[Gnso-rpm-sunrise] [Discussion Thread] Sunrise Q9

Sat Jun 8 07:28:32 UTC 2019

Thanks Claudio, for that detailed reaction.

Michael (Mitch), I would suggest that without a further refinement of your proposal that addresses these points (which I note are shared by a number of ST/WG members), the time has come to concede that this proposal does not meet the requisite support level for inclusion as a recommendation.

Brian

Sent from my WIPO mobile

On 8 June 2019 at 02:42:47 CEST, claudio di gangi <ipcdigangi at gmail.com> wrote:
Dear Mitch,

Thanks for your reply.

In terms of this thread, my previous note was mainly to reply to the concept that the harms are falling disproportionately on non-commercial registrants because trademark owners are able, in principle, to secure domains during Sunrise in gTLDs which may not appear directly correlated to the goods or services upon which the trademark is based. I expound on this further below for your consideration.

Sunrise was created for the purpose of helping trademark owners address registration abuse by providing an early window to register their brand as a domain before new gTLDs open up during general availability and the domain is grabbed by a bad faith registrant.

Therein, I believe lies the root of the issue that is causing your concern. As during general availability, both (1) legitimate non-commercial registrants and (2) bad faith cybersquatters are able to freely register domains. So policies aimed at limiting registration abuse may have an indirect effect on all registrants (both commercial and non-commercial), since there is no current way of separating them out during general availability.

Unfortunately, cybersquatting remains a pervasive problem and this the genesis for having the RPMs in the first instance. In other words, one way of looking at the RPMs is that they improve the likelihood that the benefits of new gTLDs will outweigh the harms, allowing in broad terms for their introduction to the DNS.

While the RPMs are helpful and necessary from an IP perspective, new gTLDs present an unique challenge for brand protection because these domains are fresh grounds where, by definition, a preexisting trademark owner does not have their trademark-matching domain name under control.

So while a non-commercial registrant may seek to register a domain name for purely expressive purposes, cybersquatters seek to register domains for their inherent value as a trademark, and in many cases with the express intent of confusing and/or harming consumers through misappropriation of the mark. Registration abuse can generate profit because the cost of the domain registration + web hosting is often significantly less that the revenue that can be generated from the cybersquatting conduct.

In terms of Sunrise, based on our calculations, there are between 105,000 and 140,000 sunrise registrations in new gTLDs. As of recent count,  there are approximately 23,000,000 registrations in new gTLDs. So by going with the upper range estimate, sunrise registrations represent approximately six one thousandths of one percent (0.006) of all current new gTLD registrations. This is an imperfect estimate but I think it's largely in the right ballpark.

However, the costs imposed on trademark owners include: (1) registering domain names defensively, in some cases these registrations cost several thousand dollars for one domain during Sunrise; (2) costs relating to continually monitoring for abusive registrations; (3) enforcement costs to address abusively registered domains, including negotiations, cease and desist letters, UDRP/URS proceedings - which cost many thousands of dollars to draft and file, often just for one domain name; and litigation or court actions under national laws; (6) the damage done to brand value when a branded domain is used for cyber-crime or other fraudulent purposes; (7) the costs that are realized when consumers are confused, have a negative online experience, or worse, defrauded monetarily or even physically harmed when a branded domain is used to instill trust for websites selling dangerous counterfeit products. Trademark owners are not registering these domains defensively to prevent bona fide registrations, but to prevent the harms that are imposed on them and their consumers from registration abuse.

As I think Phil did an excellent job describing in a recent post, non-commercial registrants have alternative ways to find domains that are a near match or close approximation to the identical match of the trademark. These domains can be very similar in appearance, phonetically, or in meaning, to the trademarked term. To provide an example, one way this can be accomplished is by adding a closely related word or phrase to the term, making the term plural, finding another word that has the same meaning, or by spelling the word phonetically in a different manner.

Since sunrise registrations are limited to the identical match of the trademark, registrants are able to register domains that are nearly identical for the same expressive purpose during general availability. Taking it a step further, a non-commercial registrant may even be able to purchase the identical match domain directly from the trademark owner when the trademark owner is willing to sell the domain because they are confident that it will be used legitimately for commerce (in an unrelated class of goods or services) or in a non-commercial manner. Or the trademark owner may let the identical match domain expire when they are unable to maintain it further or when additional TLDs are launched in the future and they need to trim their portfolio, upon which time the identical match domain can be registered by a noncommercial registrant.

