[GNSO-RPM-WG] The 7% Solution for URS Rationale [was: ACTIONS & NOTES: RPM PDP WG 08 August 2018]
Paul Tattersfield
gpmgroup at gmail.com
Mon Feb 10 20:41:26 UTC 2020
How about "unacceptable number"?
On Mon, Feb 10, 2020 at 8:25 PM <cking at modernip.com> wrote:
> I prefer “noteworthy”.
>
>
>
>
>
> *Cyntia King*
>
> O: +1 816.633.7647
>
> C: +1 818.209.6088
>
> [image: Email Logo5]
>
>
>
> *From:* Griffin Barnett <Griffin at Winterfeldt.law>
> *Sent:* Monday, February 10, 2020 2:22 PM
> *To:* Zak Muscovitch <zak at muscovitch.com>; cking at modernip.com; 'Mitch
> Stoltz' <mitch at eff.org>; gnso-rpm-wg at icann.org
> *Subject:* RE: [GNSO-RPM-WG] The 7% Solution for URS Rationale [was:
> ACTIONS & NOTES: RPM PDP WG 08 August 2018]
>
>
>
> I don’t think we can call even 13% a “significant” number, but I support
> in principle the move toward a general description rather than going back
> and forth now about whether the number is 7% or 13% or somewhere in
> between. Perhaps “non-trivial,” “meaningful,” etc. rather than
> significant?
>
>
>
> *From:* GNSO-RPM-WG [mailto:gnso-rpm-wg-bounces at icann.org
> <gnso-rpm-wg-bounces at icann.org>] *On Behalf Of *Zak Muscovitch
> *Sent:* Monday, February 10, 2020 3:17 PM
> *To:* cking at modernip.com; 'Mitch Stoltz' <mitch at eff.org>;
> gnso-rpm-wg at icann.org
> *Subject:* Re: [GNSO-RPM-WG] The 7% Solution for URS Rationale [was:
> ACTIONS & NOTES: RPM PDP WG 08 August 2018]
>
>
>
> How about we say “a significant number”? Whether it is 7% or 13% or
> whatever, it was spotted as a significant issue and we should identify it
> as such, without overstating it as for example, “a substantial number”.
>
> Zak
>
>
>
>
>
> Muscovitch Law P.C.
>
> zak at muscovitch.com
>
> 1-866-654-7129
>
> 416-924-5084
>
> http://www.trademarks-canada.com/
>
> https://www.muscovitch.com/
>
> https://dnattorney.com/
>
>
>
>
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *
> cking at modernip.com
> *Sent:* February-10-20 3:13 PM
> *To:* 'Mitch Stoltz' <mitch at eff.org>; gnso-rpm-wg at icann.org
> *Subject:* Re: [GNSO-RPM-WG] The 7% Solution for URS Rationale [was:
> ACTIONS & NOTES: RPM PDP WG 08 August 2018]
>
>
>
> Are we really going to quibble over 13% versus 7% in our proposal?
>
>
>
> Please let’s not rehash the rationale of decisions for 6% of URS cases.
>
> Let’s make the recommendation without a %, which isn’t needed for the
> proposal to stand.
>
>
>
>
>
> *Cyntia King*
>
> O: +1 816.633.7647
>
> C: +1 818.209.6088
>
> [image: Email Logo5]
>
>
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *Mitch
> Stoltz
> *Sent:* Monday, February 10, 2020 2:05 PM
> *To:* gnso-rpm-wg at icann.org
> *Subject:* Re: [GNSO-RPM-WG] The 7% Solution for URS Rationale [was:
> ACTIONS & NOTES: RPM PDP WG 08 August 2018]
>
>
>
> It would be inappropriate to presume cybersquatting from the use of a
> "well known" brand name alone. There are any number of legitimate reasons
> for registering <brand>.<new gTLD>. And we have no working standard for
> what "well known" means, especially internationally. Cybersquatting
> requires intent, and if some percentage of URS proceedings are presuming
> intent based on no facts but the domain name itself, that's highly relevant
> information that should not be buried here.
