Coalition for Responsible Internet Domain Oversight

Type:	Advocacy Initiative
Industry:	Internet
Founded:	November 2011
Founder(s):	ANA
Headquarters:	New York
Country:	USA
Website:	crido.org
Key People
Dan Jaffe, ANA EVP for Government Relations

The Coalition for Responsible Internet Domain Oversight (CRIDO) is an advocacy organization created by the Association of National Advertisers on November 2011 to stop the International Corporation for Assigned Names and Numbers in implementing its latest program to expand the number of top level domain names (TLDs) in the Domain Name System scheduled on January 12, 2012.

Backgound

ANA/Brand Owners Opposition to the new gTLD Program

On August 4, 2011, ANA President and CEO Robert Liodice wrote to Rod Beckstrom, President of ICANN regarding the new generic top level domain names (gTLDs) program that was approved by the ICANN Board on June 20, 2011 . In his letter, Liodice pointed out that the 400 member companies of ANA strongly opposed ICANN's plan to add unlimited number of TLD. The organization believed that the program does not provide benefit to the internet community but it will only cause harm and damage to brand owners and to consumers. According to him, once the program is implemented it will increase the incidence of cybersquatting and other cyber crimes. He cited that ANA conducted a research and found that the proposed TLD expansion is not supported by majority of businesses, consumers, academics including private and government agencies. He also quoted the statement of former ICANN Chairman Esther Dyson that the new program is "way for registries and registrars to make money, there are huge issues, it is offensive and will create a lot of litigation." In addition, Liodice enumerated some sections of the Economic Considerations in the Expansion of Generic-Top Level Domain Names, Phase II Reports: Case Studieswherein the experts opined that there is no scarcity of gTLds, the last ICANN TLD expansion provided little benefit thus it was a failure and the implementation of new TLD expansion may result to the following economic harms:

• Misappropriation of Intellectual Property
• Defensive Registrations
• Domain Navigation Dilution
• Increased Cybersquatting
• Reduced Investment by Intellectual Property Owners
• Losses from Failed TLDs

Liodice also claimed that international international internet governing body violated its Memorandum of Understanding with the Department of Commerce as well as the Affirmation of Commitments and the ICANN Code of Conduct. Despite Liodice's strong criticism to ICANN, he expressed the willingness of ANA to work collaboratively with ICANN to develop better solutions for the benefit of the entire internet community such as the systematic and one by one implementation of TLD. However if ICANN disregards the concerns raised by brand owners through ANA and push through with the implementation of the new gTLD program, ANA will take all measures to prevent it.

ICANN Response to ANA/Brand Owners Opposition

On August 9, 2011, Beckstrom sent ICANN's response to the issues raised by brand owners through Liodice. In his correspondence, Beckstrom defended that the new gTLD program as developed the entire ICANN community worldwide based on a multi-stake holder model in accordance with the internet governing body's core value and responsibilities set forth in the Affirmation of Commitments. Beckstrom described Liodice's letter as "incorrect and problematic in several respects." He stressed that the new gTLD program received a strong consensus internationally and approved by a super majority vote from the members of the Generic Names Supporting Organizations. The ICANN community spent 6 years in developing and planning the policy for the new gTLD program by conducting different measures such multiple public meetings and comments to ensure the security, stability and resiliency of the internet.He pointed out that Liodice's letter demonstrated lack of understanding about the program when he said it is an unrestricted expansion. According to Beckstrom, if Liodice conducted further research, he should have learned the following:

• restrictions on delegation rates
• string requirements and limitations
• required applicant background, financial and technical qualifications
• objection processes for infringing and other inappropriately applied-for strings
• standing registry operator obligations in the registry

agreement He also criticized Liodice's allegations that the new gTLD program will result to "enormous financial burdens" and argued that the quotations he used from the economic studies were biased with unsupported conclusions that more domain names will be exposed to heightened cyber security attacks and violations of consumer privacy. He explained that ICANN formed a team of international experts who developed innovative safeguards against trademark abuses and malicious internet practices. In addition, the concerns of Intellectual Property stakeholders were well documented and the ICANN Board created a team of 18 IP experts, the Implementation Recommendation Team to create additional Rights Protection Mechanisms (RPMs) such as:

• Creation of a Trademark Clearing House
• Implementation of the Uniform Rapid Suspension (URS)
• Establishment of Requirements for Maintenance of a “thick” Whois Database in all new gTLD Registries
• Establsihment of Post-Delegation Dispute Mechanism to Attach Liability to Registry Operators

Moreover, Beckstrom pointed out that ANA's stated concerns submitted on Decemebr 15, 2008 regarding trademark protection,transparency of applications and registration information, fees, general process issues and gTLDs were carefully considered and addressed by ICANN. Beckstrom strongly expressed that "ICANN will vigorously defend the multi-stakeholder model and the hard-fought consensus of its global stakeholder participants" He also said that ANA is welcome to participate actively in ICANN development processes.

Establishment of CRIDO

Following the exchange of letters between the two organization, ANA led the establishment of CRIDO to stop ICANN in implementing the new gTLD program. Its membership is composed of 87 companies and associations.. CRIDO sent a petition to the Department of Commerce objecting the proposed TLD expansion program. The latest signatories to the petition is composed of 49 associations and 54 companies including major brands such as Adidas, Dell Inc.,Toyota, Walmart etc. A complete list of petitioners can be found here

Top-Level Domain