Dear Mr. Atallah and ICANN Staff, On behalf of the undersigned professors and practitioners below, I submit the attached letter in opposition to the modification by Donuts of its DPML service. This seemingly mild RSEP technical request to change the Donuts’ registry agreement (across its 300+ top-level domain names) is actually a shocking request. It would give trademark owners vastly more control over the use of words and phrases than trademark law provides or permits, and in so doing, trample the free expression rights of consumers, civil society, and even other trademark owners. Our attached letter outlines these legal and language concerns in greater detail. We strongly urge your rejection of this Donuts proposal. Sincerely, the undersigned: A. Michael Froomkin, Laurie Silvers & Mitchell Rubenstein Distinguished Professor of Law, University of Miami* Martin Silva Valent, Esq., Partner @ Silva.legal, Founder @ Datas [www.dat.as], Professor at Universidad de Palermo, GNSO Councilor at ICANN* Erik Pelton, Esq., Erik M. Pelton & Associates, PLLC Kathryn A. Kleiman, Esq., Center for Information Technology Policy, Princeton University* Leah Chan Grinvald, Associate Dean for Academic Affairs and Professor of Law, Suffolk University School of Law* * Affiliations provided for identification purposes only