Com and .Net, Make Room for .Trademark: What Trademark Holders Should Know About the New gTLD Program
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.Com and .Net, Make Room for .Trademark:
What Trademark Holders Should Know About the New gTLD Program
Elizabeth Herbst Schierman
Dykas, Shaver & Nipper, LLP
If you are a business owner, you have
...the World Wide Web stands to welcome potentially
probably invested a great deal of time hundreds or thousands of new generic top-level domains
and money into building the goodwill of (gTLDs) in 2010...
your business and into associating that
goodwill with a business name, logo,
or other trademark. You want your cus-
tomers to know that when they see your
trademark on a flyer, commercial, letter,
or email, they are receiving a message
domain names to prevent someone else For years, ICANN has been devel-
from your business. Imagine the night-
from registering them, a preventative oping a new policy that will allow sig-
mare of learning that someone else has
measure to combat cybersquatting and nificantly more gTLDs to be introduced.5
registered a domain name using your
trademark infringement. The final step in the adoption and imple-
trademark and has been using the website
This tactic of registering multiple mentation of the New gTLD Program
at that domain to sell competing goods
websites at [trademark].com, .net, and will be the completion of an Applicant
or services to customers who think they
.org, among others, is commonly used by Guidebook to provide detailed informa-
are buying from
businesses that own valuable trademarks tion about the rules, requirements, and
your business. It
rights, and it has been used successfully process for acquiring new gTLDs.6 Ver-
is equally terrify-
in a world where the number of available sion 3 of the Guidebook was released
ing to learn that
top-level domain (TLD) names has been in October 2009.7 The final Guidebook
someone else has
rather limited. However, as the World is expected to be released at the end of
registered your
Wide Web stands to welcome potentially 2009, with applications for new gTLDs
trademark in a do-
hundreds or thousands of new generic to be accepted in 2010.8
main to lure your
top-level domains (gTLDs) in 2010, The New gTLD Program is meant to
potential custom-
trademark holders will likely find that allow for a greater degree of innovation
ers to a website
Elizabeth Herbst registering www.TheirTrademark.com, and choice for those who register domain
that publicizes
Schierman .net, and .org will no longer be sufficient names and utilize the Internet.9 It will al-
disparaging re-
when www.TheirTrademark.anything low for new gTLDs to be created, gTLDs
marks about your
and .everything are possible. that are not limited to only a few char-
business. You can only imagine the
acters or to only ASCII characters.10 For
number of potential customers who have History of TLDs, Their Control, the first time, Internationalized Domain
entered your trademark as a search term and the New gTLD Program Names (IDNs), domain names including
in Google or as a website address only As of the writing of this article, the local language characters or letter equiv-
to land at that other website, not yours. Internet’s addressing system has been alents, will available as TLDs.11 Accord-
Lost sales and damage to your reputation limited to a rather small number of TLDs. ingly, trademark holders could possibly
may increase through the drawn-out and TLDs are the two or more letters that fol- acquire new gTLDs consisting of their
expensive process of trying to dispossess low the last dot in a website address and trademarks.
that other person or business of the do- come in two types: gTLDs, such as .com Acquiring a new gTLD will not be
main name that was wrongly registered. and .net, and country-code top-level do- simple and will certainly be much more
That process is made all the more diffi- mains (ccTLDs), such as .uk and .cn.2 complicated than registering a second-
cult when the cybersquatter11 is not with- At this time, while there are over 250 level domain name using an established
in the personal jurisdiction of the United ccTLDs, there are only 21 gTLDs.3 gTLD. A second-level domain name is
States. The Internet Corporation for As- the portion of a website address (i.e.,
Visit www.Cabelas.com, www.Cabe- signed Names and Numbers (ICANN) domain name) that precedes the top-level
las.net, and www.Cabelas.org, and you has been responsible for managing the In- domain, e.g., the “Cabelas” in www.