>
> Mitch Stoltz
>
> Senior Staff Attorney, EFF | 415-436-9333 x142
>
> https://www.eff.org/donate | https://act.eff.org/
>
> On 2/10/20 11:53 AM, cking at modernip.com wrote:
>
> Agree Georges.
>
> We don’t need a percent figure. We can simply observe that ICANN needs
> specific info for data collection/oversight & outline those required fields.
>
>
>
>
>
> *Cyntia King*
>
> O: +1 816.633.7647
>
> C: +1 818.209.6088
>
> [image: Email Logo5]
>
>
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org>
> <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *Nahitchevansky, Georges
> *Sent:* Monday, February 10, 2020 1:37 PM
> *To:* Greg Shatan <gregshatanipc at gmail.com> <gregshatanipc at gmail.com>;
> gnso-rpm-wg <gnso-rpm-wg at icann.org> <gnso-rpm-wg at icann.org>
> *Subject:* Re: [GNSO-RPM-WG] The 7% Solution for URS Rationale [was:
> ACTIONS & NOTES: RPM PDP WG 08 August 2018]
>
>
>
> Thank you Greg. I was looking for that email and went back through what I
> had reviewed. The bottom line is that of the 103 cases that had been
> marked as having no rational, there were 45 that included enough to know
> what the case had been about and the rationale. That meant that 7% just
> reiterated the standard and ruled in favor of a party with nothing to
> deduce the rationale. Of those 7%, though, a number of cases involved
> domain names that were based on a well-known trademark and it would not
> take much to understand that a domain name that was simply BRAND + gTLD
> likely involved cybersquatting. So in my view while there are some cases
> that had no rationale, I do not believe we are talking overall about cases
> that involved rulings with no explanations regarding domain names that
> primarily involved a generic word with a gTLD. Most of the 58 cases (or
> 103) that arguably had no specific rationale involved domain names that
> related to trademarks that are known, which again suggests something about
> the ruling. Put another way, there is a conceptual difference between a
> case that involves a domain name based on a well-known brand such as
> <cocacola.beverage> and one that involves a generic word such as
> <fashion.clothes>. If the cases that have no articulated rationale
> primarily involved the latter type of domains, I would be much more
> concerned. But if they mostly relate to known brands, I’m not sure that
> this suggests that there were errors committed by the panelist. Also, I do
> not believe that the 58 decisions at issue actually resulted in any
> appeals, which does suggest that perhaps the decisions were not unfounded.
>
>
>
> In any event, rather than go back and forth about whether we are talking
> about 7% or 13% of cases without a stated rationale, I think the solution
> is to just say that there were several cases that had no clearly stated
> rationale without getting into percentages. After all, we are more or less
> in agreement that close to 90% of the cases had articulated rationale and
> that there should be some tweak to address the minimum of what a URS
> decision should provide.
>
>
>
> Georges Nahitchevansky
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *Greg
> Shatan
> *Sent:* Monday, February 10, 2020 1:42 PM
> *To:* gnso-rpm-wg <gnso-rpm-wg at icann.org>
> *Subject:* [GNSO-RPM-WG] The 7% Solution for URS Rationale [was: ACTIONS
> & NOTES: RPM PDP WG 08 August 2018]
>
>
>
>
>
>
> All,
>
>
>
> Here is the Georges Nahitchevansky email that was referred to in last
> week's discussion of the percentage of URS decisions that lacked a
> rationale. There was a subsequent discussion, so I recommend going back to
> the list if you want to see the follow-up.
>
>
>
> Greg
>
>
>
> ---------- Forwarded message ---------
> From: *Nahitchevansky, Georges* <ghn at kilpatricktownsend.com>
> Date: Thu, Aug 9, 2018 at 3:27 PM
> Subject: Re: [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
> To: Tushnet, Rebecca <rtushnet at law.harvard.edu>, Ariel Liang <
> ariel.liang at icann.org>, gnso-rpm-wg at icann.org <gnso-rpm-wg at icann.org>
>
>
>
> Rebecca:
>
>
>
> I do not disagree with the notion that we should discuss what a decision
> should contain, but I don’t think we have a consensus as to what that
> should be in the URS context (given the pricing of URS proceedings).
