Hi Timothe,
I think we are saying the same thing in different words. I would truly
support your submission of a statement with your words -- and all who
want to sign on to them. The more the merrier - especially since only
trademark owners have responded so far!
Best,
Kathy
----- Original Message -----
From: "Timothe Litt"
To:"Kathy Kleiman" , "NCSG-Discuss"
Cc:
Sent:Wed, 29 Apr 2015 18:13:12 -0400
Subject:Re: Comments on the Draft Rights Protection Mechanism Review
paper - now finishing ICANN Public Comment
Kathy,
No doubt you'll be unsurprised by my reaction. But I'll say it
anyway.
What about non-trademark holders rights? You know, those
individuals/families/clubs (organizations with a lower-case O) who
want
a name for non-commercial, non-trade, non-Organizational use? In the
original scheme (that created DNS from HOSTS.TXT), .COM was for
COMmercial. And trademarks having priority there made (and makes
sense.) And .com. allowed for the geographic scope of most
trademarks.
The other TLDs, such as .edu (and .edu.) also had an intended
scope, making it easy to distinguish harvard.edu (the university)
from
harvard.ma.us(the town in Massachusetts) from harvard.ma.gov from
harvard.org (now dormant) and from harvard.com (the Harvard
bookstore).
At this point, it seems that any trademark holder can assert the
right
to his mark in any TLD, any geo, and with priority over any
individual.
(Say, the descendants of John Harvard...)
I've not seen any TLD with a sunrise period for non-trademarks. Or a
prohibition against squatting on non-trademarks to prevent their use
by
individuals.
Individual (non-Organization, non-tradmark holding) registrants and
would-be registrants need to be explicitly called-out and need to
have
explicit protections. I'm fine with commercial TLDs that prioritize
trademarks. As long as there are accessible TLDs for the rest of us,
where trademarks need not apply. And some grandfather protection for
those of us who registered in the TLDs of polluted intent before the
expansion of the TLD universe...
Of course I appreciate and support your concern for "fairness and
balance" and all your efforts to comment. They are necessary - but
not
sufficient - to address the fairness and balance required to meet the
needs of my segment of the constituency.
Timothe Litt
ACM Distinguished Engineer
--------------------------
This communication may not represent the ACM or my employer's views,
if any, on the matters discussed.
Kathy,
On 29-Apr-15 15:37, Kathy Kleiman wrote:
>
>
>
>
>
>
>
> Dear All,
> ICANN has published a draft of its “Rights
> Protection
> Mechanisms Review” to ask whether the “rights protection
> mechanisms” of the New
> gTLD Program work. These include the Trademark Clearinghouse
> (TMCH), mandatory
> Sunrise Period in all gTLD to allow trademark owners to register
> first, Uniform
> Rapid Suspension (URS) process, etc.
> The young NCSG played a special role in this
> process in
> 2009-2010. We spent 7 weeks in tight negotiations with the other
> Stakeholder
> Groups to try to balance the rights of intellectual property
> owners with those
> of new/small businesses, noncommercial entities, users of all
> stripes and the
> registry/registrar communities. The NCSG team on the “STI”
> (“Special Trademark
> Issues” Working Group was Robin Gross, Konstantinos Komaitis,
> Wendy Seltzer and
> me with Mary Wong and Leslie Guanyuan as our
> Alternates.
> Now as this all comes up for review again, I
> think ICANN
> Staff has lost its way. This Draft Rights Protection Mechanism
> (RPM) report does
> not mention anything about the fairness and balance we tried to
> put in; it does
> not ask whether abuse about whether Registrants receive good
> education about
> the new domain name dispute proceeding for the URS and its
> defenses (the answer
> is No) or whether legitimate “fair use” of words in domain
names
> are truly being
> protected.
> Accordingly, I share a set of comments I have
> drafted. These are due
> shortly (sorry, ICANN’s Proxy/Privacy
> Accreditation Working Group kept us busy!) – tomorrow (Thursday)
–
> so I
> circulate them to all who would like to sign on.
>
> So far, no one has responded to this draft
> report with any interest
> in freedom of expression, fair use or the rights of Registrants. I
> guess that’s our job
style="font-family:Wingdings;mso-ascii-font-family:Calibri;mso-ascii-theme-font:minor-latin;mso-hansi-font-family:Calibri;mso-hansi-theme-font:minor-latin;
> mso-char-type:symbol;mso-symbol-font-family:Wingdings">
style="mso-char-type:
> symbol;mso-symbol-font-family:Wingdings">:-)!
