[bc-gnso] BC Reply Comment on Strawman proposal

[martinsutton at hsbc.com]

Thanks Steve - I support the reply.

Martin C SUTTON 
Group Risk 
Manager, Group Fraud Risk and Intelligence | HSBC HOLDINGS PLC HGHQ
Group Security & Fraud Risk
8 Canada Square,Canary Wharf,London,E14 5HQ,United Kingdom
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Phone
+44 (0)20 7991 8074 / 7991 8074
Mobile
+44 (0) 7774556680
Email
martinsutton at hsbc.com

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From:
Steve DelBianco <sdelbianco at netchoice.org>
To:
bc - GNSO list <bc-gnso at icann.org>
Date:
05/02/2013 03:22
Subject:
[bc-gnso] BC Reply Comment on Strawman proposal
Sent by:
owner-bc-gnso at icann.org



On 15-Jan, the BC filed substantive comments on the TM Clearinghouse 
Strawman solution. (link)

We did not anticipate needing to also file a "Reply" comment.  But the 
ExCom now believes we should file, since we heard last week about the 
CEO's wavering support for the Strawman proposal.

Feb 5 is deadline for "Reply" comments on this topic. So we are proposing 
a brief Reply comment summarizing comments filed and re-emphasizing key 
parts of our initial Strawman comments. 

Below are DRAFT Reply Comments from the Business Constituency, regarding 
TM Clearinghouse Strawman Solution (link)

Of the 88 comments filed on the Strawman solution, 67 supported the 
Strawman solution and/or called for even stronger rights protection 
mechanisms, such as Limited Preventive Registrations (LPR).   In other 
words, 76 percent of commenters favor implementation changes such as 
advance Sunrise notice and enhanced TM claim notices.

Unsurprisingly, these supporting comments came from businesses that are 
negatively affected by having to purchase defensive registrations and 
engage in other expensive and often inadequate mechanisms to protect their 
consumers against confusion or outright fraud using second level domain 
names. 

While the BC does not believe that new gTLD operators will proactively 
solicit fraudulent registrations, we believe the comments submitted show 
that present anti-abuse mechanisms are simply inadequate.  That is why 
commenters from around the world have endorsed the minimal implementation 
improvements proposed in the Strawman.

The additional Strawman suggestion for Limited Preventive Registrations 
(LPR) also found wide support in comments filed.  We believe that LPR 
could be done as a matter of implementation.   But if ICANN determines 
that LPR is new policy, we believe that GNSO Council should embark on a 
fast-track policy development process (PDP).  The gNSO Council has in the 
past done at least one fast-track PDP, which entailed face-to-face working 
sessions and significant time commitment from Councilors.   ICANN should 
also commit to provide support for a fast track PDP, such as consulting 
services and travel funding for PDP participants.


Unless we see objections from at least four BC members, we will file the 
above comment before end of day tomorrow, 5-Feb-2013.

-- 
Steve DelBianco
Vice chair for policy coordination
Business Constituency






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