[gnso-rpm-wg] FOR INFORMATION: Letter from trademark scholars and information on Deloitte Ancillary Services

J. Scott Evans jsevans at adobe.com
Tue Mar 28 20:43:26 UTC 2017


With all due respect Rebecca, any person or entity that wants a domain can and should run a trademark search. They don’t need the Clearinghouse for that.


J. Scott Evans
408.536.5336 (tel)
345 Park Avenue, Mail Stop W11-544
Director, Associate General Counsel
408.709.6162 (cell)
San Jose, CA, 95110, USA
Adobe. Make It an Experience.
jsevans at adobe.com
www.adobe.com
 
 
 

On 3/28/17, 12:52 PM, "gnso-rpm-wg-bounces at icann.org on behalf of Marie Pattullo" <gnso-rpm-wg-bounces at icann.org on behalf of marie.pattullo at aim.be> wrote:

    Thanks Rebecca. 
    If anyone wants to know what TMs exist, search a TM Registry. They're public. Claims Notices in the TMCH context tell you only that a TM owner has recorded that name - not that they are going to take action against you. They're not the same thing. 
    Marie
    
    Sent from my iPhone, sorry for typos 
    
    > On 28 Mar 2017, at 21:20, Rebecca Tushnet <Rebecca.Tushnet at law.georgetown.edu> wrote:
    > 
    > I think the value of transparency has been articulated here several
    > times, whether or not you agree: legitimate market entrants--who, not
    > for nothing, are also likely to be trademark owners--may want to know
    > what they can do.  People concerned with the integrity of the register
    > want to know whether (as current data seem to indicate) many of the
    > existing registrants and many existing claims notices are asserting
    > control over domain names whose value is distinct from trademark value
    > attributable to the registrant.  Those are the usual values of
    > transparency: knowing what's going on so one can order one's own
    > behavior accordingly, and/or advocate for change where change is
    > desirable.
    > 
    > On the other side, I find persuasive the argument that cybersquatters
    > generally don't need to consult any records to figure out what domains
    > they want and thus I find it hard to identify the harm to be avoided.
    > We are talking here about the marginal impact of transparency in the
    > TMCH added to the public nature of registration (searchable online in
    > many large nations) and the public nature of trademark fame (e.g.,
    > Twentieth Century Fox, to take an example that's been discussed).  For
    > me, transparency in the TMCH would provide a lot of TMCH-relevant
    > information but has only a marginal effect on information about
    > trademark values generally, arguing in favor of transparency.
    > Rebecca Tushnet
    > Georgetown Law
    > 703 593 6759
    > 
    > 
    >> On Tue, Mar 28, 2017 at 3:07 PM, Marie Pattullo <marie.pattullo at aim.be> wrote:
    >> Can we look at what we are trying to achieve maybe? What greater good would an open database give balanced against the harm TM owners would suffer?
    >> 
    >> No one wants to promote bad players for a theory. What is the reality? We all want a clean space. We all want legal commercial growth. And we all want the common good. No?
    >> 
    >> Marie
    >> 
    >> Sent from my iPhone, sorry for typos
    >> 
    >>> On 28 Mar 2017, at 20:38, Michael Karanicolas <michael at law-democracy.org> wrote:
    >>> 
    >>> Hi Greg,
    >>> 
    >>> If I had a perfect solution to prevent cybersquatting in my pocket I
    >>> probably would have led with it :)
    >>> 
    >>> That said, my aim in drafting that was to try and help frame the
    >>> discussion, rather than to try and close it. Look, my expertise is
    >>> more on the transparency side than on the trademark side. But on the
    >>> transparency side, we deal with potential harms all the time - be they
    >>> for information involving national security, personal privacy - or
    >>> legitimate commercial interests like trademark protection. And
    >>> generally, we seek to find an avenue forward which provides adequate
