[Gnso-newgtld-wg] FW: Proposal re Closed Generics

Mike Rodenbaugh mike at rodenbaugh.com
Fri Mar 6 17:38:55 UTC 2020


Jorge, you may not have been there, but this debate goes back to 2006-2012
and was exhaustively argued and documented.  That resulted in the GNSO
community -- indeed a unanimous GNSO Council -- allowing closed generics in
the 2012 round.  The will of the community was thwarted only by
unsubstantiated action of the GAC (no reasoning whatsoever) and a kowtowing
Board (again, with no reasoning whatsoever).  Now, with no reasoning
whatsoever, we are hearing the same arguments.

So I echo Marc's call for any sort of substantiation of potential harm,
other than "we think it's unfair."  Unfairness has existed in the DNS since
day one, both in the SLD and TLD space.  The analogy to SLDs is the best we
have, and is quite legitimate given that many .com SLDs are worth far
more than almost all new TLDs -- on the open market, to the public interest
and by any other metric.

We did have some dabbling as to closed generics despite the Board action,
with L'Oreal's fashion/makeup etc. TLDs.  That company essentially closed
those TLDs off as I recall.  Was anyone harmed, anywhere, in any way?

Mike Rodenbaugh
RODENBAUGH LAW
tel/fax:  +1.415.738.8087
http://rodenbaugh.law


On Fri, Mar 6, 2020 at 9:16 AM Marc Trachtenberg via Gnso-newgtld-wg <
gnso-newgtld-wg at icann.org> wrote:

> I think they will become more similar if there is an unlimited number of
> TLDs that can be operated.  Regardless, I think the analogy is valid and
> this is the only actual relevant  evidence available to us to consider
> since the Board punted on this issue in the first round and didn't permit
> closed generics, in which case we would have more direct evidence to
> consider.
>
> Accordingly, I reiterate my ask that those with evidence of competitive
> harm or other effects against the public interest resulting from generic
> SLDs proffer it up so that the decision of whether or not to permit closed
> generics in the next round, and if so , under what conditions, can be made
> based on more than just working group participants' commercial or
> philosophical interests..
>
> Best regards,
>
> Marc H. Trachtenberg
> Shareholder
> Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL
> 60601
> Tel 312.456.1020
> Mobile 773.677.3305
> trac at gtlaw.com | www.gtlaw.com
>
>
>
> -----Original Message-----
> From: Jorge.Cancio at bakom.admin.ch [mailto:Jorge.Cancio at bakom.admin.ch]
> Sent: Friday, March 6, 2020 10:40 AM
> To: Trachtenberg, Marc H. (Shld-Chi-IP-Tech) <trachtenbergm at gtlaw.com>;
> gnso-newgtld-wg at icann.org
> Subject: RE: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Dear Marc
> Which leads us to the TLD-SLD distinction. If they were so similar as you
> imply we wouldn’t be here since 2016...
> best
> Jorge
>
>
> ________________________________
>
> Von: trachtenbergm at gtlaw.com <trachtenbergm at gtlaw.com>
> Datum: 6. März 2020 um 17:35:51 MEZ
> An: Cancio Jorge BAKOM <Jorge.Cancio at bakom.admin.ch>,
> gnso-newgtld-wg at icann.org <gnso-newgtld-wg at icann.org>
> Betreff: RE: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Jorge,
>
> I understand that we are talking about closed generics, which is why I
> think the analogy is so apt.  Every generic SLD is closed by default.
>
> Best regards,
>
> Marc H. Trachtenberg
> Shareholder
> Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL
> 60601 Tel 312.456.1020 Mobile 773.677.3305 trac at gtlaw.com<mailto:
> trac at gtlaw.com> | http://www.gtlaw.com<http://www.gtlaw.com/>
>
> [Greenberg Traurig]
>
> From: Jorge.Cancio at bakom.admin.ch [mailto:Jorge.Cancio at bakom.admin.ch]
> Sent: Friday, March 6, 2020 10:17 AM
> To: Trachtenberg, Marc H. (Shld-Chi-IP-Tech) <trachtenbergm at gtlaw.com>;
> gnso-newgtld-wg at icann.org
> Subject: AW: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Dear Marc
> Let me also briefly respond… we are talking about closed generics… not
> about generics in general. I think I made my point clear on closed generic,
> i.e. generics restricted to a single entity, and why I feel they do not fit
> well with the public interest requirement… As to TLDs and their difference
> to SLDs: this potentially long discussion would IMO only distract us… The
> “.swiss” regulations on generics (which I mentioned only in a “p.s.”) is
> interesting inasmuch it does allow generics in the public interest, but
> those same public interest requirements do not allow a “closed” generic (in
> the SLD space).
