To: gTLD-MoU Policy Oversight Committee, c/o ITU, Place des Nations, 1211 Geneva 20, Switzerland.

From: Douglas J. Wood, Esq., CASIE Legal Counsel, Hall Dickler Kent Friedman & Wood LLP. 909 Third Avenue, New York, NY 10022. Telephone: (212) 339-5400; Telecopy (212) 935-3121; email: dwood@halldickler.com.

Introduction

This response is submitted on behalf of CASIE, a joint coalition of the Association of National Advertisers, Inc. ("ANA") and the American Association of Advertising Agencies ("AAAA"), two trade associations that collectively represent the most major players in the global advertising and advertising agency industries. In fact, CASIE's purpose is to foster the growth of marketing and advertising on the Internet.

CASIE applauds the POC's proposal that "the POC be expanded by adding representatives from the interest classes that are clear stakeholders in the Internet DNS and currently under-represented." To that end, CASIE submits that one significant under-represented interest class is the Internet marketing and advertising community -- the community which has driven the growth of the Internet from an academic medium to a global electronic marketplace. Thus, CASIE proposes that a representative from one of the global marketers among the ANA membership whose company is active on the Internet and concerned with Internet governance and global brand protection should be appointed to the POC.

A CASIE representative would be a most appropriate addition to the POC for the following reasons.

The ANA's membership is a cross-section of not only American industry, but most of the major global marketers, including retailers, manufacturers, and service providers -- many of which are foreign-based corporations. The ANA has 223 corporate members and through them represents more than 7,400 separate advertising entities. Among its corporate members are such global giants as:

United States-Based Members:

American Airlines American Express Anheuser Busch Apple Computer AT&T Bristol Myers Squibb Chase Manhattan Bank Chevron Chrysler Corp. Citicorp The Coca-Cola Co. Colgate-Palmolive Compaq Delta Airlines Digital Dow Chemical Co. DuPont Eastman Kodak Exxon Federal Express

Ford Motor Co. General Electric General Motors Grand Metropolitan Hasbro Hewlett-Packard IBM Intel Johnson & Johnson KPMG Peat Marwick Lucent Technologies MasterCard McDonald's Microsoft M & M Mars Corp. Mobil Oil Corp. Motorola Norelco Northwest Airlines Panasonic Pepsico

Pfizer Phillip Morris Polaroid Procter & Gamble Reebok RJR Nabisco Rockwell International Schering-Plough Shell Oil SmithKline Beecham Sprint Texaco Texas Instruments Unocal United Airlines Upjohn Viacom Visa Warner Brothers Westinghouse Xerox

Foreign-Based Members:

Allied Dominicis Bacardi Bayer Benckiser Betts, Dearborn BMW Cadbury-Schweppes Guiness Heineken The House of Seagram's Hyundai	LEGO Loew's Nestle Nissan Sega Shiseido Saab Siemans Sony Electronics Unilever

These marketers are among the most active users of the Internet. As of last Fall, 90% of ANA members reported having at least one website, with an average of 2.5 websites per company. Forty-nine percent of ANA members reported using the Internet for their company's intranet. In the last nine months, these percentages have only increased.

The members of the ANA are not only global companies, but also own some of the most valuable global and regional trademarks and "brands" in the world. They are one of the most representative groups of the type of brand owners most affected by policy matters considered by the POC. Indeed, without their support, it is unlikely any policy will be effective. Their direct involvement, therefore, would be most productive.

