[PC-NCSG] A balanced approach to RPMs for trademark holders, noncommercial registrants and everyone else

[Kathy Kleiman]

Hi Amr and All,
I greatly appreciate the leadership you are providing and the time you 
are about to spend revising the "RPM" Charter. I have reviewed the draft 
charter anything and, if anything, I am more concerned than before about 
the one-sided goals of the Draft Charter -- all intellectual property, 
all the time. There is nothing in the "Background," "Mission and Scope," 
"Objections & Goals," "Deliverables and Times Frames" about fairness, 
balance, or protection of the rights of Both registrants (noncommercial 
and commercial) and intellectual property owners.  It's all intellectual 
property all the time -- and that will make our job to fight for balance 
almost impossible. So your role in the next few days will be key - and 
invaluable.

To help in this process, I share additional ideas below -- knowing that 
there are at least 3 people on the BC/IPC side who care deeply about 
balance and know the laws that protect free speech and fair use - within 
trademark and other intellectual property laws - intimately. **I think 
we have to do farther than my initial suggestions, and I share more below.**

1. The STI (Special Trademarks Initiative that drafted the GNSO final 
text on the Uniform Rapid Suspension (URS) and Trademark Clearinghouse 
(TMCH) and Trademark Notice (TM Notice) intentionally, specifically and 
fully embraced the need to balance the rights of trademark holders and 
all other rights that a registrant might have (including free 
speech/freedom of expression, fair use, trademark infringement AND "the 
legitimate use of domain names" and "fair notice, justice, and due 
process."  Konstantinos, Robin, Wendy and I fought for those words and 
this clear balance -- but the rest of the Issues Work Team supported us 
as did the GNSO Council which adopted this balanced goal, language and 
mission unanimously. I include it below.

EXCERPT FROM Special Trademark Issues Work Team Recommendations, 
http://gnso.icann.org/en/issues/sti/sti-wt-recommendations-11dec09-en.pdf
***
"UNIFORM RAPID SUSPENSION PROCEDURE
There is consensus among the members of STI that creation of a Uniform 
Rapid Suspension (URS) procedure would be a beneficial rights protection 
mechanism for inclusion in the New GTLD program. The STI recognizes that 
the URS could provide trademark holders with a cost effective, expedited 
process in instances of clear cut instances of trademark abuse, provided 
_that the procedure includes appropriate safeguards to protect 
registrants who engage in legitimate uses of domain names. _Despite the 
expedited nature of the URS, Staff shall recommend a uniform procedure 
for and URS Service providers _that shall provide procedures consistent 
with fair notice, justice, and due process." _[emphasis added]/

/*2. It's not "intellectual property rights," it's trademark rights. **
*

*Since the beg**inning of the UDRP process, we **limited policies to 
trademark **issues **only**, **not all "intellectual property"****(which 
include **cop**yright and pat**ent **rights**). **Thus, the **UDRP, URS, 
**_Trademark _**Clearinghouse and **_Trademark _**Claims policies 
**protect **only to trademark holders -- despite huge efforts to expand 
the rights to all "intellectual property" owners in every past R**PM 
**PDP. **Thus, i**t is **disingenuous today for **staff to **draft this 
**charter with **"intellectual property owners" named eve**rywhere and 
not stick with the limi**tation of the UDRP, URS**, + **-- which is only 
trademark owners. To allo**w this would result in giving **copyright 
right holders A  Whole New Entrance Into this upcoming RPM Policy 
Development Processes**-- and one **to which they are not entitled. **
*

*We need your help **to co**ntinue the fight of the last 16 years, and 
limit this R**P**M**stric**tly and only to trademark rights. (**If you 
would like me to share more detailed reasons, I am happy to**, but 
ch**ief **among that is tha**t only trademarks **can be invoked by 
**domain names****disputes. **Copyright**s have to **do with content 
issues - of webpages, etc.**- beyond the scope of ICANN's narrow mission 
and mandate.**)****They've tried this huge rights exp**ansion atte**mpt 
before -- **PLEASE **DON'T GIVE IT TO THEM NOW. **All "Intellectual 
Property" must be changed to "**Trademark." Tx you!!!]**
*

