[GNSO-RPM-WG] Q#15 Transparency for the TMCH

Mon Oct 14 21:13:03 UTC 2019

I think you are mixing up Georges’ comments and mine.

I have not responded to your hypothetical. So obviously what you have
attempted to restate is not my position, since I haven’t stated one. It
doesn’t resemble anyone’s position that I can recall, though it seems to be
cobbled together from little bits and pieces of your hypothetical and
response made to it.

I was responding to your “full circle” comment.

No need for me to repeat what Marc and I already wrote in response to that.

Greg

On Mon, Oct 14, 2019 at 5:03 PM Michael Karanicolas <mkaranicolas at gmail.com>
wrote:

> Hi Greg. I think we're talking past each other with regard to Jason's
> original comment. I don't think it was attempting to accuse anyone of
> anything shady with regard to registering different things in different
> jurisdictions - which I know is standard practice. It was, I think, a
> genuine attempt to understand the substance of the opposition.
>
> I asked you earlier in the thread why someone who wanted to find out a
> brand's digital strategy wouldn't simply go to any registrar, search for
> domains corresponding to the trademarks that an entity has registered, and
> see when a claims notification pops up.
>
> So I understand - your point is that there are some national systems which
> are not included in WIPO's database (even though Canada and the US, and
> from what I can see virtually every other major market are included), and
> so there will be some countries where full trademark registration
> information is not immediately available, and thus information obtained by
> trawling through the system on a trial-and-error basis using just WIPO's
> database would be (slightly) incomplete.
>
> Is that an accurate representation of the substance of your position here?
>
> On Mon, Oct 14, 2019 at 4:47 PM Greg Shatan <gregshatanipc at gmail.com>
> wrote:
>
>> Michael,
>>
>> What Marc said.
>>
>> To make it clearer, a company will file for different marks in Country A
>> vs. Country B because they use a different subset of their total brand
>> portfolio in each country.
>>
>> Even moving between the USA and Canada, you must have noticed products
>> available in one country but not the other, even though the parent company
>> does business in both countries.  Just try to buy a Coffee Crisp in the
>> States. (Due to a failed attempt to introduce Coffee Crisp several years
>> back, the TM may be registered here, but you get the point.)
>>
>> Let’s put the “elaborate scenario” to rest and move on (unless there is
>> transcript or email evidence that this position was actually put forth as
>> an argument in favor of a closed database).
>>
>> The explanation given by Marie has been the primary stated concern since
>> the beginning — I can remember Susan Kawaguchi stating  this about 3 years
>> ago.
>>
>> Greg
>>
>> On Mon, Oct 14, 2019 at 4:26 PM Marc Trachtenberg via GNSO-RPM-WG <
>> gnso-rpm-wg at icann.org> wrote:
>>
>>> Michael,
>>>
>>>
>>>
>>> How exactly does this come full circle to the elaborate scenario  that
>>> Jason first asked about?  Jason asked about a practice where “Large brand
>>> owners like the ability to file in “remote” jurisdictions with
>>> non-searchable DBs to gain a priority date that can later be used for
>>> priority presumably in the US under a Section 44 application under the
>>> Paris Convention.”  I am not sure where he is getting his information from,
>>> particularly the part about the large brand owners “liking” this ability.
>>>  I am not aware of this practice being widespread and Jason has presented
>>> no facts or evidence that this strategy regularly occurs other than his
>>> bald and conclusory allegation of such.
>>>
>>>
>>>
>>> Irrespective of whether this practice is prevalent (which its not),
>>> Georges’ point that often brand owners file for different marks in
>>> different countries depending on local products, translation issues and
>>> other business reasons in no way connects or supports Jason’s conspiracy
>>> theory.
>>>
>>>
>>>
>>> That leaves us with Georges’ other point, which is that there does not
>>> seem to be a strong reason supported by real world evidence supporting
>>> opening up the TMCH while there is ample evidence of trademark and brand
>>> abuse which supports keeping the database closed.
