October 13, 1997

gTLD-MoU/Notice-97-01

International Telecommunications Union

Place des Nations

1211 Geneva 20

Switzerland

Dear Sirs:

The International Trademark Association (INTA) is pleased to provide a response to the Request for Comments (RFC), Notice-97-01, issued by the gTLD-MoU Policy Oversight Committee on September 13, 1997.

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

Ans: 10 to 15.

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

Ans: In composing the IAHC, the Internet Society made an effort to include representatives from the Internet engineering community, the Internet administration community, the trademark/business community and appropriate UN treaty organizations -- ITU and WIPO. The composition of the IAHC ensured a diversity of viewpoint and approach that should be sustained, and perhaps enhanced in the ongoing policy oversight committee. It is particularly important that the traditional business community be represented as it is that community's discovery of the Internet as a medium for electronic commerce that has generated the current much of the existing stress on the domain name system, and it is that community, as well as the consumer community, for whom the intersection between the domain name system and trademarks/brands and company names is so important.

3. Which of the listed interest classes above do you think are under-represented in the

g-TLD MoU Policy Oversight Committee?

Ans: The Internet has grown beyond its academic and defense -focused origins into a major medium for international commerce. International commerce, in turn, is, and increasingly

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RFC 97-01

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will be given the opportunities the Internet presents, undertaken by mainstream businesses -- manufacturers, distributors, publishers, retailers and others -- often with customer bases worldwide. If the Internet is to serve the needs of international commerce, including businesses' interest in maintaining brand equity and investment, and consumers' interest in relying on such brand equity to identify the product, service or

company of the consumers' choice, the business community must have a significant voice in Internet domain name policy.

As noted in response to No. 2 above, this interest was represented on the IAHC, and currently is on the iPOC. INTA, an organization devoted to the protection of trademarks, is comprised of over 3,400 members from 120 countries. INTA's membership crosses all industry lines and includes manufacturers, retailers, law firms, and professional and trade associations. What this diverse group has in common, is that trademarks are a company's most valuable asset -- a simple, yet effective means of communicating with consumers in the global marketplace.

Given its unique perspective, in being an organization of trademark owners and those concerned with trademarks, worldwide, INTA has played and should continue to play a necessary role in the evolution of gTLD-MoU policy as a member of the oversight committee. INTA would, however, like to see additional representation of mainstream businesses, which might come from international associations such as the International Chamber of Commerce or broadly focused trade groups.
 
 

4. For each of the interest classes you have indicated as under-represented in the gTLD- MoU Policy Oversight Committee:

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

Ans: The answer depends on how the classes are defined, but most likely

from groups within a class.

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

Ans: Again, the answer depends on how the classes are defined, but it would likely would be most appropriate to build as much self-governance (intra-class) into the process as possible.

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RFC Notice 97-01

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(c) What is the appropriate procedure for selecting representatives for each of the classes that you have indicated are under-represented?

Ans: See (b) above.

(d) 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.

Ans: Two years.

5. Please discuss below any other considerations vis-a-vis the structure of the gTLD MoU Policy Oversight Committee not covered in this questionnaire.

Ans: No additional comments.

This concludes INTA's response to RFC Notice 97-01. If you have any questions concerning INTA's submission, please contact Geert Glas, the Association's representative on iPOC, at geert.glas@lcv.be.

Sincerely,

Sally Abel

Chair, INTA Internet Subcommittee