Is 80% of .xxx going to be defensive?

Is the new adults-only top-level domain going to turn out to be just as big of a trademark shakedown as some had feared?
EasySpace, a British domain name registrar, claims that 80% of its .xxx pre-orders are from organizations outside the porn industry.
“Out of the hundreds of businesses that have rushed to pre-register with Easyspace ahead of the opening of the Sunrise phase for .XXX domains on 7 September 2011, only 20% of them are from the adult industry,” the company said in a press release.
EasySpace is just one rather small registrar, of course, and its marketing of .xxx is very much in the “Protect your brand” camp, so its numbers may not necessarily hold up industry-wide.
The company is charging $189.99 ($310) for non-porn defensive registrations, an almost 100% markup on the registry fee.
Still, 80% is a big number, and likely to be used by critics not only of .xxx but of new TLDs in general.

Big Content calls for government new gTLD oversight

The music, movie and advertising industries have backed a US move that could see governments getting more control over the approval of new top-level domains.
They’ve urged the National Telecommunications and Information Administration to keep a proposed rule that would force ICANN to show a new gTLD is in the “global public interest” before giving it the nod.
But they are opposed by many other stakeholders who responded to the NTIA’s Further Notice Of Inquiry on the renewal of ICANN’s IANA contract.
The FNOI resulted in about 35 responses, from companies and organizations on five continents.
The most controversial question posed by the NTIA was whether the IANA contract should include this provision:

For delegation requests for new generic TLDS (gTLDs), the Contractor [ICANN] shall include documentation to demonstrate how the proposed string has received consensus support from relevant stakeholders and is supported by the global public interest.

This was broadly interpreted as a way for governments to have a de facto veto over new gTLD applications, via ICANN’s Governmental Advisory Committee.
The proposed measure has now been supported by the Recording Industry Association of America, the Association of National Advertisers, and the Coalition for Online Accountability, which represents the music and movie industries.
Brand owners want another bite
In his strongly worded response, ANA president Robert Liodice wrote that the new gTLD program “is likely to cause irreparable injury to brand owners”, adding that it supported the NTIA’s proposal.

[It] provides a layer, however thin, of contractual protection that gTLDs will not be deposited to the authoritative root zone without appropriate justification. While the ANA believes that these protections are marginal at best, and that a more secure, safe and permanent solution must be found to prevent the harms to brand owners and consumers described above; nonetheless, “something is better than nothing”

Special interests
The RIAA said in its filing that it “strongly supports” the proposal, on the basis that it thinks .music, if approved as a gTLD, could lead to more online music piracy.

there are no concrete obligations in the latest application guidebook to implement heightened security measures for these types of gTLDs that are focused on particular industries such as record music. Given the the risk that such a gTLD application could pass through the ICANN process without committing to such measures, it should be incumbent on the IANA contractor to document how its entry into the root would meet the “global public interest” standard.

It’s a drum the RIAA, never afraid of making special-interest arguments on matters of internet governance, has been beating for some time.
It stopped short of asking for all existing TLDs (and IP addresses, in the case of peer-to-peer applications) to be banned outright, which would presumably do much more to prevent piracy.
Oh no you ditn’t!
The COA, which includes the RIAA among its members, has the honor of being the first of ICANN’s critics to raise the Peter Dengate Thrush Situation to officially bash the organization.
PDT, as you’ll recall, joined Minds + Machines, likely to be a volume gTLD applicant next year, just a few weeks after he helped push through ICANN’s approval of the gTLD program.
COA counsel Steve Metalitz wrote:

This development tends to confirm COA’s view that “the new gTLD process, like so much of ICANN’s agenda, has been ‘led’ by only a small slice of the private sector, chiefly the registrars and registries who stand to profit from the introduction of new gTLDs.”
…
If a “check and balance” on addition of these new gTLDs to the root was advisable prior to this announcement, it now appears to be indispensable.