I concede these examples are not the same as registering the identical match at the time of launch, but since there is no current way of distinguishing a legitimate registrant from a bad actor at the point of sale, this is the trade-off or compromise that was made to allow more gTLDs in safe and orderly manner, while permitting the maximum amount of legitimate use.

In part, in exchange for this compromise, non-commercial registrants now have over 600 new gTLDs in which they can register domains for non-commercial purposes.  As mentioned above, within those hundreds of new gTLDs (or which may soon be thousands with additional rounds of new gTLDs) only .006% of domains are registered during the sunrise period, leaving 99.004% available outside of sunrise.

And if we were to examine the number of times that a trademark owner registered a domain during sunrise in a new gTLD that appears on some level to be completely unrelated to the goods or services upon which the trademark is based (which is the target of Michael's proposal), I expect that we would find that an even significantly smaller percentage of registrations take place during sunrise.

On the flip end, new gTLDs can impose substantial costs on trademark owners as describe above.

So I don't think the harms are falling disproportionately on non-commercial users. When you look at the harms and benefits of open gTLD registries, I think the harms actually fall quite disproportionately on trademark owners, which I believe is part of the reason why the IPC had concerns with the unrestricted expansion, and why the same expansion was so strongly supported by your fellow members in NCUC.

Also just for the sake of argument, from a practical perspective, I think the various challenges of trying to draw the line on which TLDs are sufficiently unrelated to the brand to prevent a trademark owner from using sunrise are significant due to the number of variables and because it is a subjective undertaking from the outset.

How would one categorize gTLDs like <.online> or <.web> - would the trademark owner need to be the business of online transactions or the Internet to be eligible?

How about <.blackfriday>, <.auctions>, <.blue>, <.software>, <.towns>, <.technology>, <.support>.

I don't understand what the limiting principle is with the proposal that determines which new gTLDs are included in the analysis and which are not.

Also, conceptually, what is the foundation for saying that the use of the gTLD should be limited to a specific class of goods or services in order to trigger sunrise protection, as opposed to having the ability to use the gTLD in relation to one's interpretation of the general meaning of the word in a particular language?

After all, these gTLDs are open for anyone to use for any meaning or purpose whatsoever, yet the proposal is based on opposite grounds, namely that sunrise registrations shouldn't be permitted in certain TLDs for certain trademark owners because the class of goods upon which the trademark is based doesn't appear sufficiently connected to the TLD from someone's subjective perspective. But then when the gTLD is opened up during general availability, there is no such eligibility restriction for bad faith registrants to register the domain.

So the trademark owner would be prevented from using Sunrise, and the cybersquatter would be free to register the domain name during general availability. If a registry wants to limit the use of the gTLD to certain goods or services, they are free to do so. But the proposal limits use of sunrise even when the registry is operating the TLD in a manner that allows any interpretation of the meaning of the gTLD for registration purposes. This is an incongruent outcome.

Moreover, cybersquatters look for every conceivable way to identify which trademarks to register and where, so if the proposal were to be adopted, it would leave trademark owners, in principle, even more vulnerable to cybersquatting. In other words, a cybersquatter obviously has a specific trademark in mind when they register the domain. Logically, they would then look for TLDs where sunrise is restricted according to the proposal, knowing with a higher degree of certainty that they will have the ability to register the domain name in bad faith during landrush.

I very much appreciate that Michael was being innovative in trying to come up with a solution that seeks to thread the needle, and I thank him for doing so.  To the extent it's any consolation, I think the gTLDs you seem to be targeting are the most likely spaces that will not have many sunrise registrations for particular brands.

So the dynamics of the market are already producing an outcome that is most similar to the one you are seeking to accomplish through the proposal, but without the extremely complex policy and bureaucratic implications that would be generated, without the policy limitations for protecting trademarks and consumers, and without the additional advantages that would be bestowed upon those acting in bad faith.

I hope this was helpful feedback and looking forward to continued dialogue with you. Have a nice weekend.