The AAAA is the largest association of advertising agencies in the world. Similar to the ANA, its members are a cross-section of the advertising agency industry; local, regional and global. Among its members are the following global agencies:

Ammirati Puris Lintas BBDO Worldwide Bozell Worldwide Campbell-Ewald Messner Vetere et al. D'Arcy Masius Benton & Bowles DDB Needham Worldwide Grey Advertising

J. Walter Thompson Co. Leo Burnett Co. McCann-Erickson Worldwide Ogilvy & Mather Worldwide Saatchi & Saatchi True North Young & Rubicam

The U.S. offices of other global agencies are members as well, including:

Bates Advertising (Bates Worldwide)
DCA Advertising (Dentsu)
Euro RSCG Tatham
Hakuhodo
Lowe & Partners/SMS (Lowe & Partners Worldwide)
Publicis/Bloom (Publicis Communication)
TBWA/Chiat Day (TBWA International)
Wells Rich Greene (BBDP/GGT Worldwide)

The above agencies represent companies from the top 15 worldwide advertising agencies.

The AAAA's agencies represent many of today's global marketers, both in the United States and throughout the world. As such, their interests and expertise are essential ingredients in the proper administration of the Internet. Their members also include some of the most creative and technically savvy people in the marketing industry whose contributions would be invaluable to the POC.

Based upon the latest estimates, in 1997 ANA and AAAA members will spend more than $300 million on advertising on the World Wide Web. It is estimated that number will be as high as $2 billion by the year 2000. Those numbers do not include the costs incurred in building and maintaining websites, revenues that have been the major driving force in the growth of the World Wide Web service industry. Therefore, the ANA and the AAAA collectively represent an enormous amount of both the present and future investment in the Internet.

In sum, CASIE representation on the POC is not only advisable, but essential for a fully participatory representation on that governing body.

Response to Request for Comments

1.How many people do you think can constitute a functioning Policy Oversight Committee?

CASIE Response: 20-30.

2.Which interest classes require representation in the gTLD-MoU Policy Oversight Committee?

CASIE Response:

• End-Users [yes]
  
• Internet Service Providers [yes]
  
• Telecommunications Companies [yes]
  
• Public Interest Groups [yes]
  
• Business and Advertising Interests [yes]
  
• Content Providers [yes]

  For the reasons described above, CASIE believes one of its representatives would be a most appropriate representative of both the "Business and Advertising" and "Content Provider" classes.

• Internet Technical Infrastructure Interests [yes]
  
• Software Suppliers [yes]
  
• Trademark Community/Law [yes]
  
• Intergovernmental Interests [yes]
  
• Domain Name Registrars [yes]
  

CASIE Response:
€ End-Users [yes]

• Internet Service Providers [yes]
  
• Telecommunications Companies [no]
  
• Public Interest Groups [yes]
  
• Business and Advertising Interests [yes]
  
• Content Providers [yes]
  
• Internet Technical Infrastructure Interests [no]
  
• Software Suppliers [yes]
  
• Trademark Community/Law [no]
  
• Intergovernmental Interests [no]
  
• Domain Name Registrars [yes]
  

• Should each representative be selected from groups within a class (e.g., trade or other associations) or directly from members of that class?

CASIE Response:Representatives should be selected from groups within a class such as broad-based trade or other associations.

• What is the appropriate procedure for nominating representatives for each of the classes that you have indicated are under-represented?

CASIE Response:Interested parties should submit statements to the POC describing the interest class(es) they purport to represent. The statements should be made available to the public via the POC's Internet website.

• What is the appropriate procedure for selecting representatives for each of the classes that your have indicated are under-represented?

CASIE Response:The POC should solicit public comment for a specific period regarding the nominated representatives. After reviewing the comments, the POC should elect appropriate representatives from each interest class by a simple majority vote. If it appears that more than one representative is needed for a particular interest class, the POC should consider electing more than one representative.

• What is the length of term each representative should serve for each of the classes that you have indicated are under-represented? If desired, please include suggested mandatory term limits.

CASIE Response:The nomination and election procedure should be repeated every four years.
5.Please discuss below any other considerations vis-à-vis the structure of the gTLD-MoU Policy Oversight Committee not covered in this questionnaire.

CASIE Response:The interest classes should not be rigid. If the POC determines that an additional class or representative is needed, then the appropriate representatives should be elected.