>
> Link:
>
href="https://www.icann.org/public-comments/rpm-review-2015-02-02-en">https://www.icann.org/public-comments/rpm-review-2015-02-02-en
>
style="font-family:Wingdings;mso-ascii-font-family:Calibri;mso-ascii-theme-font:minor-latin;mso-hansi-font-family:Calibri;mso-hansi-theme-font:minor-latin;
> mso-char-type:symbol;mso-symbol-font-family:Wingdings">
style="mso-char-type:
>
> symbol;mso-symbol-font-family:Wingdings">
> Best,
> Kathy (Kleiman)
>
class="MsoNormal">--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
>
> Comments Submitted by Members of the
> Noncommercial
> Stakeholders Group
> Thank you for the publication of the DRAFT
> Rights Protection
> Mechanisms Review paper. Clearly an enormous amount of work was
> done to compile
> and analyze quantitative and qualitative data on the use of
> specially-created
> mechanisms in the New gTLDs, such as the Trademark Clearinghouse,
> Trademark
> Claims and Uniform Rapid Suspension.
> It is very important, however, that the
> questions being
> asked in the report, and all future reports on this subject, be
> expanded to
> reflect the whole of the GNSO and ICANN’s goals in passing these
> rules: were existing
> rights protected, were existing
> fair use protections maintained and did ICANN avoid the creation
> of new or
> expanded intellectual property rights (which ICANN has no power or
> authority to
> create)?
> With the details as set out below, we urge that
> the final
> report expand its inquiry to see if the balance and fairness
> included in these
> mechanisms worked for all parties: both rights holders and
> registrants. Did
> these programs reflect the full range of goals and commitments for
> all parties
> that ICANN set out in their adoption?
> We
> respectfully
> request that we would like to see more of these issues of
> balance and fairness
> raised in the final report. For example, when the final report
> goes out to the
> Community with questions of whether the URS (Uniform Rapid
> Suspension) worked
> for trademark owners, we also should be asking whether the URS
> worked for New
> gTLD Registrants and what obstacles they faced to education and
> information in
> responding to URS claims.
>
> So the
> comments below
> both respond to questions raised by ICANN Staff – and new ones
> that we would
> like ICANN Staff to raise in the final version of this RPM
> Review to ensure
> that all sides and concerns are heard in the feedback that ICANN
> seeks.
> Specifically:
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">1.
> In Section 3.2.2 style="mso-bidi-font-weight:
> normal">Trademark Clearinghouse Word Marks:
style="mso-spacerun:yes">
> The section raises some good points that should be
> addressed more
> directly. The GNSO adopted rules for the protection of “word
> marks” – as in the
> specific text of a mark and the letters, numbers and symbols it
> may use, e.g.,
> HASBRO. The GNSO rules
> specifically did
> not embrace the registration of “design marks,” a mark
containing
> both wording
> and design features in which the font, the colors and the artistic
> elements are
> all part of the features protected by the trademark – and the
> individual
> letters and words are expressly NOT protected outside of the
> design packaging
> in which they are presented.
>
> The GNSO’s STI Recommendation
> specifically style="mso-bidi-font-style:normal">did not
> consider it fair to provide the extensive protection of the
> Sunrise Period and
> the Trademark Claims notices to lettering within a design mark –
> lettering
> offering “disclaimed” and expressly not protected as text alone
> and in
> isolation of its design – and yet that is precisely what the
> Trademark
> Clearinghouse (TMCH) has gone ahead and accepted.
style="mso-spacerun:yes"> Domain names and URLs don’t
> have design
> elements.
>
> We strongly request further
> inquiry into: how
> many design marks have been accepted? How many of them expressly
> disclaim the very
> letters and words that the TMCH is now protecting? How can we
> return to the
> original intent of the GNSO/STI rules and the limits adopted by
> the GNSO
> Council and ICANN Board?
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">2.
> style="mso-bidi-font-weight:normal">Section 3.3
> Proof of Use is an
> important feature
> of the TMCH; it is designed to prevent gaming of the system and
> unfair
> advantage to certain new registrants over others. In addition to
> requesting
> feedback from those who have used the Clearinghouse verification
> and Sunrise
> registration processes, it is important to request input from
> those who have
> observed these practices and wish to comment on whether the
> balance and intent
> to prevent individuals/organizations/companies from grabbing
> Sunrise spots
> without any existing trademark use has been met. Should the use
> requirements be
> expanded – eg., to trademarks of a certain age such as one
> year?
