Anchovy News
Domain Name and Online Brand Protection News from Hogan Lovells
September 2010
Further information If you would like further information on any aspect of domain names please contact David Taylor, Jane Seager or the person with whom you usually deal.
Contacts David Taylor T +33 1 53 67 47 47 [email protected]
Jane Seager T +33 1 53 67 47 47 [email protected]
This publication is written for information purposes only. It should not be relied upon as a substitute for specific legal advice.
Contents
DOMAIN NAME REGISTRATION AND INDUSTRY NEWS 1 Nominet to release one and two character domain names 1 Snap up some Somalian domain names 1 Improved security for .INFO 2 CARNet allows you to net more Croatian domain names 3 IDN ccTLD update 3
DOMAIN NAME RECUPERATION NEWS 4 Bad faith registration and use under the UDRP: cumulative… or not? 4 Later trade mark rights: risk of reverse domain name hijacking 6 Dolce & Gabbana fails to obtain
ANCHOVY - GLOBAL ONLINE BRAND MANAGEMENT AND PROTECTION 11 How we can help 11 Further information 11 Contacts 11
1 Domain name registration and industry news
Nominet to release one and two character domain names
Snap up some Somalian domain names
NOMINET TO RELEASE ONE AND TWO CHARACTER 1 January 2008. Evidence of bona fide use in the UK on or DOMAIN NAMES before 1 January 2008 also has to be provided to the satisfaction of an independent assessor. These rather strict On 13 September 2010, the Registry for .UK domain names rules aim to prevent cybersquatters from effectively gaming (Nominet) announced that it would soon be releasing various the system and registering trade marks specifically for the one and two character domain names under the extensions purpose of obtaining valuable domain names. This is .CO.UK, ORG.UK, .NET.UK and .ME.UK. something that has been widely prevalent in the launch of At the moment many Top Level Domains (TLDs) do not allow previous domain name extensions, such as .EU. one and two character domain names to be registered, mainly There will also be a second stage Sunrise period for (i) any for historical reasons based on ensuring the security of the person who would have qualified for the first Sunrise but internet. In particular it was generally thought that allowing missed the application deadline and (ii) the holders of the registration of two letter domain names at the second or unregistered rights enforceable in the UK which exactly third level may cause confusion, especially given the fact that correspond to the required domain name and which were in the two letter codes published by the International force as of 1 January 2008. Again evidence of bona fide use Organization for Standardization (ISO) are used to designate in the UK on or before 1 January 2008 has to be provided to country code Top Level Domains (ccTLDs) on the internet. the satisfaction of an independent assessor. However, it is now generally accepted that such concerns are If there are multiple qualifying applicants then the domain rather outdated and that technically there is no reason why one name will be sold to the highest bidder at auction. Nominet and two character domain names cannot be made available has said that any profits it makes from this exercise will go to for registration. In this regard a number of TLD Registries the Nominet Trust, which is a charity founded to provide have recently allowed the release of such domain names support to organizations and projects working to increase (for example .BIZ and .MOBI) and more are set to follow. access to the internet, online safety and education. Nominet has been considering the issue of one and two Nominet has said that it will publish more details of the character domain names for a while and recently undertook release on 1 November 2010 and aims to start the first stage a public consultation on the issue which ran from 8 March to before the end of the year. A list of all the domain names 8 June 2010 (see the March 2010 issue of Anchovy News ). available for release is available at the following link: According to Nominet, the results were mainly in favour of the http://www.nic.uk/digitalAssets/45272_domains-to-be- release. Nominet has therefore decided to manage the released.pdf . We will of course keep you informed of any release in two phases, a Sunrise period for holders of prior further developments. trade marks followed by a Landrush period which will be open to everyone. To visit the Nominet website, please go to: http://www.nominet.org.uk/ . This is good news for brand owners with one or two character trade marks, as with a little forward planning they will have a high chance of securing their domain names. One and two character domain names are usually very expensive on the SNAP UP SOME SOMALIAN DOMAIN NAMES domain name aftermarket, given that there are only a finite Domain names under .SO, the Somalian country code Top number of them, and so when they are released by Registries Level Domain (ccTLD), have for many years been unavailable they are highly sought after and competition to obtain them is for registration due to the civil war in Somalia and the general usually tough. confusion concerning who should be responsible for running The German Registry, DENIC, was recently criticised when it the Registry. released one and two character domain names as the release The initial delegation of the .SO TLD was performed in 1997 took place on very short notice on a first come, first served to World Class Domains, a US company. As of 2002, the basis. There were no rights protection mechanisms put in URL to the