Criticism #2:
The Interim Report�s recommendations encourage abuse of a legitimate
domain name registrants by trademark holders
========================================================
Domain name registrants would be required to sign a legally binding
statement that their registration does not violate any intellectual
property rights, when many innocent registrants cannot possibly know
this. The mandatory submission to jurisdiction and challenge procedure
makes it easy and inexpensive to challenge registrations and does
nothing to penalize unwarranted challenges. This will encourage
trademark holders to blackmail innocent domain name registrants who
have legitimately registered a name they want. A small business or
individual consumer who registers a domain name for $50 � $100 will,
if challenged, be subjected to a risk of losing $2-3000 in arbitration
costs. Even if they think they have a good chance of winning, the risk
of loss for a small player is too large and most will simply be
intimidated into giving up. Reverse domain name hijacking by trademark
holders is a common and well-documented problem. The WIPO report,
however, refuses to acknowledge this at any point.

Criticism #3:
The Report fails to accomplish its central mission: Define and defeat
cyberpiracy
=====================================================
One can sympathize with legitimate trademark holders who have been
plagued by cyber-squatters who deliberately register large numbers of
trademarked names and attempt to re-sell the registrations. All
evidence indicates that a very small number of people account for
almost all of this kind of abusive practice (although WIPO�s utterly
inadequate attempts at evidence collection add almost nothing to our
knowledge of this phenomenon.)
The US Government White Paper asked WIPO to find a way to prevent
abusive registrations of cyber-squatters. It also asked it to steer
clear of trying to resolve character string conflicts on the basis of
trademark law. Astoundingly, WIPO considered and explicitly rejected
that limit upon its mandate. The report fails to provide a definition
of cyber-piracy and it has structured its dispute resolution and
challenge procedures to cover any conceivable trademark-based
challenge to a domain name registration, instead of coming up with
solutions carefully targeted at speculators in trademarked names.



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