Plenty of ICANN stakeholders on both sides of the new gTLD debate have been calling for a review of ICANN’s ethics policies recently, so the COA is far from alone in highlighting the perception problem PDT’s move, and others, may have created.
It looked dodgy, and people noticed.
But on the other hand…
Many responses to the FNOI take the opposing view – saying that the “global public interest” requirements appear to run contrary to IANA’s technical coordination mandate.
IANA’s statement of work, which mandates IANA staff independence from ICANN policy-making, seems like a very odd place to introduce a vague and highly policy-driven oversight check.
Opposition came from the gTLD registry community and likely applicants, as you might expect, as well as from a number of ccTLD operators, which was perhaps less predictable.
A typical response, from the ccNSO, was:

While recognising and supporting the need for ensuring that new gTLDs have consensus support and are consistent with the global public interest, the ccNSO suggests that the IANA contractor’s role should simply be to verify that ICANN has followed the Guidebook process and that all the evaluation criteria (not just the two referred to) have been met.

A number of responses also call for the strict separation of IANA staff from ICANN’s policy-making functions to be relaxed. The way the NTIA’s proposal is currently worded, it’s not clear if IANA’s experts would be able to provide their input to important work.

FarmVille domain seized from Chinese squatter

Zynga has claimed control of the domain name farmville.co.uk from a Chinese cyberquatter.
The summary decision under Nominet’s Dispute Resolution Service was made July 14, and posted to the Nominet web site today, but the Whois still shows the previous owner.
According to Whois records, the domain was registered July 1, 2009, just a couple of weeks after the popular FarmVille game launched on Facebook.
The domain currently resolves to a Sedo placeholder page.
If this proves anything, it’s that owners of rapidly growing web applications need to keep an eye on their brands in non-core TLDs, because cybersquatters are too.

Bit-squatting – the latest risk to domain name owners

Forget phishing, forget cybersquatting, forget typosquatting, high-value domain name owners may have a whole new threat to worry about – “bit-squatting”.
This appears to be the conclusion of fascinating new research to be presented by Artem Dinaburg at the Black Hat and DEF CON hacker conferences in Las Vegas next week.
Defective internet hardware, it turns out, may be enabling a whole new category of typosquatting that could prove worrying for companies already prone to domain name abuse.
According to a summary of Dinaburg’s research, RAM chips can sometimes malfunction due to heat or radiation, resulting in “flipped bits”, where a 1 turns into a 0 or vice-versa.
Because the DNS uses ASCII encoding, a query containing a single flipped bit could actually send the user to a completely different domain name to the one they intended to visit.
To test the theory, Dinaburg appears to have registered the typo domain name mic2osoft.com. While it’s not visually confusing or a likely typo, in binary it is only one bit different to microsoft.com.
The ASCII binary code for the digit 2 is 00110010, which is only one bit different to the lower-case letter r, 01110010.
The binary for the string “microsoft” is:

011011010110100101100011011100100110111101110011011011110110011001110100

and the binary encoding for “mic2osoft” is (with the single changed bit highlighted):

011011010110100101100011001100100110111101110011011011110110011001110100

Therefore, if that one bit were to be accidentally flipped by a dodgy chip, the user could find themselves sending data to the bit-squatter’s domain rather than Microsoft’s official home.
I would assume that this is statistically only a concern for very high-traffic domains, and only if the bit-flipping malfunction is quite widespread.
But Dinaburg, who works for the defense contractor Raytheon, seems to think that it’s serious enough to pay attention to. He wrote:

To verify the seriousness of the issue, I bit-squatted several popular domains, and logged all HTTP and DNS traffic. The results were shocking and surprising, ranging from misdirected DNS queries to requests for Windows updates.
…
I hope to convince the audience that bit-squatting and other attacks enabled by bit-flip errors are practical, serious, and should be addressed by software and hardware vendors.

His conference presentations will also discuss possible hardware and software solutions.
For large companies particularly at risk of typosquatting, the research may also present a good reason to conduct a review of their trademark enforcement strategies.
I’m not going to be in Vegas this year, but I’m looking forward to reading more about Dinaburg’s findings.
The annual Black Hat and DEF CON conferences are frequently the venues where some of the most beautifully creative DNS hacks are first revealed, usually by Dan Kaminsky.
Kaminsky is not discussing DNS this year, judging by the agendas.
The conferences were founded by Jeff Moss, aka The Dark Tangent, who joined ICANN as its chief security officer earlier this year.