> Kind regards
> Jorge
>
> Von: trachtenbergm at gtlaw.com<mailto:trachtenbergm at gtlaw.com> <
> trachtenbergm at gtlaw.com<mailto:trachtenbergm at gtlaw.com>>
> Gesendet: Freitag, 6. März 2020 17:01
> An: Cancio Jorge BAKOM <Jorge.Cancio at bakom.admin.ch<mailto:
> Jorge.Cancio at bakom.admin.ch>>; gnso-newgtld-wg at icann.org<mailto:
> gnso-newgtld-wg at icann.org>
> Betreff: RE: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Jorge,
>
> I would offer this quick observation.  With a virtually unlimited number
> of TLDs available for operation, the difference between new gTLDs second
> level domains in existing TLDs erodes or completely disappears and ICANN
> becomes a TLD registrar Right now almost every conceivable generic term in
> every language is registered in .com, inarguably the most dominant TLD.
> The owner of each of these generic terms SLDs is in sole control of it and
> can either permit third parties to “register” third level subdomains in
> his/her SLD or set up as many third level subdomains on the SLD (or none)
> has he/she wants.  Yet no one complains about this “monopolization” of
> generic terms in SLDs and how it is against the public interest.  The
> .swiss limitation on registration of generic SLDs is the first I have heard
> of such.  Is there any evidence anywhere of harm to competition or other
> public interests from this scenario?  I have not seen it but if it exist
> please someone send it to me.  If this is so harmful then we should ban all
> generic second level registrations in all TLDs that are not in the public
> interest.
>
> Best regards,
>
> Marc H. Trachtenberg
> Shareholder
> Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL
> 60601 Tel 312.456.1020 Mobile 773.677.3305 trac at gtlaw.com<mailto:
> trac at gtlaw.com> | http://www.gtlaw.com<http://www.gtlaw.com/>
>
> [Greenberg Traurig]
>
> From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces at icann.org] On
> Behalf Of Jorge.Cancio at bakom.admin.ch<mailto:Jorge.Cancio at bakom.admin.ch>
> Sent: Friday, March 6, 2020 5:25 AM
> To: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Dear all
>
> Please allow me to chime in on this discussion at this stage, and share
> some comments…
>
> In fact, the harder I think about this issue and how to equate “closed”
> (i.e. exclusive) registration of SLDs with “public interest”, the harder it
> is for me to find any possible example – as “public interest” as core of a
> “generic term” in the end always leads to a function that can be performed
> by a multiplicity of institutions or organizations and cannot be
> circumscribed to one single entity.
>
> I’ve seen in the materials and discussions the example of “.disaster” as
> one potential closed generic. But I think that this TLD would actually best
> work as a generic with a restrictive eligibility policy for SLDs: all
> entities complying with a set of objective criteria (e.g. being disaster
> relief organizations) should be allowed in.
>
> I cannot see any reason why such a TLD would be restricted to only one
> organization, even if that one is the ICRC ;P
>
> The argument that otherwise anyone could get a SLD under that TLD is IMO
> not precise, as, as we know, the “control” ensuring that only the right
> people get the SLDs can be obtained through precise, objective and
> non-discriminatory eligibility criteria (hence a “closed” generic is not
> necessary).
>
> Kind regards
>
> Jorge
>
> p.s.: under Swiss regulations for «.swiss» a generic term registration (as
> SLD) is subject to quite exhaustive rules, including the
> “non-discrimination” obligation, which excludes a “closed” approach…
>
>
> Von: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> Im Auftrag von Marc Trachtenberg via
> Gnso-newgtld-wg
> Gesendet: Dienstag, 3. März 2020 06:02
> An: Brian at Winterfeldt.law<mailto:Brian at Winterfeldt.law>
> Cc: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Betreff: Re: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Brian,
>
> Thank you for looking into this.  It gave me the opportunity to review the
> Board resolution again as well.  While you are correct to point out that
> the Board resolution references serving a public interest goal, I think the
> Board is clear that it is doing so to address the GAC advice and not taking
> a position on the issue.  Specifically the Board states:
>
> Resolved (2015.06.21.NG02), to address the GAC's Category 2.2 Safeguard
> Advice, the NGPC requests that the GNSO specifically include the issue of
> exclusive registry access for generic strings serving a public interest
> goal as part of the policy work it is planning to initiate on subsequent
> rounds of the New gTLD Program, and inform the Board on a regular basis
> with regards to the progress on the issue.