> Moreover, a review of the URS cases makes your 13% number and comment of
> “significant due process and implementation issues” point questionable. At
> NAF for example, there were 827 cases that that your research assistants
> reviewed. I found a total of about 103 that your team flagged as having no
> articulated decisions. I would agree that in 58 cases the decisions lacked
> details, but in 45 cases there were details that sufficiently let you know
> what the case was about and the basis of the resolution. I am sure we can
> argue about these 45 cases and whether they should say more, but ultimately
> we are really only talking about 58 cases that actually do not have any
> specific details and just provide the standard and a resolution (although I
> note that most of these cases involve domain names based on fairly well
> known marks such as NISSAN, DATSUN, TEXACO, BLOOMBERG, BNP PARIBAS etc., so
> you pretty much know what trademark was involved.). In all, we are really
> talking about 7% of the cases that have no details, which is not
> significant.
>
>
>
> Again, we can discuss what the decisions should provide, but I don’t think
> we ought to be qualifying this as a “significant” issue per se (as 93% of
> them have details). There are other issues being considered in the URS
> review that have better percentage numbers as an issue that are viewed as
> not being significant per se. The point is that the URS looks to be working
> appropriately and there are probably some tweaks and refinements needed but
> this is not sky is falling issue.
>
>
>
>
>
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>
>
> *From:* gnso-rpm-wg <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *Tushnet,
> Rebecca
> *Sent:* Thursday, August 9, 2018 1:22 PM
> *To:* Ariel Liang <ariel.liang at icann.org>; gnso-rpm-wg at icann.org
> *Subject:* Re: [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
>
>
>
> My apologies for missing the meeting. Comment on the big document:
>
> This is currently only covered under Defenses but I would put it for
> discussion/recommendations under 2. Examiners’ Guide/3. Other Issues
> because it goes beyond defenses: Decisions should contain basic
> information, including what the trademark is, what the finding of abuse is
> and/or what findings are on any defenses—13% of decisions did not, and this
> raises significant due process and implementation issues.
> ------------------------------
>
> *From:* gnso-rpm-wg <gnso-rpm-wg-bounces at icann.org> on behalf of Ariel
> Liang <ariel.liang at icann.org>
> *Sent:* Wednesday, August 8, 2018 3:56:54 PM
> *To:* gnso-rpm-wg at icann.org
> *Subject:* [gnso-rpm-wg] ACTIONS & NOTES: RPM PDP WG 08 August 2018
>
>
>
> Dear All,
>
>
>
> Please see below the action items and notes captured by staff from the RPM
> PDP WG call held on 08 August 2018 (17:00-18:30 UTC). Staff have posted to
> the wiki space the action items and notes. *Please note that these will
> be high-level notes and are not meant as a substitute for the recording.* The
> recording, AC chat, and attendance records are posted on the wiki at:
> https://community.icann.org/x/uwNpBQ
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_x_uwNpBQ&d=DwMGaQ&c=WO-RGvefibhHBZq3fL85hQ&r=E-M4OQvQBo8UWqE1LwEiDR3PcWlfM0I-0jiI1c4ous0&m=CypdnKxuYaImNW0ttGO-h5FbHiLxMQ2kzt4bzMuwnHU&s=gcgRms-bmezGQQmwXCqLMQXOdSv3gly_0bWYNSuRlY8&e=>
>
>
>
> Best Regards,
>
> Ariel
>
>
>
> Ariel Xinyue Liang
>
> GNSO Policy Support Specialist
>
> Internet Corporation for Assigned Names and Numbers (ICANN)
>
>
>
> *==*
>
> *ACTION ITEMS:*
>
> - Brian Beckham to send to the WG a WIPO FAQ with regard to “Doe
> Complaint”.
> - Renee Fossen to provide more information on HSTS-preloaded domain
> suspension issues in the written responses.
> - Staff to recirculate the Super Consolidated URS Topics Table document
> - WG members to provide substantive comment and raise anything they
> believe is missing on the WG mailing list by *COB Tue, 14 Aug*.
> Co-Chairs will then discuss among themselves to determine further
> actions/process.