will find yourself at the same website, ternet’s addressing system for more than Cabelas.com. Acquiring a new second-
not three separate websites. Each domain
ten years. It coordinates the allocation level domain name with an established
name points to one website, owned and
and assignment of, among other things, gTLD like .com or .net, is usually as
operated by Cabela’s Inc., with the Ca-
domain names, and it has overseen the simple as filing out a short form and
bela’s® trademark prominently displayed
growth of the number of gTLDs from the paying a relatively-small annual or
in the upper left-hand corner. Obviously,
eight that pre-date ICANN’s formation semi-annual fee to a registrar such as
Cabela’s has no interest in operating a
(.com, .edu, .gov, .int, .mil, .net, .org, and GoDaddy.com. The registrar takes the
separate website at each of the separate
.arpa), through two rounds of gTLD ex- information from the would-be domain
website addresses, and yet it separately
pansions, to the twenty-one gTLDs that name registrant, checks to confirm that
registered each of these domain names.
existed at the end of 2009.4 the domain name is available, and then
Undoubtedly, Cabela’s registered these
registers the new domain name with
The Advocate • February 2010 25 ..the registry operator associated with
the appropriate gTLD (e.g., if seeking
to register a domain name in the .com
gTLD, the registrar would register the To have standing to file a legal rights objection, the
new domain name with VeriSign, Inc., the objector must be a rightsholder, and the objector must
Registry Operator for the .com gTLD12).
The registry operator would then add
provide documentation of the source and existence of the
the new domain name to the registry legal rights at issue.
database. In this process, there is little that
is required by the would-be registrant of
the second-level domain name, and the
process is completed almost immediately
upon the registry operator’s receipt of a
string review, looking for string similari- by which trademark holders are poten-
registration request.
ty, during an Initial Evaluation of all new tially protected, the end result being that
Acquiring a new gTLD, on the other
gTLD applications; (2) for formal objec- the application for the new gTLD is not
hand, will require the prospective own-
tions of pending gTLD applications, re- approved and the gTLD is not put into
er to complete a complex application
solved by a dispute resolution process; operation. However, because the com-
to prove the applicant is ready, willing,
and (3) for a Trademark Post-Delegation parison is limited to only established and
and capable of operating a registry busi-
Dispute Resolution Policy (PDDRP) concurrently-applied-for gTLD strings,
ness as the registry operator for the new
to which the registry operators of new for a trademark holder to be “saved” by
gTLD; payment of fees in the neighbor-
gTLDs will be subject. These three this mechanism, the trademark holder
hood of $185,000; and signing a contract
mechanisms are tools to prevent a regis- would need to have already acquired or
with ICANN governing the operation of
try operator from acquiring a new gTLD have concurrently applied for a gTLD
the gTLD, provided the applicant has
that infringes upon the trademark rights consisting of its trademark. Further,
successfully survived the application
(or other rights) of another or otherwise as the string review is limited to visual
process, including an objection period.
operating a gTLD in a manner that sys- comparison, the string review mecha-
The application process is expected to
temically infringes or cybersquats upon nism will likely do little to protect a
take several months from beginning to
another’s trademark rights.16 Trademark trademark holder against a third party ap-
end.
holders would be well advised to be cog- plying for a confusingly-similar sound-
Surely, there are trademark holders
nizant of these mechanisms and to posi- ing gTLD (e.g., .Costco compared with
who have the resources and willingness
tion themselves to utilize them to prevent .KostKo). Nonetheless, the string review
to secure their trademarks as new gTLDs,
or combat trademark infringers and cy- mechanism does mean that trademark
either to be able to utilize www.____.
bersquatters. holders that do take the time and incur
[trademark] as their own or to simply pre-
the expense to acquire gTLDs for their
vent a third party or competitor from ac- Initial Evaluation
trademarks will have this one quick and
quiring that gTLD.13 However, given the of New gTLD Application
free shot at stopping third parties from
complexity and expense of the applica- by ICANN
acquiring gTLDs that are confusingly
tion process and the ongoing, contractual The first RPM that will come into
similar in appearance to the trademark
commitments accompanying the acqui- play as part of the New gTLD Program is
holder’s marks.