Sponsoring Organisation’s website intermittently place for trade mark holders and domain name registrars who contained the following message: had a realistic chance of securing domain names on a first come, first served basis (namely the larger ones with “As Somalia has no internationally recognized government, sophisticated systems in place) were reportedly able to this domain is not currently used. We simply have parked this charge successful applicants five to six figure sums for them. top level domain till an official government is implemented. In order to avoid such criticism and to try and ensure an If you are looking for information about Somalia, please visit orderly and fair release, Nominet is planning to operate a first Yahoo’s Somalia category or the United Nations Somalia page. stage Sunrise period for the holders of registered trade marks No .SO domains are available and we are not looking for any enforceable in the UK which exactly correspond to the registrar partners”. required domain name and which were in force as of 2
Snap up some Somalian domain names (continued)
Improved security for .INFO
In 2008 the Ministry of Post and Telecommunications of the .YT (Mayotte) are run by the French Registry, AFNIC, but are Transitional Federal Government of Somalia made an currently suspended, presumably in favour of .FR. application to run .SO which was reviewed by the Internet Assigned Numbers Authority (IANA), the organisation The fact that there will be a Sunrise period for .SO represents responsible for the global co-ordination of the internet. good news for brand owners. If you would like further An objection was received by a Mr Aveek Datta, who stated information regarding registrations under .SO, please contact that he was “holding this top-level domain in trust for the David Taylor at [email protected] . people of Somalia as their government is currently in disarray. I do have a contact of Somalia origins that has agreed with this course of action.” IMPROVED SECURITY FOR .INFO However, despite asking for clarification and issuing several On 9 September 2010, Afilias, a global provider of internet reminders, IANA received no further response and so infrastructure services and the Registry for .INFO domain recommended to the board of the Internet Corporation for names (amongst others), announced that it had enabled Assigned Names and Numbers (ICANN) that .SO be Domain Name System Security Extensions (DNSSEC) for redelegated as requested, and this course of action was the .INFO Top Level Domain (TLD). .INFO is the 27th TLD approved by the board in February 2009. to deploy DNSSEC and Afilias has indicated that it aims to The new Registry will therefore launch registrations on deploy DNSSEC across a further 13 TLDs that it supports in 1 November 2010 according to the following phased Asia, Latin America and Europe by the end of the year. schedule: Further to the launch of .INFO in 2001 (the first generic, Sunrise period (1 November - 30 November 2010): unrestricted TLD to be launched after .COM), its popularity has grown to the extent that it is now the fourth largest Registered trade mark holders (from any country) may apply generic TLD in the world with over 6 million domain names to register .SO domain names corresponding to their trade registered. Due to .INFO's popularity, the risks of malicious marks. Trade marks must have been registered on or before attacks are obviously high, and thus DNSSEC technology 1 January 2010. No local presence will be required. If will protect users to a greater extent against fraudulent identical applications are received this will be resolved by activity. auction (see below). The aim of DNSSEC technology is to secure any weak points Sunrise auction period (1 December - 15 December 2010): within the Domain Name System (DNS) which would Auction for domain names with more than one credible potentially be exploitable by pirates. DNSSEC works by Sunrise application. digitally signing responses received from the DNS. It thus helps to ensure that internet users reach their intended Landrush period (16 December 2010 - 9 February 2011): destination and are not misdirected to, for example, look-alike websites used to fraudulently collect personal details such as Available domain names may be registered, although if account numbers and passwords (often referred to as identical applications are received this will be resolved by "phishing"). auction (see below). The deployment of DNSSEC started in 2009 with the digital Landrush auction period (10 February - 28 February 2011): signing of the root zone file, as covered in the June 2009 issue of Anchovy News . This was finally completed on 16 Auction for domain names with more than one credible July 2010. Progress has been slow, perhaps due to the Landrush application. technical implications of deploying DNSSEC and the reluctance of Registries and registrars to step into the General availability (1 March 2011): unknown. However certain country code TLDs such as .SE Available domain names may be registered on a first come, (Sweden) and .BE (Belgium) have already deployed DNSSEC first served basis. and some are currently in the process of doing so, such as .GR (Greece) and, most recently, .FR (France). Interestingly .SO was one of the few remaining ccTLDs to remain unused. The remaining ones look unlikely to open up in the near future as, for the most part, they represent dependent territories where the ccTLD of the country in question is used in preference. Examples include .BV (Bouvet Island) and .SJ (Svalbard and Jan Mayen), both of which fall under the administration of Norway, which prefers to use .NO. Similarly, .PM (Saint Pierre and Miquelon) and 3