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">3.
> style="mso-bidi-font-weight:normal">Section 3.4
> Matching Rules: This
> is an important
> section as the rules of the GNSO’s STI were specially crafted to
> allow only
> exact matches. What the section does not include, and should, is
> why that
> decision was made. Going beyond “exact matches” created a
> firestorm of trouble
> for what is one person’s “mark contained” is another person
word.
> Inclusion of
> examples in the next version of this paper would be key to
> illustrating the
> point. Thus, an existing trademark in ENOM (an ICANN-Accredited
> Registrar), but
> such rules, would create a bar on the domain name registration of
> VENOM – and
> entirely different word (and one itself also trademarked now and
> it will be
> again and again in the future).
> Similarly, the ___ registrations of GOGGLE in the US
> Trademark Office
> did not prevent the registration of the domain name GOOGLE.COM or
> the
> registration of GOOGLE as a trademark in the US Trademark
> Office style="mso-spacerun:yes">
>
> A few clear illustrations
> would convey the
> ambiguity and difficulty of going beyond an “exact match” and
shed
> light on the
> rationale of the existing rule – a balanced approach as the next
> draft asks for
> additional input and possible changes.
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">4.
> style="mso-bidi-font-weight:normal">Section 3.5
> Trademark Clearinghouse Communications: style="mso-spacerun:yes">
> In the next version and other related inquiries, we would
> like ICANN
> Staff to reflect a much broader question. style="mso-spacerun:yes">
> Should the goal have been only “to reach trademark holders
> worldwide to
> inform them of the services related to the Clearinghouse via
> webinars and
> QF sessions” or should it have been to inform the worldwide
> community of a
> massive change in the rules of registration of domain names in the
> New gTLDs
> and a new set of protections and notices that ALL registrants
> should know about
> and understand. Did the
> TMCH devote even
> one second or one dollar to outreach, webinars and QA session
> to explain
> the impact of the Trademark [Claims] Notice to those receiving it,
> to answer
> questions that may arise from ambiguities or the publication of
> this new type
> of notice, or to ensure that those registrants who the Trademark
> Notice was
> meant to protect were not artificially “chilled” from moving
> forward with the
> registration of a domain name if they had the rights to do
> so.
> style="mso-bidi-font-weight:normal">
> While the TMCH has highly
> publicized that
> many potential registrants fail to “click through” a Trademark
> Claim, where is
> the additional information about why – so that the forms and
> notices can be
> tweaked to be fairer and more balanced? style="mso-spacerun:yes">
>
> Our concern is of course that
> no education and
> no information was provided to the global community by ICANN or
> the TMCH. style="mso-spacerun:yes"> This
> has left noncommercial registrants, small businesses, and
> individuals without
> the guidance that these rules and policies are designed to protect
> all legitimate
> overlapping uses of words, names, phrases, acronyms for future
> domain names,
> just as they have been protected for existing ones (see e.g., ACM
> as the
> Association for Computing Machinery and the Academy of Country
> Music, and DELTA
> as Delta Faucets, Delta Airlines, Delta Sigma Theta and Delta the
> symbol for
> change in mathematics.
>
> Is the TMCH only helping one
> side, and
> shouldn’t it be educating and communicating its rules, policies,
> protections
> and balances with all and for all users of the new gTLD domain
> name system?
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">5.
> style="mso-bidi-font-weight:normal">Section 4
> Sunrise Period: style="mso-spacerun:yes"> We request that the
questions
> in the next
> draft and related reports be expanded to see if the sunrise period
> gives unfair
> advantage to trademark owners far outside their categories of
> goods and
> services. In cases where a New gTLD caters to .PIZZA should Delta
> Airlines
> really have a right of first registration?
style="mso-spacerun:yes">
> For New gTLDs and future gTLDs catering to individuals,
> noncommercial organizations,
> religious groups, etc., should the Sunrise Period exist at all?
style="mso-spacerun:yes">
> style="mso-bidi-font-weight:normal">
> Inquiry style="mso-bidi-font-weight:normal">
> into whether an automatic and upfront registration benefit for
> existing
> trademark owners unfairly benefits McDonalds Restaurant in a
> .FAMILY or
> .CATHOLIC gTLD is a question that truly needs to be added and
> asked. Further, how can
> Sunrise Periods in future
> rounds be more narrowly tailored to the limited rights of existing
> trademark
> owners?
