Comments by Reebok International Ltd. on Proposed Uniform Domain Name Dispute Resolution Policy

[curt.krechevsky@reebok.com]

Reebok International Ltd. of Stoughton, Massachusetts, U.S.A ("Reebok")., owner
of the REEBOK trademark, respectfully submits these comments on the ICANN
proposal for a Uniform Domain Name Dispute Resolution Policy ("UDRP") as posted
on 29 September 1999.  As a member of the trademark and the Internet
communities, we very much appreciate the opportunity afforded to us by ICANN to
provide these comments.

1.  As the owner of a number of famous trademarks, including the REEBOK
trademark, Reebok's paramount concern is the effective protection of trademark
owners under the UDRP.  For example, Reebok continues to be victimized by
numerous attempts to register domain names that incorporate the REEBOK mark or
terms confusingly similar to that mark.  Stronger protection than is currently
available under the dispute resolution policy of Network Solutions Inc. ("NSI")
would be desirable.

2.  One of the most serious shortcomings of the NSI policy is the inability of a
trademark owner to protect against domain name registrations that do not use
only the relevant mark in conjunction with a gTLD.  For example, NSI currently
refuses to apply its dispute resolution policy to domain names such as
<wwwreebok.com> or <reebokstore.com>, nor will NSI invoke its policy against
domain names that represent deliberate bad faith misspellings of a famous mark,
such as <reabok.com>.

3.  In general, Reebok believes the ICANN UDRP proposal to be an improvement in
the protection available to trademark owners in the domain name area.  However,
we believe there are some opportunities to further strengthen the UDRP to
protect against domain name piracy / cybersquatting and to avoid confusion among
users of the Internet.

4.  As a longstanding and active member of the International Trademark
Association ("INTA"), Reebok supports and incorporates by reference the specific
comments and amendments submitted to ICANN by INTA on the proposed UDRP.

5.  In the preamble portion of Paragraph 4(b), the phrase "registration and use"
should be changed to "registration or use", to conform with INTA's comments
concerning Paragraph 4(a)(iii).


Please feel free to contact the undersigned with any questions or if additional
information is desired.

Sincerely,

Curt Krechevsky
Assistant General Counsel and Trademark Counsel
Reebok International Ltd.
100 Technology Center Drive
Stoughton, Massachusetts  02072-4705  U.S.A.

Telephone:  +1-781-401-7339
Fax:  +1-781-401-4780
Email:  <curt.krechevsky@reebok.com>