> - WG members to finish reviewing the rest of the Super Consolidated
> URS Topics Table document, including page 24-35, during next week’s call.
> Later period to discuss larger policy issues.
>
>
>
> *NOTES:*
>
> *Review Agenda/Statements of Interest*
>
> - George Kirikos has become a member of the At-Large Community:
> https://community.icann.org/display/gnsosoi/George+Kirikos+SOI
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_display_gnsosoi_George-2BKirikos-2BSOI&d=DwMGaQ&c=WO-RGvefibhHBZq3fL85hQ&r=E-M4OQvQBo8UWqE1LwEiDR3PcWlfM0I-0jiI1c4ous0&m=CypdnKxuYaImNW0ttGO-h5FbHiLxMQ2kzt4bzMuwnHU&s=8-YfNNseZ7YW77BHJT9ciEr_I08JQcazWKn1rxNI900&e=>
>
>
>
> *General Comment on the Super Consolidated URS Topics Table Document *
>
> - The topics in the table were developed by the WG members and
> deliberated on by the WG & URS Sub Teams. Each Sub Team then did very
> substantial work on data collection and reviewing what came back. While the
> actual Sub Team recommendations and suggestions captured in this document
> are what is intended the WG should discuss - to see if it wishes to develop
> policy or operational recommendations - discussion over what should be on
> the actual list of topics should not be reopened unless the WG agrees to do
> so. We encourage all WG members to review all the previous reports from
> each Sub Team, and all the documents they worked on. They are linked in
> this Super Consolidated document (page 2).
> - The Super Consolidated document is a summary of findings and
> suggestions by the Sub Teams. The Table does not mean to limit/restrict
> recommendations from the WG members. If there is any issue overlapping with
> UDRP, can possibly be carried over to the phase II of the PDP.
> - Is it possible to add additional topics to the Super Consolidated
> Table? One WG member said that access to the Courts, for example, is a
> topic he raised, which isn't in the table. Statute of Limitations, whether
> URS should apply to legacy gTLDs as a consensus policy, are just a few of
> the topics not in the table. He brought it up in November 2017 (see:
> https://mm.icann.org/pipermail/gnso-rpm-wg/2017-November/002585.html )
> and it was reflected in a later document. That's a critical issue for
> registrants. if they don't have access to the courts to challenge a URS
> decision, then it's a huge denial of their rights.
> - While the chart is not meant to foreclose further discussion, it is
> a good faith attempt at capturing the work of the sub teams. The purpose
> of today's, and likely the next few, calls was to make sure this was an
> accurate and comprehensive reflection of our discussions so far. That
> said, WG members should bear in mind that we are seeking consensus, so
> items which are unlikely to achieve that may not be appropriate to reflect
> as a recommendation, but could be included in public comments on the
> Initial Report. Also, before adding items to this chart, we will want to
> work with staff to see whether such topics was previously discussed, and if
> so, the level of agreement/consensus. In other words, it is not necessary
> final, but is equally an opportunity to reintroduce topics which have been
> discussed, but for which consensus is/was not possible.
> - Could we create a list of "missing issues" -- a list of issues
> raised in this call (and calls to follow); we can evaluate the nature and
> weight of these ideas later.
> - Regarding the Action Items highlighted in column 3 of the table,
> Providers ST will do a first pass of the responses from the Providers to
> the follow-up questions, and then discuss the issues that they identified
> and proposed suggestions with the full WG.
>
>
>
> *Limited filing period (page 3) *
>
> - One WG member believes that there should be limitation for filing
> period to bring URS Complaints, so the domain registered many years ago
> would not be subject to unfair treatment. He said a registrant who owns a
> domain for 20 years, for example, shouldn't have to be concerned about a
> policy that can take their domain down with very short time period to
> respond.
> - Other WG members said this was discussed, and did not achieve
> agreement. That would only even be an option if the trademark
> pre-dated. This is unlikely to be a situation in practice where a URS was
> brought because it would probably not be a "slam dunk" case after 20 years
> unless there had been a change of circumstances.
> - On the issue of delay and laches - as reported by the Docs Sub Team,
> the data did not provide any basis for which a policy recommendation should
> be made. The Providers and Practitioners Sub Teams also did not uncover any
> specific issues that came to either practitioners' or providers' attention.
