IP: WIPO recommendations - U.S. Small Business Administration comments

[Dave Farber <farber@cis.upenn.edu>]

>\Date: Fri, 21 May 1999 17:36:16 +0900
>To: apple@apnic.net
>From: ajp@glocom.ac.jp (Adam Peake)
>
>http://www.icann.org/comments-mail/comment-ip/msg00054.html
>
>Comments on WIPO's final report on domain names, Office of Advocacy,
>U.S. Small Business Administration.
>
>Basically - delay adopting WIPO recommendations.
>60-90 days plus time to fully consider the comments filed takes us
>into the period when the DNSO and first elected board should be formed.
>GOOD!
>
>Can ICANN ignore this advice and adopt any of the recommendations?
>
>Conclusion from submission follows.
>
>Adam
>
>
>Conclusion
>Advocacy believes that ICANN did not provide reasonable notice for
>the solicitation of comments in violation of ICANN's bylaws and the
>APA. Advocacy requests that ICANN clarify its notice and revise the
>comment period to allow 60 to 90 days for commenters to respond.
>Also, Advocacy requests that ICANN postpone a final decision until
>it has had the opportunity to fully consider the comments filed.
>
>In response to WIPO's Final Report, Advocacy believes that the
>dispute resolution process recommended by WIPO in its Final Report
>strikes a fair balance between the interests of intellectual
>property owners holders and small businesses if the limitations on
>what qualifies as abusive registration is left intact.  Finally,
>Advocacy recommends that ICANN refer famous and well-known mark
>exception to the DNSO for further comments.
>
>Respectfully submitted,
>
>Eric E. Menge
>Assistant Chief Counsel for Telecommunications
>
>Office of Advocacy
>U.S. Small Business Administration
>409 3rd St., S.W.
>Suite 7800
>Washington, D.C.  20416
>Phone:  202-205-6949
>Fax:  202-205-6928
>E-mail:  eric.menge@sba.gov
>
>May 20, 1999
>
>
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