CARNet allows you to net more Croatian domain names
IDN ccTLD update
CARNET ALLOWS YOU TO NET MORE CROATIAN This meant that internet users had to change scripts to type DOMAIN NAMES IDNs into their browsers and this was not particularly user friendly for speakers of languages using non Latin scripts. On 15 June 2010, the Croatian Academic and Research However ICANN is now rolling out ccTLDs in different scripts, Network (CARNet), the central Registry for .HR domain meaning that entire domain names may now be written in non names, introduced new regulations concerning .COM.HR Latin characters. This represents a significant step towards and .HR domain names. creating a less Anglophone centred internet and has been a As a result, the registration and management of Croatian long time coming considering that a significant proportion of domain names, previously handled by CARNet directly, are internet users do not speak English as a first language. now to be dealt with by accredited registrars. This means Countries/territories who wish to apply for an IDN ccTLD first that, at the time of their renewal, all existing domain names have to successfully complete a String Evaluation phase before will have to be transferred from CARNet to an accredited they can submit a request to ICANN for delegation of the registrar. approved ccTLD extension into the DNS root. The first four Domain name registrations under the .COM.HR extension applications to be approved by ICANN were as follows: . рф ALSAUDIAH for.) ا د ,(are unrestricted, and a local billing contact is no longer (.RF for the Russian Federation EMARAT for.) ارات. (.MISR for Egypt) and required, thus any entity may register a .COM.HR domain Saudi Arabia), . name. CARNet also announced that it is now possible for the United Arab Emirates). Numerous other countries/territories Croatian companies to register a total of ten .HR domain have successfully completed the String Evaluation phase, names, whereas previously only one .HR domain name was including China, Hong Kong, India, Jordan, Singapore, Taiwan, allowed per company. Thailand and Tunisia which means that they may now apply to ICANN for delegation of their chosen string(s). With any announcement such as this by a domain name Registry, it is possible that some third parties will take the It is thus anticipated that a flood of new IDN ccTLDs will soon opportunity to register any available domain names that may be upon us. In this regard the Registries of the four IDN infringe trade mark holders' intellectual property rights. ccTLDs that have already been activated are all currently proceeding with phased registrations in order to ensure that Considering the changes to the registration and management governmental organisations and trade mark holders are of Croatian domain names, Anchovy News readers are adequately protected before registrations open up to the advised to ensure that their Croatian domain name portfolio is general public on a first come, first served basis. secure and that their domain name renewals are being dealt with according to the new registrar system. In this regard it is worth noting that the Sunrise Period under EMARAT for the United Arab Emirates) for trade mark.) ارات. To visit the CARNet website please go to: holders will begin on 27 September 2010. So far only http://www.carnet.hr/en . governmental organisations have been eligible to register, If you would like any further information regarding securing meaning that the website of HH Sheikh Mohammed Bin your intellectual property rights under the .COM.HR and .HR Rashid Al Maktoum, vice president and prime minister of the domain name extensions, please contact David Taylor at United Arab Emirates and Ruler of Dubai, is now available at [email protected] . a website address which is entirely in Arabic. will be opened up to trade mark holders in a phased ارات. manner, with priority being given first to trade marks registered in Arabic in the United Arab Emirates, then trade marks in IDN CCTLD UPDATE Arabic in any country, then trade marks in Latin characters in In the April 2010 issue of Anchovy News we reported on the United Arab Emirates, and finally trade marks in Latin the introduction of internationalised country code Top Level characters in any Arab country (for the purposes of domain Domains (often referred to as IDN ccTLDs) and in particular name registration in Arabic, trade marks in Latin characters will the fast track roll out process put in place by the Internet be transliterated). Registrations are set to open on a first Corporation for Assigned Names and Numbers (ICANN). come, first served basis on 11 December 2010. As regular readers will recall, until recently it was only If you would like further information concerning domain name or indeed any other available IDN ,ارات. possible to register the first part of a domain name in non registrations under Latin characters (depending on the characters allowed by ccTLD, please contact David Taylor at the particular ccTLD in question) but the second part of the [email protected] . domain name, the ccTLD part, remained one of the two letter To read more about the ICANN IDN ccTLD Fast Track country codes set by the International Organization for Process, please go to: http://icann.org/en/topics/idn/fast-track/ Standardization (ISO) which are all in Latin characters. 4 Domain name recuperation news
Bad faith registration and use under the UDRP: cumulative... or not?
