The letter follows public comments the ANA made July 29 to the U.S. Department of Commerce, as part of a public review process before the new plan goes into effect in January.
"By introducing confusion into the marketplace and increasing the likelihood of cybersquatting and other malicious conduct, the ICANN top-level domain program diminishes the power of trademarks to serve as strong, accurate and reliable symbols of source and quality in the marketplace," ANA President-CEO Bob Liodice stated. "Brand confusion, dilution and other abuses also pose risks of cyber predator harms, consumer privacy violations, identity theft and cyber security breaches. The decision to go forward with the program also violates sound public policy and contravenes ICANN's Code of Conduct and its undertakings with the United States Department of Commerce."
Liodice added that the timing of the plan couldn't be worse, creating new costs and uncertainty for brand marketers "in the middle of the worst economic crisis since the Great Depression."
The new ICANN program would enable anyone prepared to pay $185,000 to apply for Web the simple brand domain names, which the ANA said would create a "Hobson's choice" for established brand marketers that might need to divert "marketing, legal, financial and technical resources" to applying for, managing and protecting their top-level domains or "risk band dilution."
"They are essentially being forced to buy their own brands from ICANN at an initial price of $185,000," Liodice noted.
The ANA's letter requests a written response from ICANN by Aug. 22.