sition of a new gTLD, many trademark the string review during the Initial Evalu-
holders will find it unfeasible to acquire ation stage of the application consider- Formal Objection and Dispute
new gTLDs for their trademarks. These ation process. After applications for new Resolution Process
trademark holders need to be aware of gTLDs are received and the application After the Initial Evaluation stage in
the rights protection mechanisms that period closes, an Initial Evaluation stage the application review process, ICANN
the New gTLD Program is expected to begins during which ICANN will, among will post, on its website, a list of com-
provide as means for preventing or com- other things, evaluate whether each of the plete applications for gTLDs being con-
bating cybersquatting and trademark in- applied-for gTLD strings is so similar to sidered. This list, once posted, will be
fringement. other already-established gTLDs or ap- publicly available and its posting will
The rights protection mechanisms plied-for gTLDs that it would cause con- initiate an Objection Filing / Dispute
(RPMs14) that the New gTLD Program is fusion.17 String confusion will be found Resolution period. During this period
expected to provide are aimed at further- where an applied-for gTLD string “so formal objections may be filed, but are
ing certain principles of the program, in- nearly resembles another visually that it limited to only four grounds: (1) string
cluding that “[s]trings [i.e., the sequence is likely to deceive or cause confusion.”18 confusion, (2) legal rights, (3) morality
of characters that make up a gTLD] It would have to be probable, not merely and public order, and (4) community ob-
must not be confusingly similar to an possible, “that confusion will arise in the jections.20 Of these, trademark holders
existing top-level domain . . .” and that mind of the average, reasonable Internet will be most interested in the first and
“strings must not infringe the existing user.”19 second grounds.
legal rights of others that are recognized Because this string review is initiated In filing a formal objection on the
or enforceable under generally accepted and conducted by ICANN at the start of grounds of string confusion, the objector
and internationally recognized principles the application review process, without alleges that the applied-for gTLD string
of law.”15 To carry out these principles, prompting, and at no extra cost to either is confusingly similar to either an exist-
the New gTLD Program is expected to the applicant or a third-party, it essen- ing TLD or to a concurrently-applied-for
provide (1) that ICANN will engage in tially provides the quickest mechanism gTLD (i.e., an applied-for gTLD being
26 The Advocate • February 2010considered in the same round of appli-
cations as the objected-to gTLD).21 To
have standing to bring such a formal
objection, the objector must be an exist- Thus, trademark holders will need to be on their toes
ing TLD registry operator or concurrent to take advantage of the formal objection and dispute
gTLD applicant.22 Unlike the string re-
view during the Initial Evaluation, how-
resolution mechanism.
ever, the consideration of whether there
is string confusion sufficient to prevent
the grant of the new gTLD will take into
consideration more than just visual simi-
larity. Accordingly, this mechanism will gTLD would create a likelihood of con- Resolution Policy.”30 As part of the PD-
be available to those trademark holders fusion with the objector’s mark as to the DRP, trademark holders will be able to
who have acquired or who are seeking to source, sponsorship, affiliation, or en- take action against a gTLD registry oper-
acquire a gTLD of their trademark and dorsement of the gTLD. ator that has operated in bad faith, “with
who want to prevent a third party from With either the string confusion or le- the intent to profit from the systemic reg-
registering a confusingly-similar gTLD gal rights objections, the formal objection istration of infringing domain names (or
string where the similarity is due to more and dispute resolution process should be systemic cybersquatting) or who have
than obvious visual similarity. a useful tool for trademark holders due to otherwise set out to use the gTLD for an
A formal objection on the grounds of its many benefits. First, the process is de- improper purpose.”31 The PDDRP will
a legal rights objection amounts to a con- signed to be rather quick, just a matter of not apply to a gTLD registry operator
tention that the applied-for gTLD string weeks.27 Second, all filings, including the who just happens to have infringing do-
would infringe the objector’s existing response from the gTLD applicant, are to main names registered in its gTLD.
legal rights.23 To have standing to file a be in English and the response is to pro- The PDDRP mechanism may be used
legal rights objection, the objector must vide the applicant’s contact information.28 to combat trademark infringement or cy-
be a rightsholder, and the objector must This can be quite helpful when dealing bersquatting at either the top level or the
provide documentation of the source and with a potential cybersquatter or trade- second level. Infringement at the top lev-
existence of the legal rights at issue.24 mark infringer in a foreign jurisdiction. el would be an infringement due to the
Notably, these objections can be based Third, because it takes place before the gTLD (the top-level domain) itself (e.g.,
on either a registered or unregistered gTLD is awarded, it should allow trade- www.domain.infringingstring), while
trademark.25 mark holders to prevent cybersquatting infringement at the second level would
During evaluation of a legal and trademark infringement before any be an infringement due to a domain
rights objection, the appropriate damage is done. Fourth, though the cost registered within the gTLD, but not the
dispute resolution service provider for the associated dispute resolution pro- gTLD itself (e.g., www.infringingstring.