BAD FAITH REGISTRATION AND USE UNDER THE (i) The domain name registered by the respondent is identical UDRP: CUMULATIVE... OR NOT? or confusingly similar to a trade mark or service mark in which the complainant has rights; and A. Nattermann & Cie. GmbH (the Complainant), a subsidiary company of Sanofi-aventis, recently lost a complaint filed (ii) The respondent has no rights or legitimate interests in under the Uniform Domain Name Dispute Resolution Policy respect of the domain name; and (UDRP) with the World Intellectual Property Organization (WIPO) concerning the domain name
Bad faith registration and use under the UDRP: cumulative... or not? (continued)
Given the facts, the Panel had no difficulty in finding that the In his dissenting opinion, Mr Donahey supported the panels in Domain Name had actually been used in bad faith. However, the so called Octogen trio of cases (named after Octogen whether or not the Domain Name had been registered in bad Pharmacal Company, Inc. v. Domains by Proxy, Inc / Rich faith was a complex question. The Panel first discussed Sanders and Octogen e-Solutions (D2009-0786) ) which whether the Respondent's offer to sell the Domain Name for advocated the view that if the legitimacy of a registration was an elevated price could lead to a finding of bad faith subject to compliance with certain conditions, a subsequent registration. In the Panel's view, bad faith registration could non-compliance with those conditions may make it a be invoked when an offer for sale was made shortly after the registration in bad faith, even if the registrant was intending to acquisition of a domain name, or when there was no other comply with the conditions when it registered the domain credible reason for a respondent to register a domain name. name. Under that particular line of cases, bad faith However in this case, the offer was made more than ten years registration and use was viewed as a unitary concept that after registration and the Respondent had a very good reason could not be separated, and Mr Donahey felt this to be the for registering the Domain Name, namely to promote the correct interpretation. Complainant's product as a result of their agreement. Taking into account the totality of the evidence produced by both Furthermore, in Mr Donahey’s view, even though the UDRP parties, the Panel was convinced that the Respondent had no was not a statute, it was a system of rules designed to intention of selling the Domain Name at the time of remedy a specific wrong and so the rules of statutory registration, or at least that was not its primary purpose when construction should apply, in particular the so called “mischief registration took place. rule” which meant the examination of what “mischief” or purpose the legislation was intended to prevent. According to The Panel went on to assess the possibility of inferring bad Mr Donahey, the purpose of the UDRP would appear to be faith registration from the Respondent's subsequent use of the twofold: first, to prevent consumers from being misled and Domain Name in bad faith, which was well established in this second, to provide trade mark owners with a relatively case. The Panel noted that in a number of cases, previous inexpensive mechanism to protect their rights. In Mr panels had held that a domain name had been registered in Donahey’s opinion, any decision that failed to find bad faith bad faith on the grounds that the respondent had registration and use when it was found that the respondent, in subsequently acted in bad faith. In the majority of the Panel's all the circumstances of the case, was acting in bad faith was view, the concept of ''retroactive bad faith registration'', a decision that failed to fulfil the purpose for which the UDRP broadened the language of paragraph 4(a)(iii) and was was intended. inconsistent with the ordinary meaning of the wording of the UDRP. The majority of the Panel was therefore inclined to Finally Mr Donahey explained why he believed that it was adhere to the generally accepted panel view that the original intended that panels be vested with discretion in their registration must be in bad faith. interpretation and application of the UDRP, based on various preliminary reports and committees and the actual wording of In view of the fact that the registration of the Domain Name in the UDRP itself. good faith was well established because the Complainant was well aware of the registration and did not complain about it Overall the decision is interesting as it highlights the fact that prior to the expiry of the licence, the majority of the Panel there is a very real difference of opinion between certain concluded that the third limb of the UDRP was not satisfied UDRP panels on the question of whether registration in good because bad faith registration could not be proved, only bad faith is necessarily fatal to a case. The majority of panels faith use. The Panel thus denied the Complainant's request believe that it is, although a certain number, like Mr Donahey, and refused to transfer the Domain Name. do not. It is unfortunate that such a difference of opinion has arisen, as it introduces