Best regards,
Claudio

On Tue, May 28, 2019 at 8:53 PM Mitch Stoltz <mitch at eff.org<mailto:mitch at eff.org>> wrote:
Hi Claudio,
   According to your numbers, trademark holders have registered between 105,000 and 140,000 domains that were never available to noncommercial users. You and others suggest that most of these registrations were “defensive,” meaning that they were done primarily to prevent anyone else from registering those domain names - not to use them. What’s more, given the little we know about what marks are in the TMCH, a great many of those domain names are either commons words, or words that are associated with a product or service ONLY in particular contexts. This represents an enormous loss to the public that will only grow as new gTLDs roll out.

I take issue with your suggestion that noncommercial users can simply choose a different domain name that hasn’t been taken by trademark holders before public availability. For a noncommercial user, the expressive value of a domain name can be equal to or greater than its value to a commercial user. A noncommercial user acting in good faith should have equal opportunity to register a domain.

Yes, rightsholders can choose to register domains in sunrise based on their internal calculus about where "abuse" is likely to happen, but they are also currently free to act as though good faith registrations by noncommercial users are "abuse." That's a fundamental flaw in the Sunrise mechanism. At a minimum, Michael Karanicolas's proposal to limit sunrise registrations based on the goods and services actually sold by the rightsholder would begin to address this.
   Best,
      Mitch

Mitch Stoltz
Senior Staff Attorney, EFF | 415-436-9333 x142
https://www.eff.org/donate | https://act.eff.org/

On 5/22/19 8:46 PM, claudio di gangi wrote:
hi Mitch,

Sunrise registrations have averaged between 150 and 200 domains per TLD.

I believe there over 700 different new gTLDs where non-commercial users can register domains for non-commercial use.

For the purposes of consensus-building, when one does the math, can you kindly clarify on how this results with harms falling disproportionately on non-commercial registrants and small business registrants?

In terms of the orthogonal domains you mention, registration abuse that targets a brand can easily take place in these zones (and often does take place). Isn’t this a standing justification, along within the fact that only 150 to 200 domains are registered during Sunrise per TLD, for having Sunrise in place in to prevent consumer confusion and harm from taking place?

In terms of the question of scale that your mention, I don’t see a necessary inconsistency that should raise alarm.

One on hand, the brand owner is making an informed choice about where to protect their brand, often because they have been previously targeted and they recognize a pattern, or due to some other implicit connection with the brand that made not be readily apparent to an outside observer on the surface.

But for the vast majority of cases, defensive registrations are based on strategic factors, such as the likelihood of infringement in a particular TLD. I do consider this as resulting in ex-ante harm to non-commercial registrants, as for one reason there are virtually an unlimited number of registrations available in nearly a 1000 gTLDs. To take an extreme case, even in .com with nearly 140 million domains registered, successful domainers continue to profit and non-commercial users have meaningful choices for expression.

Thanks in advance for your thoughts.

Best regards,
Claudio

On Wednesday, May 22, 2019, Mitch Stoltz <mitch at eff.org<mailto:mitch at eff.org>> wrote:
This working group has hit on numerous problems with the Sunrise regime, with harms falling disproportionately on non-commercial and small business registrants. Michael K. has proposed a narrow solution to one of these problems, and I think it deserves serious consideration.

Quite simply, Sunrise as it exists is an expansion of trademark rights. Allowing priority registration without regard to the actual goods and services to which a mark pertains turns a trademark from a source identifier into a global dominion over a word or phrase. We have ample evidence that Sunrise is being abused in just that way. Looking beyond obvious abuses, there is little or no justification for giving trademark holders priority registration in TLDs that are clearly orthogonal to any product or service the mark-holder offers.

At scale, having that priority absolutely harms the free expression rights of others. To use a simple example, Apple is a distinctive trademark in consumer technology but a generic word in many other circumstances. There are any number of individuals and organizations who should be able to express themselves with a domain name containing Apple, in ways that raise no possibility of trademark infringement or cybersquatting. All of these potential users should have equal opportunity to register "apple" in new TLDs that don't raise an association with technology products.

Moreover, we need to be consistent about questions of scale. If sunrise registrations are used often enough to provide benefit to trademark holders, then they are also being used often enough to interfere with the rights of noncommercial users. And if they are not used very much at all, then we should be jettisoning the program as unnecessary. If Sunrise is to continue, Michael's proposal is a straightforward way of making it conform to the actual legal rights it's meant to protect.