>
>
>
> *Administrative Review (page 3-4) *
>
> - One WG member asked whether ICANN should bring Providers into
> contractual relationship in order to enforce the URS Rules & Procedures.
> Another member said it probably need to be ICANN’s legal department to
> enforce the rules & procedure.
> - URS Providers have MoU with ICANN. Whether it is ICANN’s compliance
> department or legal department to enforce the rules & procedures, it should
> not be controversial that Providers must abide by them.
> - An MOU could be legally enforceable, depending on the circumstances.
>
>
>
> *500-word Complaint limit (page 4-5)*
>
> · On 500-word Complaint Limit - Practitioners' survey results were
> split (out of 12, 5 agree it's sufficient, 4 disagree); results included
> feedback from some that the word limit was too low: "arbitrary and often
> insufficient" and "should be slightly increased".
>
> · One member said he understands and generally agrees with the
> decision not to suggest an expansion of the word limit, he wonders if there
> aren't situations (multi- domain challenges, etc.) where a Complainant or
> Respondent might be given the opportunity to request an expansion. This
> point can be captured for decisional phase.
>
> · Another member suggested that perhaps providers can provide
> stats on the average word length of complaints, to see how close to the 500
> words they are at present. (i.e. a table of distributions, e.g. 10% under
> 200 words, 20% between 201 and 300, etc.)
>
>
>
> *Amending the Complaint in light of GDPR/Temp Spec (page 5-6)*
>
> - One member believes that 2-3 days might not be a good rule (e.g.
> weekends, time to research, etc.). Maybe 5 business days.
> - WIPO’s approach to “doe complaints” has been very helpful and
> provides some comfort that the lack of true registrant/registrant
> organization data masked due to GDPR will not result in a deficient
> complaint for an omitted respondent.
> - *ACTION ITEM: *Brian Beckham to send to the WG a WIPO FAQ with
> regard to “Doe Complaint”.
> - Forum is asking for amendment of the complaint in UDRP - under the
> rules that's not allowed in URS.
>
>
>
> *SMD Files (page 6-7)*
>
> - SMD files are used for limited purpose of demonstrating the use.
> - Recollection is that SMD files would be passed to the Examiners and
> relay the critical information related to the TM registration. That's why
> some people are surprised by the limited info SMD files would provide.
> - The SMD files contain some basic human-readable information, with
> the rest of the information coded. For example, the trademark itself is
> human-readable but the applicable Nice classification is coded. A SMD file
> is used by registries/registrars for validation, and as Greg noted, to
> demonstrate use. From the TMCH provider:
> http://www.trademark-clearinghouse.com/help/faq/which-information-does-smd-file-contain
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.trademark-2Dclearinghouse.com_help_faq_which-2Dinformation-2Ddoes-2Dsmd-2Dfile-2Dcontain&d=DwMGaQ&c=WO-RGvefibhHBZq3fL85hQ&r=E-M4OQvQBo8UWqE1LwEiDR3PcWlfM0I-0jiI1c4ous0&m=CypdnKxuYaImNW0ttGO-h5FbHiLxMQ2kzt4bzMuwnHU&s=v3df_qE8Dw_U7YY7_IfhIMgGSxt-a44LbNskorrbTIg&e=>
>
> - If the intent of the STI was that the SMD file would be a file
> summary, that got lost somewhere along the way, way before the SMD file was
> designed by the TMCH providers.
> - Rules 3(b)(v) Specify the trademark(s) or service mark(s) on which
> the complaint is based and the goods or services with which the mark is
> used including evidence of use –which can be a declaration and a specimen
> of current use in commerce - submitted directly or by including a relevant
> SMD (Signed Mark Data) from the Trademark Clearinghouse
> - It might be useful to look at the spec that they relied on. But the
> real question is how should the examiner get the relevant data about the
> Complainant’s mark. The SMD file is probably not the answer, if it was ever
> intended to be.
> - the Examiner is not required to second-guess the SMD file. Its
> existence is sufficient that the mark has had use validated by the TMCH.