panel will determine whether . . . cess will likely be in the range of several gtld). With a top-level infringement, the
thousand dollars (likely between $3,000 alleged infringer is the registry operator;
the potential use of the applied-for and $56,000 for most objections29), the with a second-level infringement, the al-
gTLD by the applicant takes unfair cost is still significantly-lower than ap- leged infringer is a domain registrant, not
advantage of the distinctive charac- plying for and operating a new gTLD. the registry operator. As such, the PD-
ter or the reputation of the objector’s However, the window during which for- DRP mechanism treats the two situations
registered or unregistered trademark mal objections can be filed will probably differently.
or service mark . . . , or unjustifiably be rather narrow, perhaps as little as two To succeed with a PDDRP complaint
impairs the distinctive character or weeks between the posting of the Initial regarding a top-level infringement, the
reputation of the objector’s mark, or Evaluation results and the close of the trademark holder (i.e., the complainant)
otherwise creates an impermissible objection filing period. Thus, trademark will likely need to prove by clear and
likelihood of confusion between the holders will need to be on their toes to convincing evidence . . .
applied-for gTLD and the object’s take advantage of the formal objection
mark . . . 26 that the registry operator’s affir-
and dispute resolution mechanism.
mative conduct in its operation or
This determination will take into Trademark Post-Delegation Dis- use of its gTLD, that is identical
consideration, among other things, the pute Resolution Policy (PDDRP) or confusingly similar to the com-
similarity of the applied-for gTLD to the The PDDRP mechanism is to be plainant’s mark, causes or materi-
objector’s trademark; whether the ob- used to protect trademark rights against ally contributes to the gTLD: (a)
jector’s acquisition and use of its trade- an entity that has already successfully
mark has been bona fide; whether the taking unfair advantage of the dis-
gone through the new gTLD application tinctive character or the reputation
applied-for gTLD is recognized in the process and been awarded the gTLD. At
relevant sector of the public as the ob- of the complainant’s mark, or (b)
the conclusion of that process, the opera- unjustifiably impairing the distinc-
jector’s mark, the applicant’s mark, or a tor of the new gTLD will be required to
third-party’s mark; the applicant’s intent tive character or the reputation of
enter into a contract with ICANN, with the complainant’s mark, or (c) cre-
in applying for the gTLD; whether and one of the terms being that the registry
to what extent the applicant has used or ating an impermissible likelihood
operator is required “to comply with and of confusion with the complainant’s
plans to use the gTLD in connection with implement decisions made according to
a bona fide purpose; and whether the ap- mark.32
the Trademark Post-Delegation Dispute
plicant’s intended use of the applied-for
The Advocate • February 2010 27Given the high burden of proof and
the requirement that the registry opera-
tor be operating in bad faith, trademark
holders will probably find it difficult to Most trademark holders will likely find that the best
win on such PDDRP complaints. How- and most practical option for guarding their trademarks in
ever, for trademark holders who missed
the narrow window of opportunity to as-
the face of the New gTLD Program will be to monitor the
sert a formal legal rights objection during application process and be ready to file any necessary
the application stage, the PDDRP mecha- formal string confusion or legal rights objections within the
nism could be their best option.
For success with a PDDRP complaint narrow objections period...
regarding a second-level infringement,
the trademark holder will likely be re-
quired to prove by clear and convincing
evidence
(a) that there is a substantial ongoing cured.36 In any regard, this mechanism and .org to prevent cybersquatting and
pattern or practice of specific bad faith provides a good tool for trademark hold- trademark infringement. Cyberspace is
intent by the registry operator to profit ers to combat ongoing cybersquatting or changing and trademark holders’ tactics
from the sale of trademark infringing infringement by registry operators. must change too.
