectual property rights legal regimes would derail ICANN’s  
mission and dramatically change the scope, nature and faces of the  
ICANN community.  Such an IP Clearinghouse structure could completely  
derail ICANN.



In particular, NCUC notes:



A.  Brand owners have no consensus on what goes into the database.   
Throughout Sydney, we heard that registered marks, and unregistered  
marks, national marks and state marks, intent to use and those in  
use, and even completely unrelated trademark rights may be entered.



Let the trademark owners create individual, regional IP Clearinghouse  
or work with the IP Clearinghouses to develop policies that most  
accurately reflect the rights and territorial limitations of  
trademark law in their jurisdictions.



B. ICANN has no scope nor authority to create a single, monolithic,  
undefined superstructure to adjudicate legal rights.  The creation of  
such a legal regime falls completely outside the function of ICANN as  
set out in the foundational White Paper.



C. Even if ICANN had the authority, which it does not, it should not  
want to create a single, monolithic IP Clearinghouse because such a  
process will change the nature of the community ICANN serves.  The  
jockeying for position in the IP Clearinghouse, the hope of extending  
its reach to even the dimmest trademark and other intellectual  
property right, will lead to a run on ICANN by trademark owners. This  
discussion, debate, and jockeying for rules of the IP Clearinghouse  
should happen outside the bounds of ICANN.



D.  The various national Trademark Offices are in a much better  
position to lead these discussions than ICANN.  Trademarks are  
territorial by nature.  They are bounded by the scope of their use,  
and by other intricacies of local law, e.g., the law that determines  
when a well-known, or even famous mark, has become generic (e.g.,  
elevator in American and hoover in English).



It is the national Trademark Offices which can best guide this  
discussion.  It is the national Trademark Offices which can best work  
together on a regional basis to support (or even help run) regional  
IP Clearinghouses.  Further, virtually all national Trademark Offices  
enter their registrations into databases.  While only some provide  
access to these databases openly to the public online, they could  
make access easily available to private IP Clearinghouse in which  
they had a hand in creating and/or running and/or overseeing.



Further, the national Trademark Offices are also the most informed  
about the limits of trademark law, their national law protections for  
freedom of expression and fair use, and can seek to incorporate these  
balances and protections of their laws into the scope and framework  
of the IP Clearinghouses.



E. Should such regional, private (and/or Trademark Office-informed)  
IP Clearinghouses be created, NCUC strongly recommends the clear and  
unmitigated addition of information necessary for the new gTLD  
Registries and Registrars to operate:

a.    the international class(es) of goods and services in which the  
goods are registered;

b.    the complete and specific description of goods and services  
which all trademark applicants must provide as a condition of  
submitting a trademark application;

c.     the entity granting the trademark registration (e.g., country,  
region) .



F. To serve IDNs, the private, regional IP Clearinghouses are in the  
best position to meet the needs of trademark owners working in their  
own languages and scripts.



G. NCUC agrees that the use of the private IP Clearinghouse should be  
optional.  Registrars and registries should work with the IP  
Clearinghouses appropriate to their languages, regions, scripts and  
community.



H. The market has already created IP Clearinghouse-type databases for  
the sunrise periods that have passed – the market will inevitably  
meet the need for new private, regional IP Clearinghouses, especially  
if ICANN makes clear the need for new gTLDs.



Overall, a single, dominant, monolithic and monopolistic IP  
Clearinghouse will delay the implementation of new gTLDs for years.   
It is outside the scope and technical mission of ICANN.  Further, not  
all conflicts can be anticipated or foreseen.  The tried-and-true  
dispute mechanisms of the UDRP process and courts will continue to  
provide an avenue to all who feel they have a legitimate case.



------------------------------------------------------------------------ 
-------------------------------



In conclusion, the NCUC appreciates the opportunity to submit these  
Substantive Comments, and its separate Procedural Comments, in this  
proceeding.  We also appreciated our meeting with members of the IRT  
Team.



The reception that we received in that meeting – to our concerns  
about Trademark Lawyer Abuse, to our concerns for fairness to Domain  
Name Registrants – showed us that, had the IRT Team held equal  
numbers of Registrant and Trademark Owner attorneys, our comments  
today would have been different and this one-sided report would have  
been much more balanced.



Overall, despite its flaws, conceptually the UDRP is still a system  
that works – and one which, in light of the anticipated traffic in  
the DNS, can stretch its scope to incorporate novel issues of abuse.   
Let’s move as the entire GNSO and ICANN community to a substantive  
UDRP reform.  Together we can improve it fairly– for all parties.




















IP JUSTICE
Robin Gross, Executive Director
1192 Haight Street, San Francisco, CA  94117  USA
p: +1-415-553-6261    f: +1-415-462-6451
w: http://www.ipjustice.org     e: robin at ipjustice.org



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