**
3/. /*Current "**Background" language is: *

"The question of who legally has rights to, or is the legitimate holder 
of, a domain name can be open to dispute. In relation to domain name 
disputes concerning the registration and use of legally protected 
trademarks, the Uniform Dispute Resolution Policy (UDRP) is the longest 
standing alternative dispute resolution procedure. As a result of the 
New gTLD Program, several new rights protection mechanisms (RPMs) were 
developed to mitigate potential risks and costs to trademark rights 
holders that could arise in the expansion of the gTLD namespace: the 
Uniform Rapid Suspension System (URS); the Trademark Clearinghouse 
(TMCH) and the associated availability through the TMCH of Sunrise 
periods and the Trademark Claims notification service; and the 
Post-Delegation Dispute Resolution Procedures (PDDRPs)." /In all of 
these dispute mechanisms, the rights of the domain name registrant and 
gTLD registry are also taken into account, including their ability to 
participate fairly and the mitigation of risks of harrassing and 
unwarranted claims. [Italics = KK proposal to add some balancing 
language - I think we need more.]
/

/==> /If I were to rewrite this, I would say: **Since the beginning of 
open domain name registration, the Internet Community has operated on a 
"first-come, first-served" basis. Everyone had access to available 
domain names, and if problems arose then challenges could be brought. 
The initial legitimate holder of a domain **is the registrant** unless 
proven otherwise. Any process to remove a domain name from a gTLD 
registrant must have fair notice, justice and due process written into 
its rules, as set out in the UDRP the longest standing alternative 
dispute resolution procedure. It must also balance trademark rights with 
the rights of free speech/freedom of expression and legal protections 
for "fair use" including criticism, competition, noncommercial use and 
commercial use in completely different categories of goods and 
services... **

/[NOTE: Working Group 2 -- on Famous Marks - REJECTED "famous marks" 
protections for trademarks because there was no international treaty in 
which nations broadly agreed to comply by a common set of principles. So 
we are working with basic trademark rights **and limitations** as agreed 
by treaty, practiced by federal law and well-known. You simply can't 
stop me from naming my dog Orange and setting up a website at 
www.orange.dog simply because Orange Telecom is a huge company in 
Europe. Trust me - WIPO tried that already and lost.//]/

*3. Current "Mission and S**cope" language is:
*


This PDP Working Group is being chartered to conduct a review of all 
RPMs in all gTLDs in two phases: Phase One may focus on a review of all 
the RPMs that were developed for the New gTLD Program, and Phase Two may 
focus on a review of the UDRP. The Community in its public comments was 
split on whether this order makes sense given that the UDRP is the 
ordest consensus policy of ICANN and may be the best place to begin an 
overall RPM review. This is an issue for initial evaluation and decision 
by the WG as no consensus as yet been reached in the Community. ,In all 
events, by the completion of its work, the Working Group will be 
expected to have also considered the overarching issue as to whether or 
not all the RPMs collectively fulfill the purposes for which they were 
created, or whether additional policy recommendations are needed, 
including to clarify and unify the policy goals.

==> I would rewrite this opening paragraph of the section as: /This PDP 
Working Group is being chartered to conduct a review of all RPMs in all 
gTLDs for their fairness and balance, effectiveness in protecting the 
rights of domain name registrants and trademark owners, whether 
continuation is required, and whether the fairness, protections, 
justice, notice and due process hoped for by the drafters is being 
achieved in the implementation.  Are the UDRP, URS and other new gTLD 
RPMs fair and being fairly implemented?  [Then the details of UDRP and 
URS, including the edits I proposed, could be included. As written, it 
is currently only a laundry list of policies and not a true Mission and 
Scope statement for goals, so the Draft Charter needs the definite and 
goal set out above to be fair and balanced in the objectives of the PDP.] /

4. *Current "Objectives and Goals" language:*

In addition to an assessment of the effectiveness of each RPM, the PDP 
Working Group is expected to consider, at the appropriate stage of its 
work, the overarching issue as to whether or not all the RPMs 
collectively fulfill the purposes for which they were created, or 
whether additional policy recommendations are needed, including to 
clarify and unify the policy goals. If such additional policy 
recommendations are needed, the Working Group is expected to develop 
recommendations to address the specific issues identified.

The Working Group is also directed to bear in mind that a fundamental 
underlying intention of conducting a review of all RPMs in all gTLDs is 
to create a framework for consistent and uniform reviews of these 
mechanisms in the future.