>
> Interestingly, the Board also notes in its rationale for the resolution
> that when the NGPC  requested the GNSO to provide guidance on the issue of
> closed generics the GNSO Council stated that, "although the GNSO did not
> explicitly consider the issue of 'closed generic' TLDs as part of the new
> gTLD PDP, we recall that the issue of restricting new gTLDs was, in
> general, considered and discussed. At that time, it was the view within the
> GNSO that it should not be the responsibility of ICANN to restrict the use
> of gTLDs in any manner, but instead to let new gTLD applicants propose
> various models; open or closed, generic or not."
>
> The Board also notes in its rationale that:
>
> “The comments from the community express a diversity of views on how, and
> whether the NGPC should implement the GAC's advice. Some of the significant
> themes raised by community comments, and considered by the NGPC in taking
> this action, are as follows:
> §  A Policy Development Process with respect to operating exclusive
> generic strings in the "public interest" should be undertaken by the
> community. Policy issues on "closed generic" TLDs should be resolved
> through the multistakeholder process.
> §  The public interest goal requirement as stated is too general and
> requires greater specificity for enforceability. The NGPC should add
> relevant meaning to the "public interest" concept by applying the GNSO
> rationales regarding the promotion of competition, consumer choice, market
> differentiation, and geographical and service provider diversity as
> standards for such affirmative objective showings and findings.
> §  Safeguards are important when applicants have chosen to apply for
> closed control of a generic term designating a particular industry where
> the applicant is engaged in the conduct of business activities in that
> industry.
> §  Requiring applicants to demonstrate some additional public interest
> goal in the context of exclusive registry access for generic strings would
> reverse the deliberate choices made by the ICANN community in its bottom-up
> process and impose new evaluation criteria.
> §  The status quo as set out in the Applicant Guidebook should apply so
> that both "open" and "closed" registry access for generic strings should
> continue to be allowed in this first application round, but both should be
> subject to significant scrutiny after launch by ICANN to ensure that the
> interests of rights owners and consumers are protected.”
> If anything is clear it is that this issue is complicated and that there
> are strong opinions on both sides of it.  Accordingly, whatever the final
> decision is, I hope it is based on facts, evidence, and reason, and not
> reliance on whatever the person thinks the status quo is.
> Best regards,
> Marc H. Trachtenberg
> Shareholder
> Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL
> 60601 Tel 312.456.1020 Mobile 773.677.3305 trac at gtlaw.com<mailto:
> trac at gtlaw.com> | http://www.gtlaw.com<http://www.gtlaw.com/>
>
> [Greenberg Traurig]
>
> From: Brian Winterfeldt [mailto:Brian at Winterfeldt.law]
> Sent: Monday, March 2, 2020 9:01 AM
> To: Trachtenberg, Marc H. (Shld-Chi-IP-Tech) <trachtenbergm at gtlaw.com
> <mailto:trachtenbergm at gtlaw.com>>
> Cc: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: RE: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Dear Marc,
>
> Re-reading the particular Board resolution on the subject from June 21,
> 2015, the Board resolved “that the GNSO specifically include the issue of
> exclusive registry access for generic strings serving a public interest
> goal as part of the policy work it is planning to initiate on subsequent
> rounds of the New gTLD Program” and “For the remaining applicants in this
> round of the New gTLD Program who propose to provide exclusive registry
> access for a generic string ("Exclusive Generic Applicants") … they must
> elect within a reasonably limited time to either: submit a change request
> to no longer be an exclusive generic TLD, and sign the current form of the
> New gTLD Registry Agreement; maintain their plan to operate an exclusive
> generic TLD. As a result, their application will be deferred to the next
> round of the New gTLD Program, subject to rules developed for the next
> round, to allow time for the GNSO to develop policy advice concerning
> exclusive generic TLDs; or withdraw their application for a refund
> consistent with the refund schedule in the Applicant Guidebook.”  See
> https://urldefense.com/v3/__https://www.icann.org/resources/board-material/resolutions-new-gtld-2015-06-21-en*2.a__;Iw!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3YPj8A5Oc$
> <
> https://urldefense.com/v3/__https:/www.icann.org/resources/board-material/resolutions-new-gtld-2015-06-21-en*2.a__;Iw!!DUT_TFPxUQ!XkyuqsZM36VMMmchhWmN03IzlZaiKVo74ife4rF55bXVUAAz8BAhi2ss8c_H8XdIEfk$
> >.
