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Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Submissions for this Proceeding

Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP)

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Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - TipTopNames
19 April 2022

Submission Summary:

I would have loved developing these points but as the period of time to answer is really short, here is my submission:

1) As an open worldwide organization, please let more time to respond to public comments. Can you extend ?

2) As a worldwide organization, ICANN should open reports and comments to other languages. This is a matter of equity.

3) Why Panelists can also be representatives of complainants or respondents ? It a...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Silla, Erika
19 April 2022

Submission Summary:

Under our associate’s view, the UDRP provides trademark holders with a quick and cost-effective mechanism.

There are relevant prior rights holders which have been left out of the UDRP system given that the UDRP is only available for trademark holders. For instance, the Brazilian UDRP-equivalent, named “SISTEMA ADMINISTRATIVO DE CONFLITOS DE INTERNET RELATIVOS A NOMES DE DOMÍNIOS SOB ".BR" - DENOMINADO SACI-Adm” (“SACI-Adm”) (available a...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Name Defend Services
19 April 2022

Submission Summary:

The UDRP process was set in place for obvious cases of trademark abuse and cyber squatting and works well for the large majority of these obvious and black and white cases. The UDRP fails entirely when Panels try to decide more complex and contested cases by applying the so called evolved laws like WIPO Overview of WIPO Panel Views on Selected UDRP Questions, Third Edition


The egregious illegality of WIPO's 3 arbitrator panel ...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Mugford, Brad
19 April 2022

Submission Summary:

The UDRP process was designed for black & white cases of trademark abuse. Most disputes seem to fall under this group.

As is, it works well for these types of clear-cut cases.

The problem occurs when you start dealing with more generic types of domains; domains with many potential uses that often have high value on the open market.

The value of these domains has risen dramatically since the UDRP policy was first created a...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Brahma University
19 April 2022

Submission Summary:

I support and adopt the views of NCSG and others like George Kirikos, Romana Busse and Col Rajendra Dalvi in their entirety, and equally demand that ICANN stop this farce of a public comment based on suppressed and manipulated data, and withdraw this report immediately. I concur that ICANN staff are incompetent and not up to the job. From what we see ICANN's entire system of public consultation is a sham and hollow formality to further the ag...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Leap of Faith Financial Services Inc.
19 April 2022

Submission Summary:

We reject the report in its entirety. It is irrevocably flawed and should be withdrawn. ICANN staff have squandered the time and resources that were allocated for this project. It should be redone in its entirety with all the missing elements mentioned in our submission taken into account, perhaps divided amongst multiple independent research groups outside of ICANN. ICANN staff simply don't have the research skills to do the job, given what w...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Hindustan Republican Army
18 April 2022

Submission Summary:

Regarding Point 2 of the consultation, it is clear and the data must so reflect it, that the UDRP is tremendously unfair to genuine non-commercial users, without trademarks, using the domains for free speech (example bloggers) or for research or for academic purposes. By raising the straw man (ghost) bogey bogus hollow argument of Chinese cyber squatters under every bed or behind every privacy protected domain name, the trade mark holders have...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Busse, Romana
18 April 2022

Submission Summary:

As a universitum academic and member of the Open / Free Libre movements, I am disgusted at the sellout of ICANN to Commercial trademark holders and total failure of unfair UDRP to protect the non-commercial non-profit small domain holders against capitalist trademark accumulators and moneybag trademark hoarder grabbers who misuse UDRP against registrants from Global South

The UDRP was proposed by the US Department of Commerce. The presen...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - International Trademark Association (INTA)
18 April 2022

Submission Summary:

The UDRP has been extremely effective in meeting ICANN’s Goals. As recognized by the Report, the UDRP was adopted by ICANN in order to provide an efficient, quick, cost-effective and fair substitute to traditional litigation for clear cases of cybersquatting. Based on the experience of its members and the data summarized by the Report, INTA believes that the Policy has been effective at targeting straightforward cases of cybersquatting a...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - PROKHOROVA, GANNA
18 April 2022

Submission Summary:

Potential amendments to UDRP

(1) The development of technologies and a vast interconnection of the world entails the rapid spreading of English as a universal language. That is why our suggestion is to supplement the Rules with the provision of English being the language of administrative proceedings as an alternative to the language of the Registration Agreement.  

(2) In disputes related to "old" domains the stat...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - NCSG
17 April 2022

Submission Summary:

As we have already declared in previous Reports related to intellectual property rights protection system (legislative, regulatory, etc.), based on state-of-the-art scholarship and reports about this thematic worldwide, questions related to balance need always to be asked when enforcing these rights.

In other words, are the rights holders protected while all the other interests involved are also being respected? Is there enough protectio...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Telepathy, Inc.
15 April 2022

Submission Summary:

The UDRP is due for an update. 


The UDRP as originally drafted has proven itself to be an effective tool for combatting cybersquatting.  Yet the UDRP should be updated to account for the changes to the DNS that have occurred in the over 20 years since it was adopted.  Further, the current version of the UDRP is a first release of a policy that has left several critical areas unaddressed for decades.


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Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - (RySG), Registries Stakeholder Group
15 April 2022

Submission Summary:

The Registries Stakeholder Group (RySG) supports the UDRP as a valuable tool for the community and has no further input for the UDRP Status Report. 


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - DIMA NABER
14 April 2022

Submission Summary:

Efficiency

The UDRP provides efficient mechanism to trademark owners to deal with domain name disputes. However, the system polices need to continue to be enhanced, updated and developed to include: 1) Domain names with clear infringement of other rights, such as copyrights, right of publicity and unfair competition resulted from bad faith conducts, ii) expedite the process of ruling in the UDRP complaints to ensure prompt remedies, iii)...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Hill, Richard
14 April 2022

Submission Summary:

This summary is in lieu of an attachment.

I have been a UDRP panelist since the inception of the scheme in 2000, am a panelist for NAF and WIPO, and was a panelist for eResolution. I am also a panelist for ADR.EU. I have been a panelist in over UDRP 800 cases and am currently handling over 100 cases/year, mostly default cases where there is obvious abuse, e.g. illegal activity such as fraud and/or phishing. At the beginning of the UDRP, ...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Maroun, Sara
14 April 2022

Submission Summary:

The procedures are clear and fair. The ability to make cross examination of evidences, documents and memos by parties meets the standard due process fairness criteria. It is worth to introduce oral hearings and ability for arbitrator(s)-panels- to meet with parties, receive their arguments, hear their evidences and brief about the case and its grounds. This can be optional based on parties request and/or based on panels’ discretion. 

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Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Suboh, Munir
12 April 2022

Submission Summary:

Efficiency. The UDRP system polices need to continue to be enhanced to include: 1) Domain names with clear infringement of other rights, such as copyrights, right of publicity and unfair competition resulted from bad faith conducts, ii) expedite the process of ruling in the UDRP complaints to ensure prompt remedies, iii) expand in the scope of panels to rule on other remedies claimed by the trademark owners, such as monetary remedies and compe...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - Chang, Ted
04 April 2022

Submission Summary:

The current UDRP procedure itself should be maintained as is without any changes. However, the closely-related URS must be discontinued.


Compared to legal courts, the much more simplified processes and lowered costs associated with UDRPs are already more than enough to benefit trademark holders while at the same time preventing excessive RDNH abuse. This is why the URS must be discontinued or at least have the fees increased t...


Policy Status Report: Uniform Domain Name Dispute Resolution Policy (UDRP) Submission - 何, 锦国
06 March 2022

Submission Summary:

If the domain name is registered earlier than the trademark, please prohibit the initiation of UDRP