    >>> protection for these interests, while respecting the overarching
    >>> interest in openness. This calculus shouldn't mean that openness is
    >>> abandoned whenever a potential for harm is encountered. Indeed, if
    >>> that were the case almost no information would end up being put out
    >>> there. Rather, it means assessing the specific harms that would flow
    >>> directly from the specific disclosures, weighing them against the
    >>> public interest in disclosure, and seeking ways to work around those
    >>> harms which also provide for maximum openness.
    >>> 
    >>> So, while I don't have a readymade solution to present, I do think we
    >>> need to work together to find one. Reverting to secrecy is just not
    >>> consistent with ICANN's broader mission, given that the entire model
    >>> is based on public oversight and accountability.
    >>> 
    >>> Looking forward to engaging on this further.
    >>> 
    >>> Michael
    >>> 
    >>> P.S. I'm not sure why it's at all relevant who actually drafted the
    >>> text of the EFF letter? As someone who's been involved in many similar
    >>> efforts, they can be done fully collaboratively, or with one or two of
    >>> the signatories taking the lead. Either way though, all of the names
    >>> attached to it have approved and endorsed it. These are very senior
    >>> and respected experts - they don't just throw their names on any
    >>> document that's sent their way. If they signed the letter it means
    >>> they support it - what does it matter who held the pen?
    >>> 
    >>> 
    >>> 
    >>>> On Tue, Mar 28, 2017 at 2:30 PM, Greg Shatan <gregshatanipc at gmail.com> wrote:
    >>>> Michael,
    >>>> 
    >>>> Do you have any solutions for the issues and concerns that have been
    >>>> mitigated by having the database be closed?
    >>>> 
    >>>> Thanks!
    >>>> 
    >>>> Greg
    >>>> 
    >>>> Greg Shatan
    >>>> C: 917-816-6428
    >>>> S: gsshatan
    >>>> Phone-to-Skype: 646-845-9428
    >>>> gregshatanipc at gmail.com
    >>>> 
    >>>> 
    >>>> On Tue, Mar 28, 2017 at 12:21 PM, Michael Karanicolas
    >>>> <michael at law-democracy.org> wrote:
    >>>>> 
    >>>>> Hi all,
    >>>>> 
    >>>>> Just building on the discussion around transparency, after hearing the
    >>>>> conversation at ICANN 58 I drafted my own short note setting out my
    >>>>> thoughts on the issue, which I'm attaching here.
    >>>>> 
    >>>>> I want to be mindful of the conversation on inputs which is ongoing
    >>>>> now - so hopefully it isn't out of place or inappropriate to submit my
    >>>>> thoughts via this method.
    >>>>> 
    >>>>> I very much look forward to further discussions on this issue.
    >>>>> 
    >>>>> Best wishes,
    >>>>> 
    >>>>> Michael Karanicolas
    >>>>> 
    >>>>> On Tue, Mar 28, 2017 at 11:54 AM, Jeff Neuman <jeff.neuman at comlaude.com>
    >>>>> wrote:
    >>>>>> Thanks Mary.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Co-Chairs,
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Can I assume that with respect to the EFF letter, the only items we
    >>>>>> would be
    >>>>>> discussing from that letter at this point are their comments with
    >>>>>> respect to
    >>>>>> design marks and the transparency of the TMCH database?
    >>>>>> 
    >>>>>> I am not saying the other comments are not important, but with respect
    >>>>>> to
    >>>>>> this Working Group at this time, we are not yet addressing those other
    >>>>>> issues.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> I would strongly urge that we not engage yet in the other discussion
    >>>>>> around
    >>>>>> the other comments at this point (namely, trademark rights in general),
    >>>>>> as I
    >>>>>> think that could lead us down a large rabbit hole and considerably slow
    >>>>>> down
    >>>>>> out work.
    >>>>>> 
    >>>>>> 
    >>>>>> Thanks.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Jeffrey J. Neuman
    >>>>>> 