>>>
>>>
>>>
>>> Best regards,
>>>
>>>
>>>
>>> *Marc H. Trachtenberg*
>>> Shareholder
>>> Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago,
>>> IL 60601
>>> <https://www.google.com/maps/search/77+West+Wacker+Drive+%7C+Suite+3100+%7C+Chicago,+IL+60601?entry=gmail&source=g>
>>> Tel 312.456.1020
>>>
>>> Mobile 773.677.3305
>>>
>>> trachtenbergm at gtlaw.com | www.gtlaw.com
>>>
>>>
>>>
>>> [image: Greenberg Traurig]
>>>
>>>
>>>
>>> *From:* GNSO-RPM-WG [mailto:gnso-rpm-wg-bounces at icann.org] *On Behalf
>>> Of *Michael Karanicolas
>>> *Sent:* Monday, October 14, 2019 3:09 PM
>>> *To:* Nahitchevansky, Georges <ghn at kilpatricktownsend.com>
>>> *Cc:* J. Scott Evans via gnso-rpm-wg <gnso-rpm-wg at icann.org>
>>> *Subject:* Re: [GNSO-RPM-WG] Q#15 Transparency for the TMCH
>>>
>>>
>>>
>>> Thanks Georges - we have now come full circle to the "elaborate
>>> scenario" which Jason first asked about, and which your colleagues
>>> disavowed earlier in this very thread.
>>>
>>>
>>>
>>> On Mon, Oct 14, 2019 at 4:03 PM Nahitchevansky, Georges <
>>> ghn at kilpatricktownsend.com> wrote:
>>>
>>> Michael
>>>
>>>
>>>
>>> With all due respect not every country is listed in the WIPO database.
>>> In fact there are a number of countries that are not listed or included
>>> there and that are not online. I am surprised you do not know this.  Most
>>> practitioners know this. The point is that you have do much research to
>>> figure out all of the marks filed by a brand owner. Perhaps you do not know
>>> this, but often brand owners file for different marks in different
>>> countries depending on local products, translation issues and other
>>> business reasons. But again this is an aside.  the real point is that the
>>> concern of brand owners of having an open TMCH registry is the likelihood
>>> that it will lead to more abuse. There does not seem to be a strong reason
>>> supported by real world evidence supporting a change here
>>>
>>>
>>>
>>> *From:* mkaranicolas at gmail.com
>>>
>>> *Sent:* October 14, 2019 4:36 PM
>>>
>>> *To:* gnso-rpm-wg at icann.org
>>>
>>> *Subject:* Re: [GNSO-RPM-WG] Q#15 Transparency for the TMCH
>>>
>>>
>>>
>>> Hi all,
>>>
>>> A few points have been raised that warrant being addressed. First off -
>>> it wouldn't take "hours of painstaking searches" to find a trademark
>>> owner's full portfolio. WIPO has a wonderful tool which aggregates these
>>> databases together: https://www3.wipo.int/branddb/en/
>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www3.wipo.int_branddb_en_&d=DwMFaQ&c=2s2mvbfY0UoSKkl6_Ol9wg&r=L7MB7eHT-UoCXD4iA3c7Sm3JrKXt7T1dG3NjBzCxm1c&m=1LwWScbonghAqwT9jIHMhEuXMtkQJey8DSBMUi5zfbQ&s=VZWft9Wmkt_-fiKa0lU4oDs7B4MYllu_BfCZSAa-b04&e=> It's
>>> a bit surprising to me that professionals working in this space are
>>> unfamiliar with this aggregated database... but live and learn.
>>>
>>> Regarding the technical challenges of findings a trademark owner's
>>> filings in the TMCH - while it is correct that the claims period only runs
>>> for 90 days - the fact that there has been, and continues to be, a steady
>>> stream of new gTLD rollouts renders that relatively moot as an obstacle to
>>> access. I concede there might be some small financial risk to mining the
>>> data in this way (although I believe most credit cards allow for cancelled
>>> transactions within 24 hours or so) - but even so, it would be a relatively
>>> trivial amount of money in the context of corporate intelligence budgets.