Mitch Stoltz
Senior Staff Attorney, EFF | 415-436-9333 x142
https://www.eff.org/donate | https://act.eff.org/

On 5/15/19 8:09 AM, Kathy Kleiman wrote:

Hi Phil,

As a co-chair, I'm a little surprised by the vehemence of the debate. Many of us are lawyers and we're used to talking about important issues in dispassionate ways. I think we should do so here.

As an ordinary member, I participate in these discussions, as you and Brian do, and in that capacity, I note that we have a problem.  I also see the seeds of the solution in your answer below.

In 2009, we foresaw that there might be gaming of the Sunrise period -- people registering trademarks for ordinary words to get priority during Sunrise. We now see it happening. Journalists, reporters and bloggers have done the work for us -- and no one seems surprised by their results.  I list some of the articles we (as a Subteam) collected below. Links in our Sunrise Summary Table under Q9 - https://community.icann.org/download/attachments/102138618/%5BSunrise%20Summary%20Table%5D%20%2816%20April%202019%29.pdf?version=1&modificationDate=1555515624235&api=v2

Nothing in the MK proposal is burdensome, or unusual. It's narrowly-tailored (too narrowly-tailored in my view) to prevent gaming and to use systems already in place.

As you note below, the cost of the vetting is part of the process for many gTLDs and ccTLDs -- whether it is providing residency in Japan or the objective standard for .bank or .insurance or .attorney or .cpa. It's already built into our processes -- and not burdensome -- and easily extended to Sunrise.

We know there is a misuse and even abuse of the Sunrise system. The MK proposal is an easy fix, and one that actually protects and preserves the balance of rights. We are being asked to solve problems -- and this is a big one.

Best, Kathy

Articles in our gathering data (links in Summary Table):

● How one guy games new gTLD sunrise periods
● Fake Trademarks Stealing Generic Domains In New gTLD Sunrises
● The Trademark ClearingHouse Worked So Well One Company Got 24 new gTLD using The Famous Trademark “The"
● How common words like Pizza, Money, and Shopping ended up in  the Trademark Clearinghouse for new TLDs
● The numbers are in! Donuts sunrises typically get 100+ domains, but they also got gamed
● Digging in on Donuts’ Sunrise: Amazon tops the list, gaming, and top registrars
● .Build Registry Using Questionable Swiss Trademark Registration To Grab “Build” Domains In Sunrise
● How Did RetailMeNot Get 849 .Codes Domains In Sunrise Without AnyTrademarks?

On 5/15/2019 10:10 AM, Corwin, Philip wrote:

Kathy:

I presume that these are your personal views, just as the email I posted last week raising serious doubts about Michael’s proposal were clearly labeled as personal. Likewise, what follows is an expression of personal views.

Not to repeat myself, but to the extent there is gaming based on weak marks it should be a focus of discussion when we review requirements for mark recordation in the TMCH. But I have seen no substantial evidence that legitimate trademark holders are seeking to utilize sunrise registrations in gTLDs other than those for which they have a good faith belief that registration is necessary for brand protection. Even where a sunrise registration might arguably be abusive, I do not see that as placing any burden on the speech rights of others who wish to register a domain name that bears some resemblance.

I also described why I believe adoption of this proposal will require a costly bureaucracy to yield reasonably consistent applications of what will always be a subjective standard subject to interpretation. I do not see this as the same as the objective standard for a .bank or .insurance domain (where the cost of vetting is built into the registration fee, and the requirement is satisfied by furnishing a certificate evidencing that the applicant is a regulated institution) or even ccTLDs, where some have objective criteria to demonstrate being domiciled or doing business in a particular jurisdiction. While I don’t believe that Michael has the responsibility to provide a full-blown implementation scheme, I have not yet heard a credible explanation of how adoption of a relationship test will be consistently administered in a cost-effective way.

Finally, and more broadly, we are in the process of considering proposals to recommend to the full WG for inclusion in the Initial Report for public comment. While that does not require a demonstration of consensus at this point, it should require some reasonably strong support within the sub team and, following that, the WG;  and some prospect that the proposal can achieve consensus down the road within the WG (for the Final Report) and Council. Frankly, I don’t see that reasonably strong support for Michael’s proposal within the sub team but rather a sharp divide over whether there is even a problem that requires addressing. And, while I have no crystal ball, I feel reasonably confident that in the end contracted parties will oppose it for administrative and cost reasons, among others, and that BC and IPC members will oppose it as putting yet another burden on sunrise registrations – so I don’t see any prospect of consensus.