an element of uncertainty for The majority of the Panel thought that the UDRP resembled complainants and devalues the UDRP as a straightforward, an international convention in its preparation and function, swift solution. The best advice for parties who wish to rather than a statute, and thus that it was appropriate to recuperate a domain name that was clearly registered in good consider the principles identified in the Vienna Convention on faith but has since been used in bad faith is simply not to use the Law of Treaties when deciding how to apply and interpret the UDRP but a different forum instead, if a negotiated its terms. Such principles provided that the UDRP should be solution cannot be found. A complaint under the UDRP in interpreted in accordance with the ordinary meaning of its such circumstances could nevertheless succeed with the right terms in their context and in the light of its object and purpose. panel, but relying on this would be risky in the extreme. In addition, the majority of the Panel considered the The decision is available at the following link: preparatory documents that were produced at the time that http://www.wipo.int/amc/en/domains/search/text.jsp?case=D2 the UDRP was introduced and concluded that they also 010-0800 . supported the view that bad faith registration and use were cumulative requirements, not alternatives.
6
Later trade mark rights: risk of reverse domain name hijacking
LATER TRADE MARK RIGHTS: RISK OF REVERSE To achieve the transfer of a domain name under the UDRP, a DOMAIN NAME HIJACKING complainant needs to establish all of the three following circumstances: A recent case decided under the Uniform Domain Name Dispute Resolution Policy (UDRP) by a panel from the World (i) The domain name registered by the respondent is identical Intellectual Property Organisation (WIPO) clearly underlines or confusingly similar to a trade mark or service mark in which the fact that registration of a domain name must generally the complainant has rights; and post-date the complainant’s trade mark rights or the complaint will be denied. This is because if a domain name is registered (ii) The respondent has no rights or legitimate interests in before the relevant trade mark, it is almost impossible to respect of the domain name; and demonstrate that the respondent was aware of and was (iii) The domain name has been registered and is being used specifically targeting the complainant, thus evidencing the in bad faith. necessary bad faith for a complaint to succeed. The Complainant claimed that he had registered the domain Cases where complainants with later trade mark registrations names
7
Later trade mark rights: risk of reverse domain name hijacking (continued)
Dolce & Gabbana fails to obtain
In this case, the Domain Name was registered in 1996 while declare in its Decision that the Complaint was brought in bad the Complainant set up his company VIRTUALEXPO in 2000, faith and constitutes an abuse of the administrative registered domain names including the name VIRTUALEXPO proceeding." The Panel therefore went on to find that the in 2003 and registered a trade mark in the name complaint was brought in bad faith and did constitute an VIRTUALEXPO in 2005. In this respect, the Panel quoted the abuse of the administrative proceeding. WIPO Overview of WIPO Panel Views on the following question: "can bad faith be found if the disputed domain name The decision is available at the following link: was registered before the trade mark was registered / http://www.wipo.int/amc/en/domains/search/text.jsp?case=D2 common law trademark rights were acquired?" 010-0941 . The consensus view on this question amongst WIPO Panels is that: DOLCE & GABBANA FAILS TO OBTAIN
Dolce & Gabbana fails to obtain
requiring information that is often primarily within the difficult for the Complainant to contest the Respondent's knowledge of the respondent. Therefore complainants are sworn evidence in a procedure such as the UDRP. simply required to make out a prima facie case that respondents lack rights or legitimate interests. Once such The Panel's closing remarks underline the fact that the case prima facie case is made, it is the respondent who carries the was a difficult one and could have gone either way based on burden of demonstrating rights or legitimate interests in the the facts at hand. If the Respondent had failed to respond or domain name. failed to supply detailed evidence it is possible that the Panel could have found against it. As the Panel pointed out, on the In this case the Complainant made out its case by asserting face of it the Respondent's assertions were somewhat thin, that the Respondent was neither commonly known by the but clearly the Respondent managed to do just enough to acronym ''D&G'', nor a licensee of the Complainant. However, convince the Panel that a business was really being planned the Respondent responded by submitting evidence that it had and that the evidence was not merely a montage designed to purchased the Domain Name with the intention of operating a camouflage the Respondent's real intentions and hoodwink marketing firm called D&G