The Business Constituency offers this suggestion on ICANN's proposed matching rules for names entered in the Trademark Clearinghouse.

Upon review of the possible methods for translating “@” and “&” as described in the “Explanatory Memorandum: Implementing the Matching Rules”, the Business Constituency requests that the languages for translations of “@” and “&” be chosen on a per-record basis by the trademark owner.

The memorandum suggests that the language of translations should be based upon the official language(s) of the trademark registry.

Restricting translations to the official language of the trademark registry is problematic, particularly for global brands or for trademarks registered in countries where there is no official language.

Furthermore, requiring that translations of “@” and “&” match the official language of the trademark registry would likely result in additional costs to brand owners for additional submissions of the same mark to the Trademark Clearinghouse.

Elisa Cooper served as Rapportuer for these comments, which were approved in accordance with the BC Charter.