My comments to Spec 13 in the attached. In sum: 1. In section 2, ICANN should not be able to later reasonably determine that a TLD no longer qualifies as a .BRAND for the same reasons that an arbitration panel overturned such decision [cid:image001.png@01DBB86E.AB6C81D0] 1. There is no Section 3 – it goes from Section 2 to Section 4. 1. As I discussed previously on the list, why should individual licensees be excluded from possible registrants if they meet the other requirements? I am guessing the concern is to avoid ROs from claiming Spec 13 status and then offering registrations to anyone. But that does not seem to be a valid concern because there is also the requirement that the trademark license “is for the use of such trademark in the regular course of that entity’s business outside of the provision of Registry Services, and is not primarily for the purpose of enabling registration or use of domain names in the TLD.” There are a number of brands where individual persons might be legitimate trademark licensees and need to use the trademark (and a domain name in the .brand TLD) as par of their regular business. For example, Realtors or individual insurance or other brokers working for a large company. Best regards, Marc H. Trachtenberg Shareholder Chair, Internet, Domain Name, e-Commerce and Social Media Practice Greenberg Traurig, LLP 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601 T +1 312.456.1020 M +1 773.677.3305 trac@gtlaw.com<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com<http://www.gtlaw.com/> | View GT Biography <https://www.gtlaw.com/en/professionals/t/trachtenberg-marc-h> [Greenberg Traurig Logo] [cid:image003.png@01DBB86E.ADB671D0] From: Karla Hakansson via SubPro-IRT <subpro-irt@icann.org> Sent: Monday, April 28, 2025 6:17 PM To: subpro-irt@icann.org Subject: [SubPro-IRT] NxR Base RA: SubPro Meeting #135 *EXTERNAL TO GT* Hello SubPro IRT, We will cover the following topics regarding the Next Round Base RA in meeting #135 tomorrow, 29 April: 1. Name Collision Report Handling, Spec 6, Sec 6.3.1 & 6.3.2, 2. Specification 13 3. Specification 14 Attached please find the redlines we will review. Also, the incorrect document is posted on the SubPro IRT wiki from our discussion on Recommendation 36.4. Until we resolve, please fine the correct redline we reviewed in meeting #134 on Thursday, 24 April. Regards, Karla