>
> I suppose, then, you are right that it would perhaps be more accurate to
> say that the current status quo is merely that closed generics have to date
> been prohibited, but could be permitted in future pending a change in rules
> through policy recommendations of this PDP (even though the resolution of
> course references serving a public interest goal).  In any case, our
> position is still that closed generics should (continue to) be prohibited
> in future new gTLD rounds, unless the applicant can demonstrate that
> operating a generic gTLD in a closed manner would serve a public interest
> goal (outweighing anti-competition concerns).
>
> Best regards,
>
> Brian
>
> ________________________________
> [
> https://urldefense.com/v3/__https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b113a1d2a61b_WIPG_LogoMark.png__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3YNi5ULMk$
> ]<
> https://urldefense.com/v3/__https:/www.winterfeldt.law/__;!!DUT_TFPxUQ!XkyuqsZM36VMMmchhWmN03IzlZaiKVo74ife4rF55bXVUAAz8BAhi2ss8c_HI44qDEU$
> >
>
> Brian J. Winterfeldt
> Principal
> Winterfeldt IP Group
> 1601 K Street NW, Ste 1050
> Washington, DC  20006<
> https://urldefense.com/v3/__http:/x-apple-data-detectors:/*12/1__;Lw!!DUT_TFPxUQ!XkyuqsZM36VMMmchhWmN03IzlZaiKVo74ife4rF55bXVUAAz8BAhi2ss8c_HFDLI9p0$
> >
> brian at winterfeldt.law<mailto:brian at winterfeldt.law>
> +1 202 903 4422
>
>
>
>
>
> From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces at icann.org] On
> Behalf Of Marc Trachtenberg via Gnso-newgtld-wg
> Sent: Friday, February 28, 2020 1:59 PM
> To: Brian Winterfeldt <Brian at Winterfeldt.law<mailto:Brian at Winterfeldt.law>>;
> gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Brian,
>
> Respectfully I disagree that the status quo with respect to treatment of
> “closed generic” gTLDs, is that they should be prohibited unless the
> applicant can demonstrate a public interest reason for allowing operation
> as a closed generic gTLD.  As I and some others have pointed out in
> numerous other emails on this thread, the public interest requirement was
> merely GAC advice and has become the “status quo” only as a result of it
> being inaccurately referred to that so many times that people accept it as
> fact.  In my view, if anything, the status quo is one of the following:
>
>
>   1.  Closed generics are permitted because they were not prohibited in
> the AGB and the Board only prohibited them in the first round and directed
> the GNSO to make policy to address their treatment in subsequent rounds; or
>   2.  Closed generics are not permitted because the Board prohibited them
> in the first round
>
> Personally, I think it is #1 based on the Board making specifying that the
> prohibition just applied to the current round and directed the GNSO to make
> it policy if the ban were to apply to future rounds, but reasonable minds
> can differ on that.  I don’t think it is reasonable to keep saying though
> that the status quo is that closed generics can only exist if it is
> demonstrable that their existence is in the public interest based on the
> record.
>
> Best regards,
>
> Marc H. Trachtenberg
> Shareholder
> Greenberg Traurig, LLP
> 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 T +1 312.456.1020
> trac at gtlaw.com<mailto:trachtenbergm at gtlaw.com> | http://www.gtlaw.com<
> http://www.gtlaw.com/> | View GT Biography <
> https://www.gtlaw.com/en/professionals/t/trachtenberg-marc-h>
>
> [Greenberg Traurig]
>
> From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> On Behalf Of Brian Winterfeldt
> Sent: Thursday, February 27, 2020 3:16 PM
> To: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> *EXTERNAL TO GT*
> Dear all,
>
> We generally support the current status quo with respect to treatment of
> “closed generic” gTLDs, namely that they should be prohibited unless the
> applicant can demonstrate a public interest reason for allowing operation
> as a closed generic gTLD.  While we appreciate that there may be some
> innovative uses of closed generic gTLDs in the public interest, given the
> potential for abuse of closed generic gTLDs (e.g. anti-competitive uses),
> we support prohibition as the default (again, subject to a public interest
> exception, for which the applicant would bear the burden of proof).
