International Trademark Association
Washington Office
1990 M Street, Suite 340, Washington DC 20036
May 6, 1998
Ms. Karen Rose
Office of International Affairs
National Telecommunications and Information Administration
U.S. Department of Commerce
14th and Constitution Avenue, NW, Room 4701
Washington, DC 20230
Dear Ms. Rose:
The International Trademark Association (INTA) is pleased to provide you with a summary
of its comments on the future of the domain name assignment system (DNS) conveyed to Mr.
Ira Magaziner during a meeting in the Old Executive Office Building on May 5, 1998.
- No one benefits from consumer confusion, except, perhaps, those who seek to engender it.
Additional gTLDs will increase confusion and add to the risks for trademark owners.
INTA therefore considers it undesirable and premature to add up to five new gTLDs
before an effective dispute resolution is in place to protect existing trademark rights.
- Trademark owners need complete and accessible information if they are to contact
potential infringers at an early stage before consumer confusion occurs and before domain
holders make significant investments in domains that infringe established trademark
rights.
- INTA supports a reasonable and uniform dispute resolution policy which renders
administrative - not legal - decisions. The lack of a uniform system will only lead to
confusion on the part of trademark and domain name holders. Inconsistent policies and
precedents will lead to chaos in the Internet community and, in the end, increase rather
than decrease transaction costs.
- If the Internet is to serve the needs of international commerce and consumers which rely
on trademarks to make an informed decision, mainstream business and the trademark
community must have an effective voice in setting Internet domain name policy.
On behalf of INTA, I would like to once again express our thanks to the Administration for
conducting fair and open discussions concerning the future of the DNS. If you have any
questions or comments concerning our summary, please feel free to contact me.
Sincerely,
J. H. Kent
Washington Representative