[Exemption-request] Comments on .translations excemption request

[Volker Greimann]

Dear ICANN

thank you for providing the opportunity to provide public feedback on 
the excemption requests for so-called dotBrand TLD applications.

Having reviewed the requirements for eligibility for an exemption from 
the code of conduct as well as the exemption request itself, this string 
appears to fail to fullfill the most important requirement as it is a 
generic string as defined in Section 3d of Specification 11 of the 
Registry Agreement.

The term "Translations" is the plural form of the common English noun 
translation, meaning:

1.the rendering of something into another language 
<http://dictionary.reference.com/browse/language> or into one's own from 
another language.
2. a version of such a rendering: a new translation of Plato.
3.change or conversion to another form, appearance, etc.; 
transformation: a swift translation of thought into action.
4.the act or process of translating.
5.the state of being translated.

(Source: http://dictionary.reference.com/browse/translations?s=t)

.translations is therefore a string consisting of a word or term that 
denominates or describes a general class of goods, services, groups, 
organizations or things, as opposed to distinguishing a specific brand 
of goods, services, groups, organizations or things from those of others.

 From the initial application, it is also clear that the applicant 
intends to use the TLD in the generic meaning of the string:

Section 18(a) of the application reads:
/The mission and purpose of the .translations TLD is to promote 
translation as a professional skill and intellectual service (....). The 
Translations company believes, first, that translation is a ?high added 
value? service and second, that the translator is the most important 
aspect of this service. The .translations TLD will be an informative 
space used by Translations company to educate the Internet public about 
the role and benefit of professional translation and to generate 
awareness of highly-skilled translators including Translations company.//
//
//Translation is essential to communication in the modern, globalised 
economy. It is therefore crucial to combat its commodification. The 
.translations TLD will promote and showcase the profession through 
informational sites that emphasise the value added by professional 
translators to communications. It will also provide an online forum for 
professional translators around the world to communicate and collaborate 
with each other./

In order to prevent a monopolization of the term translations, and as 
the string is a generic string, the request should be denied. Granting 
the proposed exemption would be against the public interest as 
unaffiliated translators would be excluded from use of a string that 
describes the work product of their livelihood.



-- 

Should you have any further questions, please do not hesitate to contact us.

Best regards,

Volker A. Greimann
- legal department -

Key-Systems GmbH
Im Oberen Werk 1
66386 St. Ingbert
Tel.: +49 (0) 6894 - 9396 901
Fax.: +49 (0) 6894 - 9396 851
Email: vgreimann at key-systems.net

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