> style="mso-spacerun:yes">
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">6.
> style="mso-bidi-font-weight:normal">Section
> 4.2 Limited Registration Periods is an important section and
> one that fairly
> highlights the legitimate reasons why registries may want to open
> registrations
> to those who are not trademark owners, but otherwise fit into a
> category, such
> as football players seeking to register their names in .FOOTBALL
> prior to the
> opening in General Availability.
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">7.
> Section 4.5 style="mso-bidi-font-weight:normal">Reserved
> Names. Reserved names policy is one that raises a lot of
> questions and
> should be clarified in the future rounds. The idea of reserved
> unlimited
> numbers of domain names in a gTLD and releasing them to any
> “person or entity
> at Registry Operator’s discretion” may and has led to gaming
and
> anticompetitive
> activity. Can these Reserved Name policies be used to cherry-pick
> all of the
> best names by one industry competitor and bypass ICANN’s rules
> barring closed
> generics? This is an
> important inquiry
> for the next round. style="mso-spacerun:yes">
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">8.
> style="mso-bidi-font-weight:normal">Section 5
> Trademark Claims Service:
> The
> Trademark
> Claims Services, as discussed above, has raised a number of
> questions
> and concerns. Questions we request be asked in future drafts and
> related reports
> include:
>
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l1 level1 lfo3">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">a)
> Is the Trademark Notice
> being shown to all
> Registrants?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l1 level1 lfo3">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">b)
> Do all registrants
> understand the trademark
> claims notice?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l1 level1 lfo3">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">c)
> Why are so many potential
> registrants not
> registering domain names after reading the Trademark Notice? Are
> they actually cybersquatters
> or are potential legitimate customers being “chilled” by
language
> of the notice
> or the inability to understand the notice (either the phrasing or
> not reading
> it in a language they speak?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l1 level1 lfo3">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">d)
> **How can we make the
> Trademark Notices better,
> clearer, fairer and more accessible so that those protected by the
> notices are
> protected and yet the limits, balances and fair use protections
> adopted by the
> GNSO Council and ICANN Board are achieved as well?
style="mso-spacerun:yes">
> style="margin-left:1.25in;mso-add-space:
> auto">
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">9.
> style="mso-bidi-font-weight:normal">Section
> 5.2, Inclusion of
> Previously Abused
> Labels: there is a lot of concern re: how this non-policy
> was created and
> implemented by ICANN. In
> light of the
> complaints brought against it, and apologies issues, shouldn’t
the
> report and
> future versions be asking if this “50+” policy should be
> reasonably limited, or
> rolled back completely?
>
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">10.
> style="mso-bidi-font-weight:normal">Section
> 5.3, Extensions of Trademark Claims Service, may be a completely
> invalid
> offering. The GNSO’s adopted rules and those of the ICANN
> Board were
> clearly limited in how long a Trademark Claims Service would
> last. style="mso-spacerun:yes"> Trademark Owners are
> responsible for the
> policing of their own marks and there are many private services
> and public
> tools they can use. Should the ICANN Community be subsidizing or
> allowing such
> an expanded and even unlimited extension of the Trademark
> Claims Service and
> what are the intended and unintended consequences to the most
> vulnerable of our
> potential future registrants: including noncommercial
> organizations,
> individuals and small businesses and entrepreneurs?
style="mso-spacerun:yes"> What is the impact on those
> in developing
> countries? What is the
> impact of those
> who don’t speak English (e.g., those now registering in our
> Internationalized
> Domain Names)? Is the
> TMCH unlimited
> extension fair, is it being invalidly subsidized or even paid
> for by the ICANN
> Community without authorization and should it be stopped?
>
>
> We strongly request that the
> inquiry of the
> next and similar reports be expanded to include the questions
> above and whether
> the TMCH is allowed to write its own rules.
style="mso-bidi-font-weight:
> normal">
> style="mso-spacerun:yes">
> style="text-indent:-.25in;mso-list:l0 level1 lfo1">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">11.