> Accordingly, we would support formalizing this approach in a future
> iteration of the AGB.  To that end, we also agree that clear criteria for
> what might constitute a public interest exception should be enumerated in
> such text (to be developed in implementation), and that any determinations
> on this subject would be appealable through the existing ICANN
> accountability mechanisms.
>
> Hope this input is helpful.
>
> Sincerely,
>
> Brian and Griffin
>
> ________________________________
> [
> https://urldefense.com/v3/__https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b113a1d2a61b_WIPG_LogoMark.png__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3YNi5ULMk$
> ]<
> https://urldefense.com/v3/__https:/www.winterfeldt.law/__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QE7wJjcYI$
> >
>
> Brian J. Winterfeldt
> Principal
> Winterfeldt IP Group
> 1601 K Street NW, Ste 1050
> Washington, DC  20006<
> https://urldefense.com/v3/__http:/x-apple-data-detectors:/*12/1__;Lw!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QECuej0gk$
> >
> brian at winterfeldt.law<mailto:brian at winterfeldt.law>
> +1 202 903 4422
>
>
> ________________________________
> [
> https://urldefense.com/v3/__https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b113a1d2a61b_WIPG_LogoMark.png__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3YNi5ULMk$
> ]<
> https://urldefense.com/v3/__https:/www.winterfeldt.law/__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QE7wJjcYI$
> >
>
> Griffin M. Barnett
> Associate
> Winterfeldt IP Group
> 1601 K Street NW, Ste 1050
> Washington, DC  20006<
> https://urldefense.com/v3/__http:/x-apple-data-detectors:/*12/1__;Lw!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QECuej0gk$
> >
> griffin at winterfeldt.law<mailto:griffin at winterfeldt.law>
> +1 202 759 5836
>
>
>
> From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces at icann.org] On
> Behalf Of Pruis, Elaine via Gnso-newgtld-wg
> Sent: Thursday, February 27, 2020 2:22 PM
> To: dorraink at amazon.com<mailto:dorraink at amazon.com>;
> gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Thanks for the response. I don’t see why a TLD would have to be a generic
> word to support any of the innovative concepts put forward.
>
> From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> on behalf of "Dorrain, Kristine via
> Gnso-newgtld-wg" <gnso-newgtld-wg at icann.org<mailto:
> gnso-newgtld-wg at icann.org>>
> Reply-To: "Dorrain, Kristine" <dorraink at amazon.com<mailto:
> dorraink at amazon.com>>
> Date: Thursday, February 27, 2020 at 12:06 PM
> To: "gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>" <
> gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>>
> Subject: [EXTERNAL] [Gnso-newgtld-wg] FW: Proposal re Closed Generics
>
> Somehow I accidentally only replied to Elaine, apologies!
>
> From: Dorrain, Kristine
> Sent: Thursday, February 27, 2020 9:02 AM
> To: 'Pruis, Elaine' <epruis at verisign.com<mailto:epruis at verisign.com>>
> Subject: RE: [Gnso-newgtld-wg] Proposal re Closed Generics
>
> A “closed generic” is single-registrant (see Spec 9 and Spec 11 of the
> RA).  A restricted TLD has non-RO registrants, but those registrants may
> have to satisfy criteria to get in, like .BANK.
>
> From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> On Behalf Of Pruis, Elaine via
> Gnso-newgtld-wg
> Sent: Thursday, February 27, 2020 8:53 AM
> Cc: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] Proposal re Closed Generics
>
> What’s the difference between a “restricted TLD” and a “closed generic” if
> the operator writes the rules to only allow registrants that fit their
> desired profile?
> What am I missing?
> Elaine
>
> From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> on behalf of Mike Rodenbaugh <
> mike at rodenbaugh.com<mailto:mike at rodenbaugh.com>>
> Date: Wednesday, February 26, 2020 at 6:02 PM
> To: Becky Burr <becky.burr at board.icann.org<mailto:
> becky.burr at board.icann.org>>
> Cc: "gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>" <
> gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>>
> Subject: [EXTERNAL] Re: [Gnso-newgtld-wg] Proposal re Closed Generics
>
> I think closed generics should be allowed, just as they were in the 2012
> round... until the Board's knee-jerk reaction to unsubstantiated GAC
> pressure.
>
> I disagree with Alan that means "no closed generics" is the current
> policy.  The AGB clearly allowed them, as they were not prohibited or
> restricted in any way.