>>> If the commercial value of this information doesn't exceed a few hundred
>>> dollars for a major brand, I would question whether it's as sensitive as
>>> people claim.
>>>
>>>
>>>
>>> I'm not going to engage in discussions about the original intent of the
>>> TMCH since I wasn't involved in ICANN at the time - except to note that
>>> there are those who were involved in the process who will argue vehemently
>>> that it was intended to be transparent.
>>>
>>> Best,
>>>
>>>
>>>
>>> Michael
>>>
>>>
>>>
>>> On Sun, Oct 13, 2019 at 6:12 PM claudio di gangi <ipcdigangi at gmail.com>
>>> wrote:
>>>
>>> Good points, Marc.
>>>
>>>
>>>
>>> And point #3 is what I expressed in my prior note, e.g. the mining of
>>> TMCH data was an issue that was contemplated during TMCH implementation in
>>> the content of *minimizing misuse of access*.
>>>
>>>
>>>
>>> As some may recall, there was a major proposal (submitted by a group of
>>> registries) designed to mitigate the misuse of access by decreasing the
>>> coupling of certain technical functions of the TMCH from registry
>>> interaction.
>>>
>>>
>>>
>>> Misuse of access was germane to these proposals. ICANN org ultimately
>>> decided against implementing certain proposed control mechanisms - but not
>>> for policy reasons based on the support/permission of data mining, but
>>> because ICANN org deemed the control mechanisms to be ineffective in
>>> practice.
>>>
>>>
>>>
>>> If anyone is interested in more background, please see the blog article
>>> linked to below (from CircleID) which took place at this juncture of TMCH
>>> implementation when the cited proposal was under consideration.
>>>
>>>
>>>
>>> The bottom line is the fact that someone can mine the TMCH data under
>>> current procedures, and then turnaround and use that data to target brands
>>> and register domain names abusively (in other TLDs) is, if anything, a
>>> problem we should be working to address.
>>>
>>>
>>>
>>> Moreover, data mining is a real indication that the number of TM Claims
>>> notices that were issued are not reflective of the true number of times an
>>> actual registrant sought to register a domain.
>>>
>>>
>>>
>>> So while we could try to develop TMCH recommendations that mitigate the
>>> practice of data mining, since that practice is inconsistent with the
>>> intended purpose and functionality of the TMCH, at a minimum, such
>>> harmful practices (which increase costs on all parties) do not
>>> constitute valid arguments for TMCH transparency in my opinion, and are not
>>> necessary for our team to build potential solutions for addressing
>>> stakeholder concerns.
>>>
>>>
>>>
>>>
>>> http://www.circleid.com/posts/20120828_trademark_clearinghouse_secure_reliable_usable_pick_any_two/
>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.circleid.com_posts_20120828-5Ftrademark-5Fclearinghouse-5Fsecure-5Freliable-5Fusable-5Fpick-5Fany-5Ftwo_&d=DwMFaQ&c=2s2mvbfY0UoSKkl6_Ol9wg&r=L7MB7eHT-UoCXD4iA3c7Sm3JrKXt7T1dG3NjBzCxm1c&m=1LwWScbonghAqwT9jIHMhEuXMtkQJey8DSBMUi5zfbQ&s=fnaVxbhwbUBXCwQt8vWEY94NhNnyrp3NReKHN9Yt3aM&e=>
>>>
>>>
>>>
>>> "The discussions focused on a fundamental contradiction in the TMCH
>>> specifications that are mandated by the Applicant Guidebook. During the
>>> development of the AGB, rights holders made it clear that a major concern
>>> for them was the risk of data mining if the database was released into the
>>> public domain: being able to identify new products being developed by
>>> global corporations (by tracking their registered trade marks) could
>>> threaten multi-billion dollar product development plans. This means
>>> restrictions on the distribution of the database, to minimise the chances
>>> of unauthorised access."
