IP: WIPO recommendations - U.S. Small Business Administration comments

[Dave Farber <farber () cis upenn edu>]

> \Date: Fri, 21 May 1999 17:36:16 +0900
> To: apple () apnic net
> From: ajp () glocom ac jp (Adam Peake)
>
> http://www.icann.org/comments-mail/comment-ip/msg00054.html
>
> Comments on WIPO's final report on domain names, Office of Advocacy,
> U.S. Small Business Administration.
>
> Basically - delay adopting WIPO recommendations.
> 60-90 days plus time to fully consider the comments filed takes us
> into the period when the DNSO and first elected board should be formed.
> GOOD!
>
> Can ICANN ignore this advice and adopt any of the recommendations?
>
> Conclusion from submission follows.
>
> Adam
>
>
> Conclusion
> Advocacy believes that ICANN did not provide reasonable notice for
> the solicitation of comments in violation of ICANN's bylaws and the
> APA. Advocacy requests that ICANN clarify its notice and revise the
> comment period to allow 60 to 90 days for commenters to respond.
> Also, Advocacy requests that ICANN postpone a final decision until
> it has had the opportunity to fully consider the comments filed.
>
> In response to WIPO's Final Report, Advocacy believes that the
> dispute resolution process recommended by WIPO in its Final Report
> strikes a fair balance between the interests of intellectual
> property owners holders and small businesses if the limitations on
> what qualifies as abusive registration is left intact.  Finally,
> Advocacy recommends that ICANN refer famous and well-known mark
> exception to the DNSO for further comments.
>
> Respectfully submitted,
>
> Eric E. Menge
> Assistant Chief Counsel for Telecommunications
>
> Office of Advocacy
> U.S. Small Business Administration
> 409 3rd St., S.W.
> Suite 7800
> Washington, D.C.  20416
> Phone:  202-205-6949
> Fax:  202-205-6928
> E-mail:  eric.menge () sba gov
>
> May 20, 1999
>
>
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