>
> I agree with Becky that any "public interest" criteria had better be
> crystal clear to give the Board guidance.  But I don't think the Board
> should be deciding those things, at all.  The entire program was designed
> for the Board NOT to make such decisions.  Regardless of the criteria, some
> disappointed applicants certainly will challenge ICANN's decisions, as is
> their right under the Byalws.
>
> Mike Rodenbaugh
> RODENBAUGH LAW
> tel/fax:  +1.415.738.8087
>
> https://urldefense.com/v3/__http://rodenbaugh.law__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3Y9UbpSWc$
> <
> https://urldefense.com/v3/__http:/rodenbaugh.law__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QEw0KXmtQ$
> >
>
>
> On Wed, Feb 26, 2020 at 11:34 AM Becky Burr <becky.burr at board.icann.org
> <mailto:becky.burr at board.icann.org>> wrote:
> I'm taking no position whatsoever on the notion of public interest closed
> generics and/or whether an adverse decision should be appealable.  That
> said, if you do provide for a public interest exception to the no closed
> generics rule, please make the criteria crystal clear.  Otherwise you
> should expect disappointed applicants to file IRPs on the basis of
> disparate treatment.
>
> On Wed, Feb 26, 2020 at 1:27 PM Alexander Schubert
> <alexander at schubert.berlin<mailto:alexander at schubert.berlin>> wrote:
> Jeff,
>
> I agree. The board decision should be appealable – but if the board denies
> the “public interest” claim: I suggest that doesn’t have to lead to a
> denial of the entire application. The applicant could have an alternative
> “open gTLD” application portion as well – and upon board denial of the
> public interest claim the applicant could decide whether they want to
> withdraw; or fall back to the open registration version they submitted. Or
> appeal the board decision.
>
> Also I do not see the benefit of a strict “non-profit” restriction. All my
> 6 next round projects are non-profit, so I obviously value the choice of
> non-profit applicants a lot. But I could imagine “public interest” in an
> exclusive access model even when the registry is a for profit entity. In
> most of those cases that for profit entity would likely establish a
> trademark around the term. Like: “.twitter” – where TWITTER, Inc. would
> allow Twitter users to have their own twitter-handle matching domain (e.g.
> www.dotairport.twitter<
> https://urldefense.com/v3/__http:/www.dotairport.twitter__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QEvW2ELp8$>
> instead of the longish
> https://urldefense.com/v3/__http://www.twitter.com/dotairport__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3Y9Ga23LI$
> <
> https://urldefense.com/v3/__http:/www.twitter.com/dotairport__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QEkpLUbtg$>
> - why supporting the .com gTLD brand if you have your own global brand with
> dozens of millions of users?). In that case (in my mind) .twitter could
> not be a Spec 13 registration – because the heavy restrictions in Spec 13
> would in my perspective not allow all Twitter handles to be registered as
> .twitter domains to be used by Twitter, Inc. clients (brand specialists:
> what’s your opinion on this? Do I see this too narrow?).
>
> Actually this would apply to all social media that are based on generic
> terms:
>
> •        .twitter
>
> •        .facebook
>
> •        .snap
>
> •        .telegram
>
> Just as examples.
>
> Is an exclusive access “.twitter” of “public interest”? Given that the
> brand is so impacting and all domains of an open gTLD .twitter would be
> likely subject to confusion: seems to make a lot of sense to provide
> TWITTER, Inc. with exclusive access. We run into a clear “judgement call”
> here. Is “.match” (matches to make fire, matching items, etc.) better off
> as reserved for
> https://urldefense.com/v3/__http://match.com__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3Yr-mQsAo$
> <
> https://urldefense.com/v3/__http:/match.com__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QEiLqm3HI$>
> (single platform) – or not? Do we require the ICANN board to make these
> calls? What is the rationale of their decision? Gut-feeling?
>
> Thanks,
>
>
> Alexander
>
>
>
>
>
> From: Gnso-newgtld-wg [mailto:gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>] On Behalf Of Jeff Neuman
> Sent: Mittwoch, 26. Februar 2020 12:40
> To: Alan Greenberg <alan.greenberg at mcgill.ca<mailto:
> alan.greenberg at mcgill.ca>>; Mike Rodenbaugh <mike at rodenbaugh.com<mailto:
> mike at rodenbaugh.com>>
> Cc: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] Proposal re Closed Generics
>
> Alan,
>
> Can you explain why being able to assert an accountability mechanism would
> destroy the notion of the public interest closed TLD.