==> I would rewrite this opening sentence of the section as: /Our goal 
here is the assessment of the fair implementation and balance of the 
policies developed -- are all parties from registrants to intellectual 
property owners treated in a fair, just and equitable manner? The PDP 
Working Group is expected to consider whether the rights of trademark 
owners and registrants are being balanced properly and fully protected...
/

5. *Current "Deliverables and Timeframes" language is: *

"In addition to the PDP deliverables prescribed in the ICANN Bylaws and 
the PDP Manual, the Working Group shall provide a first Initial Report 
to the GNSO Council at the conclusion of Phase One of the PDP. The 
Report shall be put out for public comment and also inform the GNSO 
Council about the progress of the Working Group. At a minimum, the 
Report shall outline the Working Group?s progress and any preliminary 
recommendations it may have developed with regard to whatever it chooses 
to evaluate first: the UDRP or the new gTLD RPMs. The first Initial 
Report shall also highlight any relevant findings, information or issues 
that may have emerged during Phase One and any issues or recommendations 
that the Group believes should be considered by the PDP Working Group on 
Subsequent Procedures, and/or that the Working Group considers relevant 
to its work in Phase Two.

Phase Two of the PDP Working Group shall focus primarily on the second 
half: the New gTLD RPMs or UDRP (whatever is left). However, during this 
Phase the WG is also expected to review its first Initial Report, taking 
into account public comments received, and/or feedback submitted from 
the New gTLD Subsequent Rounds PDP or other ongoing efforts."

==> I would rewrite this opening sentence of this section to be: /In 
addition to the PDP deliverables prescribed in the ICANN Bylaws and the 
PDP Manual, the Working Group shall provide a first Initial Report to 
the GNSO Council regarding the balance and protection of rights of both 
trademark owners and registrants and additional steps necessary to 
protect the rights of each.... /


6. Conclusion:
I hope I provided some useful guidance. I am certainly losing sleep - 
and thank you for all of your efforts on this. Please let me know what I 
can do to help - including short memos on legal issues, editing in the 
background, etc.