ICM reveals .xxx launch dates, extends sunrise

Citing demand, ICM Registry has lengthened the .xxx sunrise period, which begins September 8, by three weeks. It will now end October 28, running for 50 days.
The new deadlines apply to all three sunrises, which will run concurrently.
Sunrise A-T – for porn publishers with trademarks.
Sunrise A-D – for porn publishers with matching domains in other TLDs.
Sunrise B – for anyone outside the porn business who wants to “turn off” their trademark in .xxx to prevent cybersquatting.
Successful Sunrise B applicants will see their chosen domains resolve to a standard information page explaining that the domain is not available for registration.
Post-launch, anyone can register a non-resolving domain that returns an NXDOMAIN response, but they’ll have to pay for it annually. Sunrise B applicants pay a one-time fee.
If applicants from Sunrise A and Sunrise B both apply for the same domains, the porn applicant will be given precedence, although they will be warned about possible trademark infringement.
If more than one Sunrise A applicant applies for the same domain, the fight will be taken to an auction, managed by Pool.com. Auction rules will be published at a later date.
The sunsrise is outlined in a policy document (pdf) ICM published on its web site today that sets out the rules for its pre-launch period.
The company has not yet announced details of its Charter Eligibility Dispute Resolution Procedure, nor its Rapid Evaluation Service, though it has said it expects them to cost between $750 and $1,500, depending on what deals it can come to with dispute resolution providers.
The Rapid Evaluation Service, previously referred to as “rapid takedown” will be an interesting one.
It’s expected to be a little like the Uniform Rapid Suspension process ICANN’s new gTLDs will have to implement, except it will only take about 48 hours to take down an obviously cybersquatted domain.
ICM says it expects to publish these policies before the sunrise begins.
Landrush is now expected to run November 8 until November 25. General availability will begin December 6.

Can ICANN make a trademark deal with the GAC?

The ICANN board and its Governmental Advisory Committee have yet to reach agreement on how to protect trademarks in new top-level domains, following their Friday teleconference.
The two parties are still stuck on at least four trademark protect issues, according to sources familiar with the talks, and the GAC is due to provide updated written advice to ICANN tomorrow.
Two of the areas still outstanding were previously marked “1A” in ICANN documents, meaning ICANN’s board believed the GAC’s concerns had already been resolved.
Trademark Claims
Details of the proposed Trademark Clearinghouse database and the related Trademark Claims service are still the subject of debate.
Trademark Claims provides an alert to a trademark holder if somebody tries to register their trademark in a new gTLD. The would-be registrant also gets a warning that they may be infringing rights.
As the Applicant Guidebook stands today, new gTLD managers will have to operate the service for the first 60 days of general availability, but the IP lobby and the GAC believe it should be permanent.
The sticking point for ICANN, as I understand it, is that there’s already a commercial market for brand protection services that have some overlap with Trademark Claims.
Several companies, such as MarkMonitor, CSC and Melbourne IT, offer services that alert customers when somebody appears to infringe their brand in a domain name.
If Trademark Claims ever made it into com and other gTLDs, it could effectively monopolize the brand watch services market. The Clearinghouse(s) will be ICANN contractors, after all.
Remember what happened when VeriSign announced its Wait List Service, which promised to effectively take over the existing domain back-order services market? It wasn’t pleasant.
Proof of Use
ICANN has already dropped its requirement for “substantive review”, but it still requires trademark holders to provide “proof of use” before they can add their marks to the Clearinghouse.
Without proof of use, companies will not be able to file Uniform Rapid Suspension complaints or defensively register their brands during new gTLD Sunrise periods.
The IP lobby and the GAC want this requirement scrapped. Any trademark of national effect should be enforceable using these rights protections mechanisms, they say.
One of the justifications is that some trademarks are obtained before the owner actually launches the product or service they pertain to.
If ICANN were to make these changes, there’s a good chance that bulk-registering bogus trademarks in loose jurisdictions may become an effective strategy for gaming the second level in new TLDs.
This has happened before, such as in .eu, and that wasn’t pleasant either.
Brand+Keyword
The current draft of the Applicant Guidebook only allows exact trademark matches into the Trademark Claims and Sunrise mechanisms.
But the the IP crowd (and, again, the GAC) thinks non-exact matches should be allowed in. In the .com space, the majority of cybersquatting nowadays is of course either a brand+keyword or a typo.
Millions are being needlessly spent on UDRP complaints over typos and brand+keyword domains, and the trademark lobby don’t want to risk having to spend even more.
But there could be implementation problems. Both types of variant could throw up lots of false positives during the Claims service, for example, creating conflicts where there aren’t any.
An automated system designed to scare off typosquatters could catch the generic domain goggles.tld as an infringement of Google’s trademark, to use an obvious example.
If brand+keyword Sunrise claims were allowed, holders of trademarks in generic terms could find themselves with a lucrative payday.
Any company that has a trademark on words such as “free”, “live”, “sexy” or anything that could act as a cool prefix, could have a field day during a Sunrise period.
Uniform Rapid Suspension
I understand a sticking point here continues to be the burden of proof required to make a URS case stick.
It’s currently “clear and convincing evidence”, but the IP lobby and the GAC want it reduced to “preponderance of evidence”, a lower burden.
To non-lawyers, the difference may seem trivial. Both standards are used in civil cases in many countries, but one’s a bit strong than the other.
“Preponderance of evidence” basically means “more likely true than not”, whereas “clear and convincing”… well, it’s a bit stronger than that.
The choice of burdens will have repercussions for years to come. Registrants in new gTLDs will know what they’re getting into, but if URS ever makes it into .com…
The Road to Singapore
It’s less than a month before ICANN’s next major meeting, and only a week until it plans to publish the next version of the Applicant Guidebook.
The ICANN board is due to meet face-to-face (and presumably in public) with the GAC on the first day of the meeting, June 19, but it seems that talks will be ongoing behind the scenes until then.
A great deal of progress has been made, but with complex issues still apparently unsettled (and there are more unresolved issues unrelated to trademarks) it’s little wonder that some are now wondering whether ICANN is as confident as it once was that June 20 is Guidebook Approval Day.

