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RE: TM Sunrise +20 (Re: [wg-b] WG-B Report -Take II)

I support the sunrise proposal as a fair and reasonable balance of the
trademark and non trademark interests in domain name ownership.

Steve Hartman
Nabisco, Inc.

No doubt.

A very casual search of the uspto database shows that Nabisco has over 882
U.S. trademark registrations, which
if true, means that during the "sunrise +20," Nabisco would be able to
register up to 18,522 domain names -- per TLD.

I was under the impression that the IPC, of which Nabisco is a member, was
*against* hoarding.

The question arises, how does this hoarding comply in any way with
"legitimate noncommercial or fair use of the domain name" ... ?

Also Ellen Rony wrote that the IPC Proposal, "... would immediately provide
for potential exclusion of twenty million [domain names] for U.S. trademarks
alone."  (Keep in mind, it's taken 20 years for Network Solutions to reach a
registration base of ten million domain names.)

The Trademark Lobby says it is "protecting the consumer."  How is the
Trademark Lobby "protecting the consumer" by usurping *twenty million*
domain names for storage in its private coffers?**


**The "consumer" is the 23 million small businesses in the United States in
1998, who represent more than 99 percent of all employers in this country.

The "consumer" is the 52 percent of private workers and 38 percent of
high-tech works employed by "consumer"-owned small businesses.

Virtually all of the net new jobs in the United States, staffed by
"consumers", were provided by "consumer"-owned small businesses.

"Consumer"-owned small businesses use of the Internet is rapidly expanding.
In the past two years, "consumer"-owned small businesses with access to the
Internet has doubled from 21.5 percent to 41.2 percent.  Thirty-five percent
of "consumer"-owned small businesses maintain a Web site and one in three do
business transactions through their site.

Statistics source: Comments of the Office of Advocacy, U.S. Small Business
Administration, DNSO Working Group A Final Report to the ICANN Board, August
25, 1999