>
>
>
> *Other Topics (page 7-8)*
>
> - These are policy proposals can be brought up when WG members are
> proposing changes to the URS policy itself. Charter asks us to address the
> question whether the URS should become a consensus policy applicable to
> legacy domains. Charter is not specific regarding whether such discussion
> should occur in phase I or phase II. This feedback illustrates that the ST
> didn't get to propose policy changes, it is for the WG to discuss and
> propose changes.
> - when we reference the STI and IRT reports, we need to keep in mind
> they only had about 1-2 months to complete their work and produce a report;
> they were not standard PDP working groups and had limited charters and
> mandates, which were set by the Board
> - This is feedback from one Provider, who may want to grow their
> business. Practitioners survey are from Complaints' side. Need to have a
> balanced solution when considering the input.
> - There were plenty of practitioners that represent registrants in the
> Subgroup, although their experience was largely with the UDRP.
>
>
>
> *Duration of response period (Page 11)*
>
> - One member believes that if the URS continues in its current form,
> it would affect valuable domain names. The ones the registrants that do
> want to defend them, 14 days are not sufficient. 20 days may be more
> appropriate. It should be based on the age of the domain name. If a domain
> is 3 months, it will have a shorter period to respond. If you own a domain
> name for 5-10 years, response period would be longer so less urgency.
> - Several other WG members disagree. The URS is supposed to be an
> expedited proceeding so increasing the length of time of a streamlined
> proceeding defeats the purpose. At most, there could be an additional 3 or
> 4 days extension period for cause. The point is that there are enough
> circumstances that give rise to the URS 'quick response' that we should NOT
> make assumptions into policy. It is an assumption that an "aged" domain
> would not require a fast response. In Mexico, we have not been able to file
> a domain name case due to Courts ignorance about the subject and also,
> because it could take years to be solved. We're spinning out fo control -
> extending the time to respond to URS cases just because a domain
> registration is not new defeats the purpose of fast action to take down an
> infringing domain once it's discovered. The URS is meant to address clear
> and convincing cases of infringement. A person registers a domain name for
> less than $50 and brand owner find out about at some point and then files
> an injunction in court for tens of thousands of dollars. Where is the
> balance.
>
>
>
> *Examiners Guide (page 13) *
>
> - The WIPO guidance for examiners took 1500 hours to develop.
> - The WIPO guidance is relevant to the URS, the elements are shown are
> the same and the differences include the burden of proof, word limit, etc.
> A lot of WIPO guidance goes to the shade of grey issues. URS is for clear
> black/white cases, so if there is a URS guidance it would likely be
> abbreviated.
>
>
>
> *Duration of Suspension Period & Review of Implementation (page 21-23)*
>
> - One WG member suggests to find out how much cost for registries &
> registrars to comply with the URS rules and procedures. Need to get
> data/feedback from the registries/registrars.
> - Other WG members are not sure "cost of implementation of URS" for
> Registries/Registrars is relevant to effectiveness of URS. We don't need to
> do a cost/benefit analysis (the costs & benefits aren't ICANN's), the
> providers, registrars, registries need to be asked if they are overburdened
> by the costs of compliance.
> - There is an action item to contact the registries/registrars about
> these issues. Timing TBD due to Sunrise & Claims survey launch.
>
>
>
> *Other topics (page 23-24)*
>
> - One WG member thinks the HSTS issue is not difficult to fix. The
> Providers need to improve their technical applicability to resolve the
> issue. Renee Fossen from Forum disagrees.
> - *ACTION ITEM*: Renee Fossen to provide more information on
> HSTS-preloaded domain suspension issues in the written responses.
>
>
>
>
>
> *NEXT STEPS *
>
> - *ACTION ITEM*: Staff to recirculate the Super Consolidated URS
> Topics Table document and ask all WG members to provide substantive comment
> and raise anything they believe is missing on the WG mailing list by COB
> Tue, 14 Aug. Co-Chairs will then discuss among themselves to determine
> further actions/process.
> - *ACTION ITEM*: WG to finish reviewing the rest of the Super
> Consolidated URS Topics Table document, including page 24-35. Later period
> to discuss larger policy issues.
>
>
>
>
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