Don’t rush to defensively register .xxx domains

Trademark owners trying to figure out how to protect their brands in the .xxx top-level domain should wait for ICM Registry to reveal its full suite of anti-cybersquatting measures before deciding whether to defensively register a large portfolio of domains.
With registrar prices for sunrise trademark blocks currently hovering around the $300 mark, an especially aggressive enforcement strategy could rack up six-figure bills for large brand holders.
But it may turn out to be more cost-effective to use ICM’s post-launch enforcement mechanisms to fight cybersquatting.
So far, all we’ve seen from ICM is a white paper, prepared by its partner IPRota, that outlines the policies that will be in place during the pre-launch sunrise period.
But the company plans to have some of the most Draconian post-launch IP rights protections mechanisms of any new TLD to date.
If, as a registrant, you think the Uniform Rapid Suspension policy ICANN plans to enforce on new TLDs is tough, you’ll likely have a bigger problem with Rapid Takedown.
Rapid Takedown is expected to be modeled on the Digital Millennium Copyright Act. It will use UDRP experts, but will only take 48 hours to suspend a domain name. ICM has described it like this:

Rapid Takedown
Analysis of UDRP disputes indicates that the majority of UDRP cases involve obvious variants of well-known trademarks. ICM Registry does not believe that the clearest cases of abusive domain registration require the expense and time involved in traditional UDRP filings. Accordingly, ICM Registry will institute a rapid takedown procedure in which a response team of independent experts (qualified UDRP panelists) will be retained to make determinations within 48 hours of receipt of a short and simple statement of a claim involving a well-known or otherwise inherently distinctive mark and a domain name for which no conceivable good faith basis exists. Such determinations will result in an immediate termination of resolution of the domain name, but will not prejudice either party’s election to pursue another dispute mechanism. The claim requirements will be modeled after the Digital Millennium Copyright Act.

It remains to be seen how much this will cost complainants (assuming there is a cost), and there are other unanswered questions such as the duration of the suspension, the ability of the complaint to have the domain transferred and the registrant’s right of appeal.
But it’s clear that trademark holders will very likely have cheaper options than UDRP, which can cost as much as $1,500 for a single domain name.
In addition, ICM plans to permanently ban cybersquatters that are “found to have repeatedly engaged in abusive registration”. Abusers will lose their .xxx portfolios, even their non-infringing domains, and will not be able to register any more.
Combined with Rapid Takedown, and the high price of .xxx domains ($75 a year minimum so far), this will likely make cybersquatting a much less attractive proposition in .xxx than .com.
Trademark holders should wait for their full range of options to be revealed before panicking about high sunrise fees.
It may turn out to be more cost-effective to block just a few primary brands, and leave enforcement of other brands to post-launch mechanisms.