Philip S. Corwin

Policy Counsel

VeriSign, Inc.

12061 Bluemont Way<https://maps.google.com/?q=12061+Bluemont+Way+%0D%0A++++++++++++++++Reston,+VA+20190&entry=gmail&source=g>
Reston, VA 20190

703-948-4648/Direct

571-342-7489/Cell

"Luck is the residue of design" -- Branch Rickey

From: Gnso-rpm-sunrise <gnso-rpm-sunrise-bounces at icann.org><mailto:gnso-rpm-sunrise-bounces at icann.org> On Behalf Of Kathy Kleiman
Sent: Wednesday, May 15, 2019 9:04 AM
To: gnso-rpm-sunrise at icann.org<mailto:gnso-rpm-sunrise at icann.org>
Subject: [EXTERNAL] Re: [Gnso-rpm-sunrise] [Discussion Thread] Sunrise Q9

Hi All,

I think the discussion is an important one because it is brings up issues across categories.

a) Michael's proposal addresses a problem we have found in our data-driven analysis. There are gamers out there who are registering trademarks in a certain category of goods and services, and then using them to register an array of domain names in Sunrise having nothing at all to do with the categories of their trademark registration.

We committed at the outset of the RPMs -- in the 2009 era - that we would not be expanding trademark rights. That's exactly what is happening in these situations and registrations.

b) The SDRP is broken - barely used because the Trademark Clearinghouse was supposed to be public, during implementation it was turned private, so challengers cannot get the information they need to challenge. Plus, it's not the job a challenger to police the basic principle of the entire RPM process.

Brian, you have mentioned your "suggested improvements to the SDRP" from 2 years ago several times, but that was 1000s of emails ago, and we worked hard to compile the data and solutions that we are looking at today. Per the rules that we agreed to as Co-Chairs and as a WG, we created a new table, atop extensive data gathering, and things must be reintroduced from prior to our URS break. If you could do so, that would be very timely.

I've suggested changes to the SDRP that would give challengers some chance to use it -- although only for the narrow purpose intended. The SDRP was not intended to solve a broad gaming problem -- because we did not anticipate one. We know know it exists; and a policy/operational fix resolves it.

c) Michael suggests a narrowly tailored solution for a gaming problem that we now know exists. His solution is completely consistent with how registrars, in many of these gTLDs, already handle General Availability (e.g., required proof to register in .BANK). It's not a new process -- just a way to use existing process to avoid gaming and preserve the principles we agreed to in this process.

Best, Kathy

On 5/9/2019 12:04 PM, BECKHAM, Brian wrote:

Michael,

I would personally prefer not to get into a Google search race for some kind of “exceptions to prove the rule” and also because “tattoos” is not a class of marks<https://trademark.eu/list-of-classes-with-explanatory-notes/>, but these articles could be of interest in terms of explaining why they may seek such a defensive sunrise registration:

https://www.pinterest.ch/steelephotograp/mini-cooper-tattoos/

https://metro.co.uk/2011/01/25/andreas-muller-has-mini-tattooed-on-penis-to-win-car-632961/

Also, while MINI may not make motorcycles, their sister company BMW does, so they could well branch out into that product area (including related services).

I have already suggested improvements to the SDRP on several occasions, going back almost 2 years now (those were apparently parked in preference of various data seeking exercises), so would respectfully suggest that others take the baton from here.

As I said, I believe there is a genuine willingness to explore such solutions.

At the same time, it seems unlikely that the current proposal No. 13 is likely to garner consensus, and will defer to the Sub Team Co-Chairs to address that at the level of our present discussions.

Brian

From: Michael Karanicolas <mkaranicolas at gmail.com><mailto:mkaranicolas at gmail.com>
Sent: Thursday, May 9, 2019 5:50 PM
To: BECKHAM, Brian <brian.beckham at wipo.int><mailto:brian.beckham at wipo.int>
Cc: Ariel Liang <ariel.liang at icann.org><mailto:ariel.liang at icann.org>; gnso-rpm-sunrise at icann.org<mailto:gnso-rpm-sunrise at icann.org>
Subject: Re: [Gnso-rpm-sunrise] [Discussion Thread] Sunrise Q9

Interesting, thanks for sharing. I checked whether Mini made motorcycles before I sent my proposal in... I didn't think to check whether they made regular bicycles!

