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The ALAC wishes to comment on the Trademark Clearinghouse "Strawman Solution" from a number of different perspectives.

Was this the right time for re-opening Rights Protection Mechanisms (RPMs)?

As the RPMs outlined in the Applicant Guidebook for the first round of new gTLDs were arrived at through an extremely difficult but successful consensus process, the ALAC’s first preference would be to not re-open this sensitive issue at this point. However, the ALAC also acknowledges that the concerns of the IPC/BC do have some basis, as demonstrated by the significant level of defensive registrations within existing TLDs as well as ongoing UDRP activity. Given that, the ALAC is prepared to comment on the specific RPMs being proposed on their individual merits.

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Limited Preventative Registration: This is not part of the Strawman proposal, and differs from anything previously accepted by the community. As such it is clearly policy. It is a form of blocking without (to date) any practical method of over-riding it to account for fair-use situations. The ALAC cannot support any form of such a change at this time.

FIRST DRAFT SUBMITTED

The ALAC wishes to comment on the Trademark Clearinghouse "Strawman Solution" from a number of different perspectives.

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