All, I see three problems with the revisions to 2.3.7 re: Sunrise Registration -- and additions and deletions in (B) make it inconsistent with the language written by the STI, and the review and recommendations of the RPM PDP WG – Phase 1: 1) 60 days is a too long time to allow for a TMCH DRP -- far longer than UDRP and URS response times involving much more difficult responses. I'm sure the TMCH can determine whether a challenged Trademark Record is invalid in a much shorter time – most TM records are online -- and 60 days is too long to keep an important (and available) domain name from the public. [2.3.7 (B)] 2) After the conclusion of a challenge by the TM Holder or TM agent, it appears that everything can linger for 60 days. By the wording, even if the TMCH DRP is concluded or the Sunrise Registration is deemed invalid, whichever path is taken, this section sounds like everyone can wait around a long time and eventually delete the Sunrise Registration. But this is the Internet, and we work quickly. The invalid Sunrise Registration must, of course, be deleted immediately after the challenge is concluded because we’re headed into General Availability and the domain name must be available to the public for registration. [2.3.7 (B)] 3) *Which leads us to the surprising deletion at the end of the section: “and return the domain name to the pool of available names available for registration. A Registry Operator may, through the Registry-Registrar Agreement its agreement with registrars, instead require the registrar to perform this implementation step.”This sentence is the whole purpose the section – to return the domain name to the available pool and allow it to be registered by someone who needs and can use it./Sunrise gives TMCH registrants a first right to register in the Sunrise Period, but not a wholesale removal of the domain name from registration./* Of course, domain names, if invalidly registered during the Sunrise Period must be returned to the pool of available names – that’s a key element of the fairness and balance of the TMCH and Sunrise Registration processes; they are limited for a reason. Returning appropriate domain names to the pool of domain names in New gTLDs is a) policy and b) good for Registries, Registrars, Registrants, and ultimately the end users who will use their websites, emails, listservs+. This final sentence is absolutely key to achieving the goals and intents of the RPM PDP WG; to change it is to change policy.(However, if I have misunderstood or misread this deletion, please clarify for me and for all.) `v Best, Kathy On 12/9/2025 1:19 PM, Lars Hoffmann via SubPro-IRT wrote:
Adding the IRT mailing list.
Thank you, Kathy.
Here is the link to the document: https://docs.google.com/document/d/1rDcaY1nPkfwcHpuhI74OY13rp5g99iI2/edit
Best wishes. Lars
*From: *Kathy Kleiman <Kathy@KathyKleiman.com> *Date: *Tuesday, 9 December 2025 at 10:09 *To: *Lars Hoffmann <lars.hoffmann@icann.org> *Subject: *[Ext] Question - TMCH
Hi Lars,
I think we are on a deadline today for TMCH changes/review. Is that right? Could you kindly point me to the right email or date to review it? I've been on a long bit of travel for a workshop and speaking.
Best and tx, Kathy
On 12/9/2025 11:53 AM, Lars Hoffmann via SubPro-IRT wrote:
Dear IRT members,
For Thursday’s call (11 December, 10:00 UTC), we have the following agenda items
1. Welcome and SOI 2. Surplus/Deficit Discussion (see attached paper) 3. AGB Updates 4. AOB
Attached you find a paper outlining ICANN’s approach to the surplus/deficit issue. Feel free to review before the call and share any thoughts, questions etc. on-list.
*Please note, as mentioned today’s call, the **Name Collision procedures**will now be covered on a yet-to-be-scheduled call on Tuesday 16 December 2025*.
Thank you all and best wishes, Lars
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