By any chance, were you able to find any examples of the company branching into the tattoo business as well (http://mini.tattoo)?

I'm not sure if this presents a "nuance" in trademark classes. I don't think it's much of a revelation that "bikes" can refer to motorcycles or regular bicycles. All this represents is a product line I was unaware of. And under my proposal, all Mini would have to do would be to include the link you provided when they register the domain under sunrise, and that should be that.

Personally, I don't see how the SDRP challenge process could be retooled to turn it into something that adequately represents the interests of potential future registrants without injecting massive amounts of transparency into the sunrise and TMCH processes... but I would be interested to hear your thoughts as to how this might work.

On Thu, May 9, 2019 at 12:38 PM BECKHAM, Brian <brian.beckham at wipo.int<mailto:brian.beckham at wipo.int>> wrote:

Thanks Ariel,

Copying here, my full email to the Sunrise List from earlier today as it relates to proposal No. 13:

--

Thanks Julie,

Just for fun (as I am aware the example was merely anecdotal), further to our hypothesizing last night, indeed, MINI does have a range of folding bikes:

https://www.bmwblog.com/2018/02/28/new-mini-folding-bike/

This does however illustrate in some ways the nuance in trademark classes and TLD typology that may escape proposal No. 13 in its current form.

As I mentioned on our call, I believe there is a shared willingness to address the issue Michael has raised, but via the SDRP challenge process, and not via claims exclusions.

Brian

--

Brian

From: Gnso-rpm-sunrise <gnso-rpm-sunrise-bounces at icann.org<mailto:gnso-rpm-sunrise-bounces at icann.org>> On Behalf Of Ariel Liang
Sent: Thursday, May 9, 2019 5:36 PM
To: gnso-rpm-sunrise at icann.org<mailto:gnso-rpm-sunrise at icann.org>
Subject: [Gnso-rpm-sunrise] [Discussion Thread] Sunrise Q9

Dear Sunrise Sub Team members,

As announced, this thread is being opened for final mailing list discussions related to Sunrise Agreed Charter Question 9, including Proposal #13.

We ask that you review the Summary Table (as of 16 April 2019) and provide any additional input you may have to the “proposed answers & preliminary recommendations” in relation to the Agreed Charter Question, and consider draft answers to the following questions regarding the individual proposal:

a. Should the Sub Team recommend that the full WG consider including this Individual Proposal in the Initial Report for the solicitation of public comment?

b. In light of the Individual Proposal, are any modifications to the current “tentative answers & preliminary recommendations” needed?

c. Should any additional Sub Team recommendations be made in relation to the agreed Sunrise charter question?

Unless the Sub Team Co-Chairs determine otherwise, this discussion thread will remain open until 23:59 UTC on 22 May 2019. Comments/input provided past the closing date or outside this discussion thread will not be taken into account when compiling the final Sub Team member input.

Summary Table (Pages 36-40)

The draft answers, preliminary recommendations, and links to the relevant individual proposals are in the latest Summary Table (as of 16 April 2019):

https://community.icann.org/download/attachments/102138618/%5BSunrise%20Summary%20Table%5D%20%2816%20April%202019%29.pdf?version=1&modificationDate=1555515624235&api=v2.

Agreed Sunrise Charter Question 9 (Page 36)

The Sub Team just discussed Agreed Charter Question 9 on 08 May 2019, hence the proposed answers are “TBD”. Based on the Sub Team’s discussions, the transcript and notes, staff will provide update.

Q9 In light of the evidence gathered above, should the scope of Sunrise Registrations be limited to the categories of goods and services for which?

Proposed Answer: TBD

Individual Proposal

The Sub Team just discussed the Proposal #13 on 08 May 2019, hence there is no draft answer currently on the Summary Table (as of 16 April 2019). Based on the Sub Team’s discussions, the transcript and notes, staff will provide.

Link to the individual proposal is included below.

Proposal #13: https://community.icann.org/download/attachments/102146375/Proposal%2313.pdf?api=v2

Where to Find All Discussion Threads

Access the Documents wiki page and find the opening messages of the all discussion threads in the table (highlighted in green): https://community.icann.org/x/_oIWBg

Best Regards,

Mary, Julie, Ariel

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