The notion that the URS be focused on criminal behavior, rather than rights infringement, is an intriguing one. What a different debate we would have had if it had been proposed by the IRT with that aim. That said, I believe that such a crime-focused URS should only allow for certain types of complainants (law enforcement agencies; organizations that monitor Internet fraud and abuse; etc.) to file complaints. Do we really have time to develop such an alternative for the BC when the filing deadline is one week from today and when many of us (including yours truly) are working on multiple comment letters to be filed this month for clients/employers?

Beyond that, ICA would object to any BC statement that would seek to revive the original URS and believe that, given the passage of time and events, any BC statement should be put to vote and not based upon positions that were taken many, many months ago.

Philip S. Corwin
Partner
Butera & Andrews
1301 Pennsylvania Ave., NW
Suite 500
Washington, DC 20004

202-347-6875 (office)

202-347-6876 (fax)

202-255-6172 (cell)

"Luck is the residue of design." -- Branch Rickey

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From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Philip Sheppard
Sent: Wednesday, July 14, 2010 5:10 AM
To: 'bc - GNSO list'
Subject: [bc-gnso] DAGv4 Public Comment Period

AIM has just sent the attached to public comments (for the appropriate module).

The key proposal is to radically change the URS back to a means to prevent crime (and to rely on the UDRP for any contested rights).

BC support would be most helpful.

Philip