Best regards,
Kathy




On 2/21/2016 8:37 AM, Amr Elsadr wrote:
> Hi again,
>
> Some more follow-up to this issue;
>
> First of all, Kathy had mentioned during the last monthly NCSG policy call redline changes she made to the draft charter, and she was wondering whether she should share it with the PC. I?ve attached it to this email for folks to consider.
>
> Second, in its last meeting, the Council asked that a sub-team of volunteers be formed to try to resolve the disagreements on this charter and have it ready in time for a motion to be submitted for the public Council meeting scheduled to take place in Marrakech. This team has been formed, and now consists of Phil Corwin, Susan Kawaguchi, Heather Forrest, Paul McGrady and myself. The sub-team is scheduled to hold a number of consecutive calls to try to work through this on:
>
> February 22nd
> February 23rd
> February 25th
> February 26th
>
> I will try to keep you all up-to-date with events as they unfold on this group.
>
> Thanks.
>
> Amr
>
>
>
>> On Feb 9, 2016, at 6:01 PM, Amr Elsadr <aelsadr at egyptig.org> wrote:
>>
>> Hi again,
>>
>> I realised after sending this email that I didn?t attach the draft charter, so I?ve attached it to this email.
>>
>> I also noticed that I addressed the last email to Kathy (really grateful for all the work you put into this for us all Kathy), but the majority of the message below was of course directed to the entire PC.
>>
>> Apologies folks. :)
>>
>> Amr
>>
>> <Updated draft Charter for RPM PDP - 6 Feb 2016.docx>
>>> On Feb 9, 2016, at 5:58 PM, Amr Elsadr <aelsadr at egyptig.org> wrote:
>>>
>>> Hi Kathy,
>>>
>>> Thank you very much for this. I completely agree that we cannot make compromises on this, nor do I think it right that we be asked to do so.
>>>
>>> Anyway?, I?ve pretty much hit a stone wall on this. I?ve been working very closely with both Mary and Lars on getting this done, and there have been some significant improvements to the charter, however, there have also been some setbacks. I will try to go through some of the changes that have been made, and I would be happy to answer any questions.
>>>
>>> 1. First, the good. So the list of concerns raised by the NCSG (along with everybody else?s) have been moved to the charter itself, as opposed to only being included in an annex to the issue report. I?ve attached the latest version of the charter to this email, so please take a look. This includes the issue of reverse domain name hijacking as well as other topics that the NCSG raised in our comment on the preliminary issues report.
>>>
>>> 2. Now the bad. Unfortunately the language under ?mission and scope? as well as ?timeframes and deliverables? which details the 2-phase approach has been returned to its original state of phase 1 reviewing the new gTLDs RPMs followed by phase 2 to review the UDRP. The reason staff decided it was best to do this, is that they were uncomfortable making a significant change like this without including the entire Council in the discussion that would result in this change. I can?t say that this logic is flawed. It wouldn?t be particularly acceptable for one councillor to work unilaterally with staff to make changes to a charter already presented to the Council without the knowledge of the rest of the councillors. My advice now is that we take up the change to the charter originally suggested by staff; that the PDP WG members be allowed to determine their own work plan, including how the 2-phase approach should be conducted with the GNSO Council, and ask that these changes be formally adopted.
>>>
>>> Still?, as I couldn?t agree to propose a motion to adopt an issue report/charter that clearly conflicted with the NCSG?s view, I have informed staff that they will need to get another councillor to do this. So James Bladel proposed a motion to adopt the issue report for this PDP, but only the issue report (not the charter). He recommended that the charter be put on the Council?s agenda as a discussion item during our next call. I had previously also discussed this with staff, and agreed that it would be a good idea to de-link the two documents. This, I believe, is pretty good for us. We should make our case on the charter to the Council, and ask for the flexibility required for the WG to be able to determine the methodology by which this PDP is addressed. Check out the email sent by James B. here: http://gnso.icann.org/mailing-lists/archives/council/msg18076.html.
>>>
>>> Anyway?, that?s pretty much where things are at the moment. Like I said, I?d be happy to answer any questions, and also look forward to ideas on how folks believe we should tackle this issue.
>>>
>>> Thanks.
>>>
>>> Amr
>>>
>>>> On Feb 6, 2016, at 5:46 PM, Kathy Kleiman <kathy at KATHYKLEIMAN.COM> wrote:
>>>>
>>>> Amr,
>>>> First, I truly, truly appreciate all you are doing on this. Second, I would really need to sit down with you and go through the Staff Report and our extensive comments -- and I can do that after Tuesday. But third, I am concerned about putting most of the NCSG concerns/issues/ideas in the Annex B/Potential Issues to be Reviewing -- "kitchen sink" category.  Every WG has the core issues that it is forced to address and then other issues it may address. In my experience, WG virtually never get to the issues they "may" address -- only the core issues they MUST address because that is already overwhelming.