>
> Remember, GAC Advice was fairly clear on this.  It didn’t say that there
> should never be closed generic TLDs.  It said “For strings representing
> generic terms, exclusive registry access should serve a public interest
> goal."
>
> Your initial proposal (minus the no appeals part) to have any public
> interest TLD closed generic exception is rather narrow to begin with.  Must
> be a non-profit entity, must have a vote by Board Supermajority, etc.
> Justine has recommended some additional elements on top of that with strong
> contractual compliance provisions…..
>
> I am not saying I support or don’t support the proposal, but I am not sure
> why taking away a right to use an accountability mechanism would destroy
> the entire proposal?
>
> Thanks.
>
> Jeff Neuman
> Senior Vice President
> Com Laude | Valideus
> D: +1.703.635.7514
> E: jeff.neuman at comlaude.com<mailto:jeff.neuman at comlaude.com>
>
> From: Gnso-newgtld-wg <gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> On Behalf Of Alan Greenberg
> Sent: Tuesday, February 25, 2020 5:49 PM
> To: Mike Rodenbaugh <mike at rodenbaugh.com<mailto:mike at rodenbaugh.com>>
> Cc: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] Proposal re Closed Generics
>
> Fine with me. But in my opinion, that means the exception for public
> interest TLDs will not fly and we revert to the 2012 implementation of no
> closed generics.
>
> Alan
>
> At 25/02/2020 04:32 PM, Mike Rodenbaugh wrote:
> i do not believe the Board should be allowed to make any decisions that
> are not "appealable" per the IRP.  If Claimant has proper standing and a
> dispute within the scope of the Bylaws definition of Dispute, then they
> have a valid IRP claim.  This is a very slippery slope to start to carve
> out Board decisions that have no chance of appeal, and why on Earth would
> we want to do that anyway?
>
> Mike Rodenbaugh
> RODENBAUGH LAW
> tel/fax:  +1.415.738.8087
>
> https://urldefense.com/v3/__http://rodenbaugh.law__;!!DUT_TFPxUQ!S56UmcGzyJEfOdX2Uls-BXDG8GKSscIyq7yPCSdP7CJz_9cks_vXURn8XW3Y9UbpSWc$
> <
> https://urldefense.com/v3/__http:/rodenbaugh.law__;!!DUT_TFPxUQ!Q_YjEVU8CSS0x0AFsQE_VZOnoFx9i_X26cZfLDGEeKWVisLEWhvtOjHF-3QEw0KXmtQ$
> >
>
>
> On Mon, Feb 24, 2020 at 7:08 PM Alan Greenberg <alan.greenberg at mcgill.ca
> <mailto:alan.greenberg at mcgill.ca> > wrote:
> I had this in my original proposal but based on individual discussions I
> have had I know that some people missed it.
> To have the Board make a decision that is not in any way appealable will
> require a Bylaw change, but it is a change for which there is another
> precedent that will go before the Board before out report reaches them. The
> Auction Proceeds CCWG also will require a similar Bylaw amendment.
> Alan
> At 24/02/2020 09:46 PM, Phil Buckingham wrote:
> Hi Justine , Alan , Anne,
> Justine , that̢۪s  a great suggestion. The contrntractual compliance &
> monitoring needs to be much more rigorous in the next round .
> I very much support Alan̢۪s suggestion of going aheadead with new (
> 2020) policy recommendations for a special use case  , New TLD application
> category . Let̢۪s call it a Public Ic Interest TLD .
> I am working on a proposal ( for Friday̢۪ deadline) .) . It will
> incorporate the evaluation and implementation issues too.
> Ultimately my thoughts are we need to make policy that is so demanding ,
> incorporating Alexander’s suggestion of a â₢€œ health warning “
> that applications will not pt pass the evaluation.  ICANN will need to
> employ & train “ evaluation  experts. There will be no come backs , no
> second evaluation , no appeals . Once passed the evaluation The Board would
> need to approve ( or reject) the application by Special resolution.
> Your thoughts ?
> Phil
> Phil Buckingham
> Sent from my iPhone
> On 25 Feb 2020, at 01:30, Justine Chew <justine.chew at gmail.com<mailto:
> justine.chew at gmail.com> > wrote:
> Perhaps this is something we could pick up under the Contractual
> Compliance topic.