>>>
>>>
>>>
>>> Later in the article:
>>>
>>>
>>>
>>> "But the fundamental problems with the TMCH are much more serious:
>>> rights holder protection was probably the most controversial issue
>>> surrounding the programme, and if the protection mechanisms devised should
>>> fail, then it would be a significant blow to the credibility of ICANN as a
>>> corporation and as a community (as Kurt Pritz made clear in Brussels). Some
>>> very smart minds are now paying close attention to this issue, trying to
>>> resolve the problems."
>>>
>>>
>>>
>>>
>>>
>>> On Sun, Oct 13, 2019 at 2:45 AM Marc Trachtenberg via GNSO-RPM-WG <
>>> gnso-rpm-wg at icann.org> wrote:
>>>
>>> Two reasons:
>>>
>>> 1. Trademark Claims only runs for 90 days after Sunrise; and
>>>
>>> 2. The claims notice does not pop up when a domain name is searched.
>>> The person must actually attempt to register the domain name before a
>>> Claims Notice will be generated and displayed
>>>
>>> In other words, it would take a significant amount of time and effort to
>>> try and circumvent the existing confidentiality and there would also be
>>> some measure of financial risk  - i.e., if there is no TMCH entry the
>>> person would be charged for the registration.  This might not cost so much
>>> on a one-off basis, but could quickly get expensive in the aggregate.
>>>
>>> Best regards,
>>>
>>> Marc H. Trachtenberg
>>> Shareholder
>>> Greenberg Traurig, LLP
>>> 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601
>>> <https://www.google.com/maps/search/77+West+Wacker+Drive+%7C+Suite+3100+%7C+Chicago,+IL+60601?entry=gmail&source=g>
>>> T +1 312.456.1020
>>> trac at gtlaw.com | www.gtlaw.com | View GT Biography
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: GNSO-RPM-WG [mailto:gnso-rpm-wg-bounces at icann.org] On Behalf Of
>>> Michael Karanicolas
>>> Sent: Saturday, October 12, 2019 1:30 PM
>>> To: Greg Shatan <gregshatanipc at gmail.com>
>>> Cc: gnso-rpm-wg at icann.org
>>> Subject: Re: [GNSO-RPM-WG] Q#15 Transparency for the TMCH
>>>
>>> *EXTERNAL TO GT*
>>>
>>> Thanks Greg. Now can you explain to me why a person who wanted to know
>>> this "confidential strategy" wouldn't just go to any registrar, search for
>>> domains corresponding to the trademarks that an entity has registered, and
>>> see when a claims notification pops up, to get an accurate and complete
>>> picture of which marks they have chosen to put into the TMCH?
>>>
>>> On Sat, Oct 12, 2019 at 1:42 PM Greg Shatan <gregshatanipc at gmail.com>
>>> wrote:
>>> >
>>> > Jason and all,
>>> >
>>> > This "elaborate scenario" (filing "in “remote” jurisdictions with
>>> non-searchable DBs to gain a priority date") is not at all the rationale
>>> that was put forth by those in favor of a closed TMCH database.
>>> >
>>> > I believe it's incorrect to say that this scenario was raised (in the
>>> chat, by John McElwaine, or otherwise) introduced this concept as part of
>>> an argument in favor of a closed TMCH database.
>>> >
>>> > I am not even aware of the use of the strategy as described in its
>>> totality.  I think this may be an unfortunate misunderstanding or
>>> mis-recollection of the earlier discussions and the surrounding facts.
