Attachment is the full IPC Comment

The UDRP has a proven track record in mitigating consumer confusion and harm, curbing abusive domain name registration and use, and contributing to the overall security and stability of the global DNS. The ability to address cybersquatting and related abuses in gTLDs in lieu of going to court has been invaluable, leading to significant savings in resources for brand owners, registries and registrars (and frankly, registrants) who otherwise might have been dragged into more onerous litigation. The UDRP has been consistently and predictably applied over the course of its 20+ year history. As a result of its success in the gTLD space, the UDRP has been adopted (including tailored versions) by over 80 ccTLDs for use as their own dispute resolution mechanism. It is critically important that future policy work regarding the UDRP not diminish, dilute, or otherwise undermine its effectiveness. Such policy work should be deferential to and reliant on the input of experts who have actual experience working with and within the UDRP system, and resistant to efforts that would weaken the UDRP system; any such work should be based on facts and evidence of problems in need of a systematic policy-level solution, and not merely to address specific edge cases, differences of opinion, or pet issues. The IPC is committed to ensuring that the UDRP remains the global standard for DNS dispute resolution, particularly in light of ICANN’s intention to continue expanding the DNS through future rounds of new gTLDs, and notably in light of its failure to address changes to the Whois system that have made identifying bad actors and bringing effective and efficient dispute resolution actions against them far more difficult and expensive. Similarly, to address scale ("whack a mole") and cementing jurisprudential stability, questions of “front-end” (based on notice-and-takedown regulations) and appeals avenues may warrant consideration.