Three strikes UDRP rule worries Demand Media

Demand Media and the Internet Commerce Association have called for ICANN to drop the “three strikes and you’re out” ban on applying for new top-level domains.
In the current version of ICANN’s Applicant Guidebook, if you’ve lost three UDRP cases in the last four years you’re considered a cybersquatter and effectively barred from applying for a new TLD.
It’s not entirely clear, but it is quite possible that this provision may capture Demand Media and Go Daddy, which, via subsidiary companies, have lost several UDRP complaints.
In comments filed with ICANN yesterday, Demand senior vice president Jeff Eckhaus said that a simple “three strikes” benchmark does not prove a pattern of cybersquatting:

losing a few contested UDRP cases in what amounts to a tiny percentage of their total domain name portfolio certainly doesn’t seem to constitute a “pattern” as most people would define the term
…
by all reasonable standards, it is difficult to conclude that an entity or an individual has engaged in a history/pattern of cybersquatting when they own hundreds or thousands of domain names and have lost a few UDRP or similar proceedings.

The ICA, which represents high-volume registrants, also has a problem with the rule. Principal Phil Corwin wrote ICANN:

We continue to believe that the “three strikes” criteria is too inflexible and that applicant evaluation criteria should take into account the total size of an applicant’s domain portfolio as well as the percentage of adverse UDRP decisions rendered against them in comparison to all UDRP proceedings they have been involved with.

Demand also argues that three strikes is “extremely broad standard that we believe will unintentionally disqualify otherwise qualified applicants.”
That strikes me as quite a weak argument, which could be equally applied to any of the background checks in the Guidebook. A murder conviction will also “disqualify otherwise qualified applicants”.
I’m not sure it’s “unintentional” in either case. If you work from the assumption that ICANN expects Demand and other speculators to successfully apply for new TLDs, it is. If you assume it’s designed to make their lives more difficult, it isn’t.
But Corwin noted in his comments that ICANN can waive the ban in “exceptional circumstances”, and said he suspects this could be used to allow large registrars to pass the background checks.
In any event, as Andrew Allemann has pointed out at Domain Name Wire, the way the Guidebook is phrased there may well be a loophole that would allow Demand and others to slip through.
Go Daddy, which DNW also reports could be affected by the rule, does not appear to have filed any comments on the latest Applicant Guidebook yet.

Trademark lobby makes final new gTLD demands

With ICANN’s latest and potentially last call for comment on its new top-level domains program just hours away from closing, the arguments are shaping up along familiar lines.
Trademark protection is unsurprisingly still center stage, with loud calls for the Applicant Guidebook’s rights protection mechanisms to be amended more favorably to brand owners
Meanwhile, many of those strongly in favor of the new gTLD program launching soon have submitted more subdued, concise comments, merely urging ICANN to get a move on.
While there are still some fringe opinions, many within the intellectual property community are on the same page when it comes to rights protection mechanisms.
URS
The Uniform Rapid Suspension policy, which enables trademark holders to relatively quickly shut down obvious cases of cybersquatting, comes in for particular attention.
In the latest draft of the URS, as well as its sister policy, the Trademark Clearinghouse, brand owners have to present “proof of use” for the trademarks which they want to enforce.
The International Trademark Association, the Intellectual Property Constituency and others want this provision eliminated, saying it is inconsistent with many national trademark laws.
The also want the burden of proof lowered from the “clear and convincing evidence” standard, and want to expand the “loser pays” model, to provide an economic disincentive to cybersquatting.
In the latest version of the Applicant Guidebook, ICANN introduced a system whereby a cybersquatter has to pay the cost of a URS they lose, but only if the case comprises over 25 domains.
INTA, the IPC and others want this reduced to something like five domains, on the grounds that 25 is too high a bar and may actually encourage larger-scale squatting.
IP Claims
They also want the Clearinghouse’s IP Claims service, which serves a warning to registrants when they try to register potentially infringing domains, expanded beyond exact-match strings.
Currently, you’ll receive a warning about possible infringement if you try to register lego.tld or foxnews.tld, but not if you try to register legostarwars.tld or foxnewssucks.tld.
Many commenters want this changed to also include brand+keyword domains (fairly easy to implement in software, I imagine), or even typos (not nearly so easy).
This makes sense if you assume that cybersquatting patterns in new TLDs mirror those in .com, where brand+keyword squatting comprise the majority of UDRP cases.
But if you look at the about 100 UDRP cases to be filed so far in .co, it seems that brand-only cybersquatting is clearly the order of the day.
Depending on how this was implemented, it could also create a “chilling effect” whereby IP Claims notices are sent to legitimate registrants.
It seems likely that with a brand+keyword approach, if someone tried to register legourmetchef.tld, they could wind up with a notice that the domain infringes the Lego trademark.
The trademark lobby also wants this IP Claims service extended beyond the first 60 days of a new TLD’s life, on the grounds that the cybersquatting risk does not disappear after a TLD launches.
According to submissions from existing TLD registries and potential applicants, this could add to the costs of running a TLD, increasing prices for registrants.
GAC
Most of these demands are not new. But in many cases, the IP lobby now has the support of the ICANN Governmental Advisory Committee.
The GAC and ICANN are due to meet by teleconference this Friday, ostensibly for their “final” consultation before ICANN approves the Guidebook a little over a month from now.
But with the US and Europe now strategically aligned, it seems likely that ICANN will find itself under more pressure than ever before to concede to the demands of trademark holders.

