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As indicated in our previous statement, we have serious concerns regarding what we consider to be backwards steps from areas of community consensus. As one particularly serious example, we wish to draw attention to proposed URS rules which appear to regress from the position taken by the cross-community Special Trademark Issues ("STI") group and from the Draft Applicant Guidebook version 4.

Although 14 days may be sufficient for large corporate entities, it is not sufficient for registrants who are individuals, small businesses or non-profit oprganizations -- particularly those located where mail delivery is not as effective as in the US or western Europe. Given that the overall URS process time had been reduced compared to that of the STI, there is no call for reverting to the 14 days. When public comments to earlier rules were reviewed, the ICANN staff decision was to not adjust the time period. This decision was based on a few complaints about it being to long, and a larger number about it being too short.

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