Hi Paul I’m not sure what URS proposal this goes to, but given the limited scope of the current exercise on the URS Individual Proposals (ie should they be included as individual proposals into a section of the initial report or not; not whether we support the actual adoption of the proposal) it seems that your comments would probably be better made as feedback on the initial report since they presumably go to the merits of one of the proposals. Apologies if I have misunderstood. Susan Payne Head of Legal Policy Valideus From: GNSO-RPM-WG <gnso-rpm-wg-bounces@icann.org> On Behalf Of Paul Tattersfield Sent: 15 January 2020 17:14 To: gnso-rpm-wg <gnso-rpm-wg@icann.org> Subject: [GNSO-RPM-WG] Further to last week’s call - Premium names Dear Griffin, As promised on last week’s call attached is an example of why ICANN’s flawed thinking on which the new RA is founded is so problematic. It’s pretty obvious that IP interests outside of ICANN contracted parties were much better served under the uniform standard pricing of ~$8 per domain/year model together with the occasional use (or threat of use) of the RPMs to manage the nuisances. Until recently “premium names” only affected the ICANN new gTLD bubble and the impacts were pretty much contained, however ICANN GDD is rolling out the same flawed RA model to older more established gTLDs like .org and .info. It is therefore possible the same (totally unnecessary) impacts will increasingly affect a much larger group of rights holders over time. This not only creates a framework disconnect between millions of premium names being outside the reach of URS/UDRP as they are not registered and people who have actually paid for names for genuine, non competing, non infringing future projects. It also underscores the disconnect between UDRP/URS & domestic judicial systems and the injustice of subjecting those same registrants to the risk of having to expend time and money defending vexatious claims premised on an allegation of passive holding. Yours sincerely, Paul ________________________________ The contents of this email and any attachments are confidential to the intended recipient. They may not be disclosed, used by or copied in any way by anyone other than the intended recipient. If you have received this message in error, please return it to the sender (deleting the body of the email and attachments in your reply) and immediately and permanently delete it. Please note that the Com Laude Group does not accept any responsibility for viruses and it is your responsibility to scan or otherwise check this email and any attachments. The Com Laude Group does not accept liability for statements which are clearly the sender's own and not made on behalf of the group or one of its member entities. The Com Laude Group includes Nom-IQ Limited t/a Com Laude, a company registered in England and Wales with company number 5047655 and registered office at 28-30 Little Russell Street, London, WC1A 2HN England; Valideus Limited, a company registered in England and Wales with company number 06181291 and registered office at 28-30 Little Russell Street, London, WC1A 2HN England; Demys Limited, a company registered in Scotland with company number SC197176, having its registered office at 33 Melville Street, Edinburgh, Lothian, EH3 7JF Scotland; Consonum, Inc. dba Com Laude USA and Valideus USA, headquartered at 1751 Pinnacle Drive, Suite 600, McLean, VA 22102, USA; Com Laude (Japan) Corporation, a company registered in Japan having its registered office at Suite 319,1-3-21 Shinkawa, Chuo-ku, Tokyo, 104-0033, Japan. For further information see www.comlaude.com<https://comlaude.com>