How to protect your trademark in .xxx

ICM Registry today revealed the details of its policies for trademark holders that want to defensively register or block their .xxx domain names.
The company plans to kick off its sunrise period in early September. It will last 30 days, and will be followed a few weeks later by a 14-day landrush.
The date for general availability has not been set in stone, but is likely to be in early December.
Two sunrise periods will run concurrently. Sunrise A is for the adult entertainment industry, those who want to actually set up porn sites at .xxx domains. Sunrise B is for everyone else.
ICM is trying something new with .xxx, in response to non-porn brands that are worried about cybersquatting and also don’t want to actually own a .xxx domain name.
Under Sunrise B, non-porn trademark owners can pay a one-time fee to have their brand essentially turned off in .xxx.
These domains will all resolve to a standard placeholder page, informing visitors that the domain has been blocked.
Because the domains resolve, they will usually not be picked up by any ISP system whereby non-existent domains show advertisements instead of an error message.
The fees we’ve seen so far from registrars for this service range from $299 to $648, but ICM seems to think $200 to $300 is more realistic.
The blocks are expected to last forever, but because ICM’s registry agreement with ICANN only lasts for 10 years, it can only guarantee the blocks for that amount of time.
So while it looks like a $30 to $65 annual fee, over the lifetime of the TLD it may well steadily approach a negligible sum, if you’re thinking super-long-term.
To qualify for Sunrise B, you need a nationally registered trademark for the exact string you want to block. To use an example, Lego could block lego.xxx, but not legoporn.xxx.
ICM is currently planning a post-launch block service for brands that emerge in future, but it probably won’t have the flat one-time pricing structure, due to the registry’s own annual per-domain fees.
If you’re in the porn business, Sunrise A allows you to claim your brand if you have a trademark that is registered with a national effect.
It will also enable the “grandfathering” of porn sites in other TLDs that do not have a registered trademark. If you own example.com or example.co.uk, you’d qualify for example.xxx.
Lego could, for example, register legoporn.xxx using Sunrise A, because it already owns legoporn.com, but only if it actually intended to publish Lego-based pornography.
If it were to register legoporn.xxx in this way, and use it for non-porn purposes, it would be at risk of losing the domain under ICM’s planned Charter Eligibility Dispute Resolution Policy (CEDRP).
In the event that a Sunrise A applicant and a Sunrise B applicant both apply for the same string, the Sunrise A (porn) applicant will be given the option to withdraw their application.
If they don’t withdraw, they will be able to register the domain, trumping their non-porn rival.
Two Sunrise A applicants gunning for the same .xxx domain will have to fight it out at auction.
It’s probably worth mentioning, because many cybersquatters seem to think it’s a .com-only deal, that the UDRP does of course also apply to .xxx domain names.
If you own, for example, the string “virgin” in another TLD, and use it for a porn site, you will actually be able to use it in Sunrise A to secure virgin.xxx, but you risk losing it to Virgin in a UDRP.
If you’ve “pre-registered” a domain with ICM already, it doesn’t seem that you’ll have any notable advantages during sunrise or landrush.
The registry plans to email these pre-registrants soon with instructions. More info on the new ICM site: XXXempt.com.
The sunrise policies were devised by IPRota.