> style="mso-bidi-font-weight:normal">Section
> 6, Uniform Rapid
> Suspension: we would
> like to see the next and future
> reports reflect that the URS was a controversial mechanism -- an
> ultra-fast,
> ultra-cheap takedown mechanism for New gTLDs – and many were
> worried about
> whether registrants would be able to respond.
>
> Clearly, registrants ARE
> responding, and in
> far greater numbers than we expected given that half the URS
> claims receive a
> response. Do Registrants have the information they need to
> respond? Do they
> understand the special defenses offered in the URS? Are they using
> them?
>
> Additional questions that need
> to be asked
> in the next draft of this report and similar reports must reflect
> the education
> and rights of both sides, the claimant and the respondent, and
> they must include:
>
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">A.
> Who is educating New gTLD
> Registrants globally
> on the existence of the URS?
>
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">B.
> Who is educating
> registrants about the key
> differences of the UDRP and URS, including the much more rapid
> time needed for
> response, the different standards of proof, and the much more
> expanded
> defenses? style="mso-spacerun:yes"> Where are the ICANN Webinars,
> ICANN LEARN
> Websites, FAQ pages and Q A sheets?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">C.
> Who is educating
> Registrants about the appellate
> mechanism of the URS?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">D.
> Is anyone using the
> Appellate Mechanism of the
> URS?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">E.
> Are Panelists being rotated
> as required by the URS
> rules?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">F.
> Is the limitation of the
> URS to English
> proceedings – even in the Internationalized Domain Names (!!) –
> operating a
> barrier to responses by Registrants? What percentage of URS cases
> are coming
> from the IDNs?
> style="margin-left:1.25in;mso-add-space:
> auto;text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">G.
> How can ICANN and the URS
> Providers improve the education
> of Registrants around the URS rules, URS process, and special URS
> defenses and
> rights for registrants?
> style="margin-left:1.25in;mso-add-space:auto;
> text-indent:-.25in;mso-list:l2 level1 lfo2">
style="mso-bidi-font-family:Calibri;mso-bidi-theme-font:minor-latin">
style="mso-list:Ignore">H.
> How can we improve
> monitoring of the monitoring
> and reporting of the URS results?
> Conclusion:
> Our thanks again to the ICANN Staff for such a
> comprehensive
> report. A huge amount of work was done, but work still remains. As
> in every
> type of intellectual property rights protection system
> (legislative,
> regulatory, etc.), the questions are always asked: are the rights
> holders
> protected, but also is the public protected, are all future rights
> holders
> protected, are free speech, freedom of expression, fair use and
> the rights of
> all to use dictionary words, generic words, common acronyms and
> phrases as well
> as their first and last names protected to the fullest extent of
> national laws,
> and international treaties? Are these rights in balance, and
> carefully drafted
> by the IRT, the STI and when adopted by the GNSO and ICANN Board?
>
> The next version of this report – and all
> future reports
> including the upcoming UDRP Review – must include this fair and
> comprehensively
> balanced inquiry. We must
> remain fully cognizant
> that we are adopting these rules and seeking to protect the
> balanced rights of
> the whole of the Internet Community, which is now the world.
style="mso-spacerun:yes"> This is not just a world of
> commerce, it is a
> world of free speech, democratic development, and freedom of
> association,
> rights that are impacted by restrictions on the use of
> words.
>
> Sincerely,
> THE UNDERSIGNED MEMBERS OF THE NONCOMMERCIAL
> STAKEHOLDERS
> GROUP
> Kathy Kleiman, Co-Founder Noncommercial
> Stakeholders Group,
> NCSG Representative to Special Trademarks Initiative
> Team
> Stephanie Perrin, NCSG Canada
> OTHERS – NAMES, TITLES, AND/OR COUNTRIES
> WELCOME!!!
>
>
>
>
href="file:///C:%5CUsers%5Ckleiman%5CAppData%5CLocal%5CTemp%5Cmsohtmlclip1%5C01%5Cclip_filelist.xml">
> Penn Engineering Overseers’ Meeting
>
>
href="file:///C:%5CUsers%5Ckleiman%5CAppData%5CLocal%5CTemp%5Cmsohtmlclip1%5C01%5Cclip_themedata.thmx">
>
href="file:///C:%5CUsers%5Ckleiman%5CAppData%5CLocal%5CTemp%5Cmsohtmlclip1%5C01%5Cclip_colorschememapping.xml">
>
>
>
>
>
>
>
>
>
>
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