    >>>>>> Senior Vice President |Valideus USA | Com Laude USA
    >>>>>> 
    >>>>>> 1751 Pinnacle Drive, Suite 600
    >>>>>> 
    >>>>>> Mclean, VA 22102, United States
    >>>>>> 
    >>>>>> E: jeff.neuman at valideus.com or jeff.neuman at comlaude.com
    >>>>>> 
    >>>>>> T: +1.703.635.7514
    >>>>>> 
    >>>>>> M: +1.202.549.5079
    >>>>>> 
    >>>>>> @Jintlaw
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> From: gnso-rpm-wg-bounces at icann.org
    >>>>>> [mailto:gnso-rpm-wg-bounces at icann.org]
    >>>>>> On Behalf Of Mary Wong
    >>>>>> Sent: Tuesday, March 28, 2017 6:15 AM
    >>>>>> To: gnso-rpm-wg at icann.org
    >>>>>> Subject: [gnso-rpm-wg] FOR INFORMATION: Letter from trademark scholars
    >>>>>> and
    >>>>>> information on Deloitte Ancillary Services
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Dear all,
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> During the ICANN58 Working Group sessions in Copenhagen, the following
    >>>>>> two
    >>>>>> matters came up for which staff is now following up with the requested
    >>>>>> document (for #1) and information (for #2).
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Item #1: Letter of 10 March 2017 from some trademark scholars and
    >>>>>> practitioners to our Working Group co-chairs expressing concerns with
    >>>>>> certain aspects of the TMCH:
    >>>>>> 
    >>>>>> https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.eff.org%2Ffiles%2F2017%2F03%2F10%2Ftm_scholars_letter_to_icann_final.pdf&data=02%7C01%7C%7C01dfa19d34ed48f5349408d47613f6b9%7Cfa7b1b5a7b34438794aed2c178decee1%7C0%7C1%7C636263275517185713&sdata=cyzUw49X7IgjS4ZoM%2BiQ6uBUefv68SHEUxIe6pohDo0%3D&reserved=0.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Item #2: Question regarding the Ancillary Services that Deloitte is
    >>>>>> permitted to provide under its Validation Agreement with ICANN, subject
    >>>>>> to
    >>>>>> ICANN’s authorization.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Currently, two Ancillary Services have been approved by ICANN:
    >>>>>> 
    >>>>>> 1.       Extended Claims Services
    >>>>>> 
    >>>>>> The extended claims services provide the Trademark Holder or Trademark
    >>>>>> Agent, as applicable, with an electronic notification when a domain name
    >>>>>> registered in an Eligible TLD matches one or more of such party’s
    >>>>>> recorded
    >>>>>> labels with the TMCH.  The extended claims services does not include a
    >>>>>> domain name pre-registration notification (i.e. a notification to the
    >>>>>> potential registrant of a domain name that the domain name such
    >>>>>> registrant
    >>>>>> intends to register matches a label recorded with the Trademark
    >>>>>> Clearinghouse).
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> 2.       Audit Report
    >>>>>> 
    >>>>>> Deloitte may offer an audit report service for Trademark Holders and
    >>>>>> Trademark Agents with active Trademark Records recorded in the Trademark
    >>>>>> Clearinghouse.  Such audit reports shall consist primarily of a listing
    >>>>>> of
    >>>>>> matches between their recorded labels within the Trademark Clearinghouse
    >>>>>> and
    >>>>>> domain names registered in an Eligible TLD.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> FYI, Deloitte’s contract with ICANN is for an initial period expiring on
    >>>>>> the
    >>>>>> fifth anniversary of ICANN’s entry into a Registry Agreement under the
    >>>>>> New
    >>>>>> gTLD Program, with consecutive one-year renewals thereafter. Although
    >>>>>> Deloitte currently serves as the sole TMCH validator, ICANN may appoint
    >>>>>> additional validators once ten Qualified Sunrise Periods have been
    >>>>>> completed
    >>>>>> under the New gTLD Program.
    >>>>>> 
    >>>>>> 
    >>>>>> 
    >>>>>> Thanks and cheers
    >>>>>> 
    >>>>>> Mary
    >>>>>> 
    >>>>>> 
    >>>>>> _______________________________________________
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