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[Comment-Ip] Comment on Dispute Resolution Criteria

In light of the increasing popularity of trademark registrations for
marks which include the top level domain name .com, .org, etc, in my
opinion, serious consideration should be given to allowing those parties
who have a pre-existing national trademark registration which is
identical to the entire domain name (e.g., a registration for COKE.COM)
but not merely the second level (COKE), to be able to have a domain name
which was registered by a third party and that is identical to their
registration in its entirety, placed on hold.

This only seems just under the trademark law.  Also, situations such as
the following:  A TM holder for the name BURCH should be able to have
the domain name for BUR.CH placed on hold, if the TM holder can show
that he has prior rights in BURCH.  He is not likely to have rights in
BUR, which he is required to have under the current system.

Let me know if I can do anything further in promoting this point.

Best Regards,

John Moetteli
U.S. and Swiss Patent and Trademark Attorney
BUGNION S.A. Intellectual Property Counsellors
Geneva, Switzerland