>>> >
>>> > As I recall, the rationale is much more straightforward: A brand
>>> owner's choice of the subset of their trademarks to put in the TMCH is a
>>> confidential strategy. Giving third parties knowledge of this strategy
>>> allows these third parties to engage in activities that would harm TMCH
>>> registrants, which in turn would discourage use of the TMCH.  These
>>> activities include:  Targeting the brand owner's marks not in the TMCH for
>>> domain name registrations that can then be exploited in various ways;
>>> Developing a counter-strategy for TMCH registration (either by registering
>>> the same marks in the TMCH to enable contested Sunrises, or by registering
>>> the non-TMCH marks to gain advantage in Sunrise); Targeting the non-TMCH
>>> marks for counterfeiting, knock-offs, etc. (on the theory that the brand
>>> owner is less likely to put resources into policing and enforcing these
>>> less important marks), etc.
>>> >
>>> > However, if I'm incorrect about any of this, I'm always happy to learn
>>> new facts.
>>> >
>>> > I am aware that some applicants may choose to file in jurisdictions
>>> where registrations issue more quickly.  Even this limited scenario is not
>>> the practice of any brand owners I have represented or of which I'm
>>> specifically aware.  I can't speak to who or what type of applicant engages
>>> in even this limited practice.
>>> >
>>> > I do recall that one or a few people or entities have used some
>>> aspects of this strategy or something similar to try to "game" Sunrise.
>>> The specific concern about gaming the TMCH and Sunrise is one that I
>>> believe we need to deal with. I believe we should do this in a targeted
>>> fashion, both to get to consensus in the WG and to avoid disadvantaging
>>> legitimate TMCH registrants.
>>> >
>>> > Best regards,
>>> >
>>> > Greg
>>> >
>>> > On Fri, Oct 11, 2019 at 12:52 PM Jason Schaeffer <jason at esqwire.com>
>>> wrote:
>>> >>
>>> >> Hi All,
>>> >>
>>> >>
>>> >>
>>> >> Sorry for not being able to address this on yesterday’s call – I was
>>> bounced from the Zoom and couldn’t reconnect from my mobile.  After much
>>> consideration of the chat comments and statements during the past two calls
>>> I’ve parsed together the following strategy concerns that might be at
>>> issue.   It seems the opposition to an open/transparent TMCH have set forth
>>> the following rationale:
>>> >>
>>> >>
>>> >>
>>> >> Large brand owners like the ability to file in “remote” jurisdictions
>>> with non-searchable DBs to gain a priority date that can later be used for
>>> priority presumably in the US under a Section 44 application under the
>>> Paris Convention.   For example, Party A could “secretly” register in say
>>> Mauritius or Jamaica (jurisdictions that I believe do not have searchable
>>> DBs), and then file a Section 44 with the USPTO when ready to “go public.”
>>>  In this scenario, large brand owner obtains the earlier priority date in
>>> the US without having disclosed its “secret” brand plans or strategy.
>>>  Alternatively, there may also be a similar use case with a registration in
>>> the EU.  This is what I understand the opposition was presenting in the
>>> comments last week and again yesterday.
>>> >>
>>> >>
>>> >>
>>> >> This use of the “secret TM priority” filing method is one thing, and
>>> I understand the ostensible business intelligence concerns to require such
>>> a tactic.   However, we are discussing this in the context of the TMCH.
>>> How can these parties obtain Sunrise protection without proof of use?
>>>  This is even more challenging in the case of an EU registration that might
>>> not be based on actual use.
>>> >>
>>> >>
>>> >>
>>> >> If the project is top secret and subject to heightened secrecy, how
>>> can the party then show legitimate use of the mark and obtain TMCH
>>> protection while maintaining its purported heightened secrecy?  What is the
>>> POU and what is the declarant stating to the TMCH?  Is this the position
>>> that the opposition is proffering to block transparency of the TMCH?
>>> >>
>>> >>
>>> >>
>>> >> In addition, if I am correctly capturing how the method is employed
>>> in practice, it would be helpful to know if this practice is really in
>>> widespread use or rather an outlier, because I’m not yet seeing an
>>> important justification that outweighs the important benefits of an open
>>> TMCH.
>>> >>
>>> >>
>>> >>
>>> >> Thanks,
>>> >>
>>> >>
>>> >>
>>> >> Jason
>>> >>
>>> >>
>>> >>
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