> Justine
> -----
> On Fri, 21 Feb 2020 at 01:39, Aikman-Scalese, Anne <AAikman at lrrc.com
> <mailto:AAikman at lrrc.com>> wrote:
> Thank you Justine.  This is very constructive.  We would then need to
> think about enforcement mechanisms.  Private dispute resolution process?
> Filing a complaint with ICANN?  Positive obligation by ICANN Compliance to
> monitor?  Accomplish the goals below via PICs and eligibility
> requirements?  Would appreciate your further thoughts.
> Just continuing the discussion so we can help create a complete proposal
> as this moves forward to formulate a WG recommendation.
> Anne
>
> From: Gnso-newgtld-wg < gnso-newgtld-wg-bounces at icann.org<mailto:
> gnso-newgtld-wg-bounces at icann.org>> On Behalf Of Justine Chew
> Sent: Thursday, February 20, 2020 12:28 AM
> To: gnso-newgtld-wg at icann.org<mailto:gnso-newgtld-wg at icann.org>
> Subject: Re: [Gnso-newgtld-wg] Proposal re Closed Generics
>
> [EXTERNAL]
> ________________________________
> While I remain undecided on supporting either a full ban on closed
> generics or (what I call) a qualified ban per the special case conditions
> proposed by Alan, I strongly suggest that any consideration of Alan's
> proposal should also include the following:
> Insertion as material in the relevant RA for a closed generic TLD that is
> a generic word, such terms and conditions:
> (1)  to be derived from the applicant's submission on the use of the
> closed generic TLD as being in the public interest;
> (2)  which prohibit any action considered as anti-competitive (eg.
> discriminatory registration policies in favour of certain parties or
> against competitors in the applicable industry);
> (3)  which govern any dealings on the disposal and/or future use of the
> closed TLDs - that (1) and (2) must be adhered to at all times and by any
> party which operates or acquires the rights under the RA; and
> (4)  to stipulate that launching for SLD registration for the closed
> generic TLD by the (first) RO must take place within 2 years of signing the
> RA.
> the breach of one or more of which will constitute cause for termination
> of the RA.
> Justine
> -----
>
>
> On Thu, 20 Feb 2020 at 13:48, Alan Greenberg <alan.greenberg at mcgill.ca
> <mailto:alan.greenberg at mcgill.ca> > wrote:
> While talking to a colleague today, I realized a problem with my proposal.
> I was thinking that there would (or could ) only be a small number of
> applications that could be deemed to be for closed TLDs that are generic
> words and in the public interest. That may indeed be true. However, there
> may well be MANY such applications twhere the applicant beleives their use
> will be in the public interest, and a large load of such cases going to the
> Board will not work.
> The change is to restrict applicants to not-for-profit entities only.
> This is in keeping with the nature of the one example that has been raised.
> Note that due to the unfortunate timing of the SubPro meeting being
> scheduled in conflict with the EPDP, I will likely not be on the SubPro
> call.
> To make my position clear, other than this special case I am proposing, I
> would NOT support the delegation of closed generics.
> Alan
> At 18/02/2020 07:43 PM, Alan Greenberg wrote:
> >The SubPro meeting today began discussing Closed Generics.
> >
> >One of my interventions was that although I was strongly opposed to
> >closed generics in the general case, I did support the concept that a
> >closed generic could be in the public interest, with the example of
> >.disaster operating by the International Red Cross as the example.
> >
> >I proposed that we allow closed generic applications, but the decision
> >on whether a particular application would move forward or not would
> >rest with the ICANN Board.
> >
> >The Board would have to agree, by an overwhelming majority (say at
> >least 90% of sitting, non-conflicted, Board members) that the TLD would
> >be in the public interest.
> >
> >The decision would be final and not appealable through the ICANN
> >Reconsideration or IRP processes. This latter condition would require
> >an amendment to the ICANN Bylaws to exempt such decision from the
> >accountability measures, but this is identical to an amendment being
> >recommended by the CCWG-Auction Proceeds, so there is a current
> >precedent.
> >
> >If, despite the fact that the decision would have to be near unanimous,
> >there is still distrust of the ICANN Board in this matter, the approval
> >of such TLDs could be subject to the Empowered Community Approval or
> >Rejection Actions (also requiring a Bylaw change). However, in my mind,
> >such caution would be overkill.
> >
> >This proposal would allow a closed generic when it is clearly (in the
> >view of the Board) in the Public Interest.
> >
> >Alan
> _______________________________________________
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