Don’t Want the URS on Your .Com Domains?

Did you feel the ground shake under your feet?   That little tremor is the result of ICANN staffers trying to make it easier for companies to suspend your domain names by forcing the Uniform Rapid Suspension System (URS) into legacy domain name agreements.

Take a minute out of your day to send an email to ICANN opposing adding URS to legacy domains.   Today is the last day to comment.   You’ll feel good that you will have just made your business a little more secure.

A little background – the URS is an experimental policy that was rolled out as part of the big new expansion of top level domains (new gTLDs).   The URS is a  quicker, faster, cheaper  way for a company that has a problem with your domain name to shut it down than by using the older Uniform Domain Name Dispute Resolution Policy (UDRP).

There are two big problems with what ICANN staff is trying to do:

First, it isn’t their job.   ICANN staff is supposed to implement policies developed by the ICANN stakeholder community, not make policy on its own.   ICANN staff is usurping the role of the ICANN stakeholder community by unilaterally making the decision to force URS onto established top-level domains when the ICANN community has not yet agreed that this is the right thing to do, nor has the ICANN community even finished their initial review of how well the URS is working.

Second, none of us who have registered domains in the .com, .net, .org or any of the older, ‘legacy’ name spaces agreed to be subject to the URS.   This change is being forced on us without our permission, without our agreement, and without going through the proper procedures.

The URS was made part of the new gTLD registration agreement from Day One.   When you registered a new gTLD, the URS was already part of the agreement that you agreed to when you made the registration.   But no one who registered a legacy domain name agreed that the URS could be used to shut down our domains.

ICANN staff is trying to make a fundamental change to the ownership rights to all those who own the hundreds of millions of legacy domain names on which most of the Internet is built.   ICANN staff is being sneaky.   They are trying to sneak URS into little used legacy extensions such as .travel, .pro, and .cat (did you know there was a .cat for Catalan speakers?).   If they succeed, they will have set a precedent that they will argue will require that the URS be added to .com, .net, .org and so on for consistency’s sake.

Now is the time to tell ICANN staffers that you are opposed to them overstepping their bounds.

It takes only a minute or two to make your voice heard.   And all you need to do is to send an email.   But today is the last day you can comment.

The simplest thing to do is to review the comments already posted and use of them as the basis for your own comment.   You can even copy and past and modify as you like.

ICA’s comment on .Travel and our report on the other comments can be found at  http://www.internetcommerce.org/comments-oppose-dottravel-urs/  . Here’s an excerpt from our letter:

The ICA is strongly opposed to the inclusion of new gTLD rights protection mechanisms (RPMs), particularly Uniform Rapid Suspension (URS), in this renewal agreement (RA) for a legacy gTLD.   We believe that this attempt by ICANN contracting staff to create de facto Consensus Policy via individual registry contract, absent a relevant Policy Development Process (PDP), is a glaring example of the type of top down, unaccountable action that should be targeted by enhanced accountability measures accompanying the IANA transition proposal. Contracts with legacy gTLDs can contain and enforce Consensus Policy, but it is an impermissible violation of ICANN’s Bylaws for contracts to attempt to create Consensus Policy.

We strongly urge that Section 2 of Specification 7 of the Renewal Agreement (RA) for .Travel, which contains the URS as well as the Trademark Post‐Delegation Dispute Resolution Procedure (PDDRP) be deleted in its entirety. Failure to take that action, and the resulting approval of a .Travel RA that contains these RPMs, will constitute a gross and unacceptable violation of ICANN Bylaws. We hope that contracting staff will promptly take the corrective action required on this matter…    The potential addition of these RPMs to legacy gTLDs through this inappropriate avenue will … substantially and adversely affect third parties around the world consisting of the existing registrants of more than one hundred million legacy gTLD domains.

Other comments are posted here:

http://forum.icann.org/lists/comments-cat-renewal-28may15/

and here:

http://forum.icann.org/lists/comments-pro-renewal-28may15/

and then email your comments to these email addresses:

comments-cat-renewal-28may15@icann.org    (to oppose adding URS to .cat)

comments-pro-renewal-28may15@icann.org     (to oppose adding URS to .pro)

The ICA will be posting its own comprehensive comment later today.   Feel free to post remarks below if you have any questions.

  1. This is not acceptable…

    “The fees associated with a URS proceeding are generally much lower than UDRP fees. On July 1, 2013, the Forum’s Supplemental Rules for URS proceedings entered into force. These rules define the costs associated with pursuing a URS claim, which vary depending on the number of domain names at issue (see Table 1).22 The Forum was able to meet ICANN’s target of $300 to $500 for filing fees, resulting in URS fees significantly lower than the $1,000 to $7,000 typically associated with UDRP proceedings. “

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