Can a Registry Operator register or Allocate domain names prior to the completion of the Sunrise Period to non-Sunrise Eligible Rights Holders?

The general rule is that domain names may only be registered during a Sunrise Period to Sunrise-Eligible Rights Holders who have a valid SMD file issued by the Trademark Clearinghouse. Unless the Registry Operator has received ICANN’s approval for an Approved Launch Program or ICANN implements a Qualified Launch Program as described in the TMCH Requirements, the Registry Operator may not register or Allocate domain names prior to the completion of the Sunrise Period to non-Sunrise-Eligible Rights Holders. An Allocation of a domain name includes any allocation, designation, assignment, or other form of earmarking of a domain name to a potential domain name registrant.

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