>>>>
>>>> This WG MUST be asked to assess what happens when trademark owners abuse the system (reverse domain name hijacking); they MUST assess whether the "procedural rules" voluntarily adopted by the arbitration WITHOUT GNSO OVERSIGHT are and have been fair and neutral or help largely those who chose and pay them (the trademark owner/complainants). There are more in our list/our comments that involve fairness and balance - freedom of expression & fair use versus Rights Protection Mechanisms.
>>>>
>>>> In fact, that should even be reflected in the title. If we are only dealing with Rights Protection Mechanisms, then by the title, we only listen to one side. Why can't even the title of this WG be balanced?
>>>>
>>>> Question: so the staff is Not Mandating that we do URS/TMCH first -- but that the WG can decide for itself whether it does UDRP or URS/TMCH first?  That would be OK. The reason I ask is that IPC wants few changes to UDRP and all of them to URS -- which is a hugely unfair, no-due-process system in and of itself (which is why we, NCSG, made it so, so narrow).  UDRP is the system with a) fairer notice b) fairer time for Panelist evaluation. Go to URS first and all the IPC wants is "transfer" -- moving a losing domain name to themselves: virtually no fairness and no due process.
>>>>
>>>> The best way (and virtually the only way) to defend registrants is to assess the UDRP first, make it fairer for all, and then look at the URS (which will seem trivial in comparison). Do it the other way, assess the upper floors of the building before evaluating the foundation, and you have to put a lot more changes into the upper floors.
>>>>
>>>> I will be offline this weekend through Tuesday, but happy to talk, work, support, research as of Wednesday -- if that is OK.
>>>>
>>>> I don't think we can compromise with procedure, Amr, because in it lies all we care about....
>>>> Best and huge tx,
>>>> Kathy
>>>>
>>>>
>>>> On 2/3/2016 2:30 PM, Amr Elsadr wrote:
>>>>> Hi,
>>>>>
>>>>> I never received this message in my inbox, so resending.
>>>>>
>>>>> Thanks.
>>>>>
>>>>> Amr
>>>>>
>>>>>> On Feb 2, 2016, at 5:17 PM, Amr Elsadr <aelsadr at egyptig.org> wrote:
>>>>>>
>>>>>> Hi,
>>>>>>
>>>>>> I wanted to follow up on this thread. Following my withdrawal of the motion to launch the RPMs review PDP, I?ve been working with staff to address NCSG's concerns. Specifically, the discussion has been on issues identified in the NCSG comment on the preliminary issues report that were not included in the final report, in addition to the 2-phase method approach to working through this PDP; with a review of the RPMs developed for the new gTLDs being conducted before the the review of the UDRP. This is what we came up with:
>>>>>>
>>>>>> First, the issues identified by the NCSG will be included in the Annex B of the final issues report (http://gnso.icann.org/en/issues/new-gtlds/rpm-final-issue-11jan16-en.pdf). These issues have already been documented in the staff report of the public comments. NCSG?s comments begin on row 68 of the table found here: https://www.icann.org/en/system/files/files/report-comments-rpm-prelim-issue-02dec15-en.pdf. Including these in Annex B places them in the ?List of Potential Issues for Review? to be discussed by the PDP WG.
>>>>>>
>>>>>> Second, on the methodological approach, I?ve agreed with staff that the charter will be amended to inform the PDP WG that there were divergent views on the method to follow. The same two-phase method will still be the method outlined in the charter, however, the charter will instruct the WG to develop a work-plan, and in doing so, consider reviewing or amending the method while discussing the views of different stakeholders.
>>>>>>
>>>>>> I would appreciate feedback on this now, so that I have a clear picture of the views on this before proceeding with this item of Council business. Personally, I believe this is a fair compromise. I hope I?m not missing anything.
>>>>>>
>>>>>> Thanks.
>>>>>>
>>>>>> Amr
>>>>>>
>>>>>>> On Jan 19, 2016, at 5:17 PM, Kathy Kleiman <kathy at KATHYKLEIMAN.COM> wrote:
>>>>>>>
>>>>>>> I support deferral - and substantial re-write. As you know there are *many* things missing from this report that we advocated -- or thrown into a remote corner of the "miscellaneous" section and unlikely to be visited or reviewed by any WG.  Reverse domain name hijacking -- something I wrote into the original UDRP - is now a not-infrequent finding of UDRP (hooray!)  It's trademark owner's bad faith and improper action and yet there is no penalty -- and it is time to impose one.  A Registrant engages in bad faith - loss of domain name; a large brand owner - nothing. Hmm...
>>>>>>>
>>>>>>> But Amr, just because something should be heard does not mean it has to be heard now. It is a zero sum game and the Whois2 is already rolling. We cannot create more people or time.  We can only create a flow of work that does not a) kill or b) drive away any and everyone with the skills to work on it.
>>>>>>>
>>>>>>> Best,
>>>>>>> Kathy
>>>>>>>
>>>>>>> On 1/19/2016 7:52 AM, Amr Elsadr wrote:
>>>>>>>> Hi Kathy,
>>>>>>>>