domain names; and (b) of the regis-
try operator’s bad faith intent to profit Conclusion About the Author
from the systematic registration of The three RPMs described above are Elizabeth Herbst Schierman is a
domain names within the gTLD, that the most likely to be available to help registered patent attorney focusing on
are identical or confusingly similar trademark holders prevent or stop another helping businesses and individuals se-
to the complainant’s mark, which: (i) from confusing customers with the new cure and enforce their intellectual prop-
takes unfair advantage of the distinc- gTLD registrations. Even so, the surest erty rights. Her practice includes patent
tive character or the reputation of the way for a trademark holder like Wal- application preparation and prosecution,
complainant’s mark, or (ii) unjustifi- Mart, Cabelas, or Coca-Cola to prevent copyright and trademark registration
ably impairs the distinctive character a third party from acquiring new gTLDs procurement, and intellectual property
or the reputation of the complainant’s consisting of strings confusingly-similar litigation, including domain name dis-
mark, or (iii) creates an impermissible to its trademark is to be the first to reg- putes. Ms. Schierman holds degrees in
likelihood of confusion with the com- ister .walmart, .cabelas, or .cola, as the chemical engineering and law from the
plainant’s mark.33 case may be. This will obviously prevent University of Idaho and is the current
someone else from sending mass emails Chair of the ISB Intellectual Property
As with the first-level infringement to potential customers from www.cou- Law Section.
situation, the burden of proof to succeed pons.walmart or www.hunting.cabelas or
with a second-level infringement PDDRP Endnotes
www.coca.cola and operating websites at 1
Cybersquatting, generally speaking, is the reg-
complaint is high. However, because the those domains. However, registering the
complaint will necessarily be based on istration and use of a domain name with the bad
gTLD before a third party can do so will faith intent to profit from the goodwill of another’s
the registry operator’s actions during be a complicated and highly expensive trademark. One example would be the registration
operation of the gTLD, it is not a com- process, which will likely be impractical and use of Wallmart.com (with two l’s) for a mer-
plaint that could practically be brought for most trademark holders. chandise retail website, selling gods to those who
during the application stage through a Most trademark holders will likely are confused and think the site is associated with
formal objection. Thus, the second-level find that the best and most practical op- Wal-Mart Stores, Inc. (Wal-Mart has been smart
PDDRP complaint is likely a trademark tion for guarding their trademarks in the enough to register wallmart.com itself.)
holder’s best and only mechanism (un- face of the New gTLD Program will be
2
Country-code top-level domains are limited to two
der the New gTLD Program) to combat to monitor the application process and be
letters. See Root Zone Database, Internet Assigned
a systematic cybersquatting or trademark Numbers Authority, http://www.iana.org/domains/
ready to file any necessary formal string root/db/# (last visited Dec. 16, 2009).
infringing registry operator. confusion or legal rights objections with- 3
ICANN, Draft Applicant Guidebook, Version 3,
With either the top level or second in the narrow objections period, which Preamble (Oct. 2, 2009), available at http://www.
level PDDRP situation, a complaint may opens once ICANN posts the list of icann.com/en/topics/new-gtlds/draft-rfp-clean-
be brought by any trademark holder, applied-for gTLDs.37 Once that window 04oct09-en.pdf.
whether the trademark is registered or has closed, however, the PDDRP is avail- 4
ICANN, New gTLDs – Frequently Asked Ques-
unregistered,34 and the process is meant able for clear cases of cybersquatting or tions (last revised Oct. 24, 2008), http://www.icann.
to be relatively quick, on the order of trademark infringement due to bad faith org/en/topics/new-gtlds/strategy-faq.htm.
weeks. Even so, success for the trade- actions of the new gTLD registry opera-
5
Letter from Rod Beckstrom, CEO and President
mark holder will not result in a transfer tor.
of ICANN, to All Prospective Applicants for New
of the infringing domain name.35 Instead, gTLDs 1, available at http://www.icann.com/en/
In any regard, the explosion of new topics/new-gtlds/draft-rfp-clean-04oct09-en.pdf
remedies available range from monetary TLD options is almost assuredly going (last visited Dec. 6, 2009).
sanctions equaling the complainant’s fi- to occur in 2010, and trademark hold- 6
Id.
nancial harm to suspension of the registry ers should no longer rely solely upon 7
Id.; Draft Applicant Guidebook, note 2.
operator’s ability to accept new domain registering www.[trademark].com, .net, 8
ICANN, In Focus, Applicant Guidebook, http://
name registrations until violations are
28 The Advocate • February 2010www.icann.com/en/topics/new-gtlds/dag-en.htm
(last visited Dec. 16, 2009).
9
New gTLDs – Frequently Asked Questions, note
3. In any regard, the explosion of new TLD options is
10
Id. ASCII characters, generally speaking, are
those characters that would be found on the com- almost assuredly going to occur in 2010, and trademark
puter keyboard used in Enlgish-speaking countries. holders should no longer rely solely upon registering www.