Marketing, short for David and the Panel. The case thus illustrates the importance of Goliath, as per the previous use of the Domain Name. In this submitting detailed evidence when responding to a UDRP regard it submitted evidence of its D&G logo, letterhead, complaint, particularly in relation to the issue of rights and business cards, an e-mail address and evidence of marketing legitimate interests in the domain name. the business through Facebook and Twitter. The Respondent also supplied an affidavit and brief supporting statements from The decision is available at the following link: three potential customers. http://www.wipo.int/amc/en/domains/search/text.jsp?case=D2 010-0813 . With regard to its attempt to solicit an offer to purchase the Domain Name shortly after obtaining it, the Respondent explained that it was in the business of acquiring domain names, creating corporate logos and branding programs, and selling entire branded portfolios (including domain names) to interested buyers. According to the Respondent this was viewed as a legitimate interest under the Policy. The Panel acknowledged that the evidence provided by the Respondent was ''somewhat thin in terms of proving business activity in the conventional sense'' . However, despite the Respondent's failure to prove the operation of an actual business, the Panel attached decisive importance to the Respondent's lack of intention to make any reference to the Complainant's business or even to the fashion and design fields where the Complainant operated. In the Panel's opinion, all the evidence was consistent with the Respondent's position that it was in the process of setting up an online marketing business, with the possibility that it may sell the Domain Name as part of its portfolio. The Panel also thought it was relevant that the letters ''D'' and ''G'' and the combination ''D&G'' were commonly adopted as business identifiers in the US market and elsewhere. Indeed five of the businesses approached by the Complainant with a view to soliciting an offer for the Domain Name would appear to have a legitimate interest in using the letters ''D'' and ''G'' as part of their operating name. As a result, the Panel accepted that the Respondent had rights and legitimate interests in the Domain Name. Therefore the complaint failed without the need for consideration of bad faith under the third limb of the UDRP. However, the Panel drew attention to the fact that a Court or Tribunal could have reached a different conclusion on the basis of more complete evidence. In the Panel's view it was 11 Anchovy - Global online brand management and protection
INTRODUCTION CONTACTS Intellectual property rights are at risk on the Internet, Principal Paris contacts and protecting clients' online presence is vital to current and future development of brands. The reflection of key brands, David Taylor [email protected] trade marks and company names online is more than just Jane Seager [email protected] registering a .COM domain name. There are some 250 country code Top Level Domains (ccTLDs) available, each providing the registrant with a global reach. Anchovy News editorial team The continual introduction of new domain name extensions Laëtitia Arrault and the constantly changing registration requirements in Vincent Denoyelle ccTLD Registries combined with the many and varied dispute Sean Kelly resolution procedures make the effective management of Daniel Madden brands online increasingly complex. Cindy Mikul Jane Seager Lionel de Souza HOW WE CAN HELP Sarah Taïeb David Taylor • We offer a comprehensive and centralised online brand Tony Vitali protection service named Anchovy ® for global domain name strategy, portfolio management and global Hogan Lovells (Paris) LLP enforcement using a unique and exclusive online platform 6 avenue Kléber developed in-house by our teams; 75116 Paris France • We specialise in the registration, management, protection and recuperation of domain names and clients’ rights on a worldwide basis; Local office contacts • We advise and work closely with clients on their global China Horace Lam domain name strategy and can register domain names of interest in all available ccTLD jurisdictions worldwide, France David Taylor assisting in meeting the varying pre-registration Germany Matthias Koch requirements, for example, trade mark registrations, company formation and local contacts; Hong Kong Gabriela Kennedy • In close liaison with our offices worldwide, we offer a Italy Luigi Mansani comprehensive domain name recuperation service comprising of an initial investigation (including a registrant Japan Lloyd Parker search), cease and desist letters, fixed fee UDRP/LDRP Netherlands Klaas Bisschop procedures, negotiations for domain name purchases and litigation. Poland Krystyna Szczepanowska-Kozłowska • We handle domain name transfers for clients, taking care Russia Natalia Gulyaeva of all necessary paperwork and technical issues relating to Spain Burkhart Goebel the re-delegation of domain name servers. United Kingdom David Latham
United States Shelly McGee FURTHER INFORMATION
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