>>>>>>>> Thank you very much for this. I very much agree with you; that the final issue report is poorly balanced in favour of trademark concerns including the two-phased approach. Apart from that there are some issues that the NCSG asked to be included in the final report that (as far as I can tell) are not in it or the draft charter. Examples include reverse domain name hijacking not being included in the draft charter, expanding roles of RPM providers beyond the scope of their work?, and others.
>>>>>>>>
>>>>>>>> I will, however, try to answer your question on why I submitted this motion. From a procedural perspective, it doesn?t really matter who submits the motion. Issue reports (preliminary and final) are prepped by staff, and need to be reviewed by council. The GNSO operating procedures describes the rules and timelines concerning how these are submitted and managed, and it?s all pretty straight forward. Staff prepared the final issues report for this PDP only a couple of hours before the deadline to submit motions for the January 21st council meeting. They needed a councillor to submit the motion so that the report may be formally considered, and they asked me. Procedurally, it didn?t strike me as a problem to agree. I did, however, make it clear on the council email list that the report was delivered very close to the deadline, and that I had not had a chance to review it prior to submitting the motion, so submitting the motion did not indicate any support for it, but rather agreeing to a staff request. I also immediately forwarded the email and report to both you and Tapani to make sure you knew this was happening. I?m glad I did that. :)
>>>>>>>>
>>>>>>>> I look forward to discussing this motion on today?s NCSG call, along with other important motions. My suggestion would be for one of our councillors to request a deferral of this motion (as opposed to holding a vote on it), and pointing out what we feel is problematic with it, particularly the draft charter. My hope is that we can give staff clear instructions on what needs to be amended in the report/charter before it comes up for another vote.
>>>>>>>>
>>>>>>>> On the other hand, I am divided on whether or not it is reasonable to indefinitely delay this PDP. I appreciate the limited amount of time our members have to volunteer on this and other PDPs and CCWGs. It certainly seems impractical to me to delay this until after the new gTLDs subsequent rounds and WHOIS2 PDPs are done. Apart from the UDRP, the other RPMs are not consensus policy developed by the community, but rather forced on us by staff. This (IMHO) always needed to change. Seems to me like this is especially necessary now that a subsequent round of new gTLDs is being discussed.
>>>>>>>>
>>>>>>>> Those are some of my thoughts, and I would certainly appreciate hearing more on this.
>>>>>>>>
>>>>>>>> Thanks again, Kathy.
>>>>>>>>
>>>>>>>> Amr
>>>>>>>>
>>>>>>>>> On Jan 19, 2016, at 4:59 AM, Kathy Kleiman <kathy at KATHYKLEIMAN.COM> wrote:
>>>>>>>>>
>>>>>>>>> Amr and All Councilors,
>>>>>>>>> I wanted to expand on this. By separating out the UDRP and New gTLD Rights Protection Mechanisms -- and making the New gTLD Protection Mechanisms FIRST -- Staff and the IPC are ensuring that basic facts will not be heard in the right order. IPC and Staff want a stronger URS. The fact is that *even with the advent of many new gTLDs i n 2015,* the UDRP filings went down - and there were not too many URS filings either.
>>>>>>>>>
>>>>>>>>> By hearing these issues in isolation, with New gTLDs first, there will be a lot of whining about the need for a faster and more effective URS (which NCSG successfully criticized as "Accuse you lose" because it was initially so one-sided) and reforms to the URS will be forced without the full context of the UDRP.
>>>>>>>>>
>>>>>>>>> Truly, if the world were coming to an end with New gTLDs (as the IPC assured us it would be), then the UDRP filings would have gone up, not down.
>>>>>>>>>
>>>>>>>>> I think we should be voting No on this RPM Issues Report. I hope you will.
>>>>>>>>>
>>>>>>>>> Kathy
>>>>>>>>>
>>>>>>>>> On 1/18/2016 2:13 PM, Kathy Kleiman wrote:
>>>>>>>>>> Hi Amr,
>>>>>>>>>> I think we talked about this some time ago, but I don't understand why we are making the motion for the RPMs PDP initiation? Our NCSG comments said very clearly that the two-phases proposed by the IPC were Not valid - that there was no way we should review New gTLD protections because a) still pretty early and b) UDRP is the trunk of the tree. Why should we evaluate the branches when we need to evaluate the health of the entire tree?   Why is the world are we, the NCSG, introducing this motion?
>>>>>>>>>>
>>>>>>>>>> On other thoughts, the idea of RPM, Whois2 and New gTLD PDPs going on at the same time is a nightmare. Every other stakeholder group has professionals -- people who are paid by their companies or clients to participate in these proceedings. We don't and yet we are the ones who are called on to do the drafting, reviewing completely one-sided and self-serving proposals and organize oppositions.
>>>>>>>>>>
>>>>>>>>>> There must be something that you, Amr and our other Councilors, can do to slow this train down. If not, some of us are going to have to jump off...
>>>>>>>>>>
>>>>>>>>>> Best regards,
>>>>>>>>>> Kathy
>>>>
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