They include the characters of the English alpha-
bet, punctuation, and other common symbols (e.g. [trademark].com, .net, and .org to prevent cybersquatting
[${/ \}). They do not include frequently-used sym- and trademark infringement.
bols in non-English languages, such as those of the
Cyrillic alphabet, Chinese characters, and Japanese
kanji and hiragana.
11
Id.
12
See ICANN, .com Registry Agreement (Mar. 1,
2006), available at http://www.icann.org/en/tlds/ 26
Watch” and “Sunrise Period” services. These two Id. at 3-14.
agreements/com/. 27
13 mechanisms would be tools particularly aimed at See id. at 3-9 (noting that responses to formal ob-
Likewise, there will probably be trademark
preventing third parties from registering cybersquat- jections are to be filed within thirty calendar days
holders who will invest in acquiring new gTLDs
ting or infringing second-level domains in gTLD of receipt of a notice from the dispute resolution
of the generic names of their products or services,
registries. These mechanisms would be in addition service provider that ICANN has published a list of
thereby preventing a competitor from doing so.
to the already-available Uniform Domain-Name formal objections).
The thought of .cola or .soda comes to mind. Were 28
Dispute-Resolution Policy (UDRP). At this time, it Id. at 3-8–3-9.
the Coca-Cola Company to acquire these gTLDs, 29
appears that the New gTLD Program will encourage, Id. at 1-32.
it could secure www.coca.cola and www.dietcoke. 30
but may not require, that gTLD registry operators Id. at 5-10.
soda while likely preventing www.pepsi.cola from 31
utilize the URS proceeding and Trademark Clear- ICANN, Proposed Trademark Post-Delegation
coming into existence.
14 inghouse mechanisms if and when such mechanisms Dispute Resolution Procedure (Trademark PDDRP)
As of the writing of this article, the rights pro-
are put into place. (Oct. 4, 2009), available at http://www.icann.org/en/
tection mechanisms (RPMs) of the New gTLD 17
Draft Applicant Guidebook, note 2 at 2-2. topics/new-gtlds/draft-trademark-pddrp-04oct09-
Program have not yet been finalized, so only the 18
Id. at 2-5. en.pdf.
mechanisms seeming to have the best chance of ap- 32
19
Id. Further, “[m]ere association, in the sense that Id.
proval and finalization will be discussed. As used in 33
the string brings another string to mind, is insuffi- Id.
this article, RPMs refer to any mechanism, policy, 34
cient to find a likelihood of confusion.” Id. Id.
or procedure within the New gTLD Program that is 35
20
Id. at 3-1–3-2. Id. (explaining that because only the registry oper-
designed to protect the rights of trademark holders. 21
Id. at 3-1. Importantly, formal objections grounded ator, and not the registrant or registrar of the infring-
The final New gTLD Program may define RPMs
on string confusion must be filed with the Interna- ing domain name, is a party to the dispute resolution
more narrowly.
15 tional Centre for Dispute Resolution, the institution proceeding, transfer of the domain name should not
ICANN, Generic Names Supporting Organiza-
that has been authorized to act as the dispute resolu- be available because transfer of the domain would
tion, Final Report – Introduction of New Generic
tion service provider for this category of objections. affect non-parties).
Top-Level Domains (Aug. 8, 2007), available at 36
Id. at 3-4. Id.
http://gnso.icann.org/issues/new-gtlds/pdp-dec05- 37
22
Id. at 3-2. Though this option is available to holders of regis-
fr-parta-08aug07.htm.
16
23
Id. at 3-1. Formal legal rights objections must be tered as well as unregistered trademarks, trademark
There has also been a great deal of discussion
filed with the Arbitration and Mediation Center of holders of registered marks will likely find it easier
about two other rights protection mechanisms:
the World Intellectual Property Organization. Id. at to succeed on a formal objection, and so holders of
a Uniform Rapid Suspension (URS) proceeding
3-4. unregistered marks would be well advised to formal-
to provide an expedited procedure for address- 24
Id. at 3-3. ly register their trademarks.
ing clear cases of trademark infringement and a 25
Trademark Clearinghouse to facilitate “Trademark Id.
The Advocate • February 2010 29You can also read
