THE MISSION AND PURPOSE OF THE NEW RESTRICTED .COMMBANK gTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST AND CONFIDENCE THROUGH THE ELIMINATION OF USER CONFUSION AND ASSURANCE OF BRAND AUTHENTICITY.

The new .commbank gTLD will operate as a restricted registry, in which the Commonwealth Bank of Australia (CBA) can create and control domain spaces that promote its brand identity and authenticity. In this regard, the .commbank gTLD will be used by CBA to provide information and services regarding CBA’s banking and financial services to customers in a way that promotes trust, confidence and utility. The .commbank gTLD will provide an authoritative internet space for CBA, its affiliates and partners that are associated with the CBA brand. Second and third level domain names can be utilised for online and mobile banking, products and services, and for marketing purposes, with internet users assured of brand authenticity.

CBA is Australia’s leading provider of integrated financial products and services including retail, premium, business and institutional banking, funds management, superannuation, insurance, investments and stockbroking. CBA is Australia’s largest retail bank with leading domestic market shares in retail deposits, home loans, personal loans, credit cards and discount stockbroking. In 2011, CBA was in the top 10 largest banks in the world by market capitalisation and was ranked equal 12th in Global Finance’s World’s 50 Safest Banks based on long-term credit ratings. CBA is listed on the Australian Stock Exchange with a market capitalisation of approximately AUD70 billion, 2011 revenue of AUD46 billion and over 52,000 employees. CBA is Australia’s leading online bank with over five million online banking customers. NetBank, CBA’s online banking website and application, is consistently in the top 10 most visited Australian websites. CommBank is a well-known short-form of Commonwealth Bank in Australia. Commbank.com.au, CBA’s central website through which NetBank can be accessed by customers, was awarded 2011 Banking Website of the Year by Australia’s Money Magazine. In this regard, consumer trust, brand reputation and continuous innovation are paramount considerations in all its activities. As well as strengthening CBA’s position as Australia’s leading online bank, the new .commbank gTLD will enhance consumer trust and confidence in CBA’s online brands by providing a more secure and authentic online banking environment. These goals will be complemented by CBA’s separate applications for the .cba and .netbank gTLDs.

Business activities are increasingly conducted over the internet, allowing for greater levels of interaction between businesses and customers. As a result, both businesses and end users benefit from ease of interaction and a wider range of choices with lower transaction costs. However, the development in this arena in the current domain name system has exposed both businesses and consumers to increased criminal activities over the internet, including data breach, hacking and phishing. These sophisticated criminal activities cause reputational damage to businesses as internet users lose consumer confidence and trust with the businesses targeted by such criminal activities. The .commbank gTLD will facilitate greater trust and assurance from internet users connecting with CBA online, whilst still allowing convenient and efficient interaction.

CBA’s mission and purpose of the proposed gTLD share ICANN’s initiatives to promote public interest. CBA is committed to contribute towards achieving such initiatives in line with ICANN’s Affirmation of Commitments, which include:

- consumer trust: the .commbank gTLD registry will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to CBA and its affiliate entities, at this stage, which will provide added consumer trust and confidence that .commbank domain names are completely secure and trustworthy. As .commbank domain names are subject to registration standards, policies and procedures under CBA’s control, this eliminates the possibility of malicious conduct within the .commbank gTLD;

- competition: the proposed new gTLD is not intended to instigate competition and consumer choice at the level of registration of domain names among prospective registrants. Instead it is anticipated to contribute to ICANN’s initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in the .commbank gTLD will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and

- consumer choice: the new gTLD will enable user-driven improvements and innovations assisting CBA’s marketing efforts through its ability to create new second and third level domain names on demand. These names will provide the consumers with more choices for interacting with CBA. As CBA has effective control over the registration and use of domain names under .commbank domain space, this will also contribute towards general service innovations on the internet.

Given the restricted nature of the .commbank gTLD, the projected number of registrations is likely to be about 10 to 50 domain names in the first three years. This number is likely to increase as CBA implements new products, services and marketing campaigns.

As the .commbank gTLD expands, CBA will continue to comply with all operational, technical and policy requirements, as well as maintaining consumer trust and the stability of the internet. CBA will keep ICANN reasonably informed of any material developments relating to .commbank gTLD including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.

CBA does not intend to utilise Internationalized Domain Names (IDNs) at the second level at this stage. Instead, CBA intends to create relevant domain names for online banking, products, services and geographic names at the second or third level. In accordance with registration policies and the proposed measures for protection of geographic names as outlined in response to Question 22, CBA will use geographic names to localise its websites in countries in which it operates. The use of geographic names is intended to:

- connect internet users with relevant information as applicable to the territory; and

- comply with required rules and regulations in the national territory.

CommBank is a well-recognised brand in the Asia-Pacific region with its “CommBank”, “Commonwealth Bank”, “Commonwealth Bank of Australia” and “Commonwealth Bank Group” trademarks registered in Australia for Insurance and financial services including banking and stockbroking (Class 36).

CBA has existing domain names with an exact match to its “CommBank” trademark and the applied-for .commbank string in the following spaces:

- gTLDs: commbank.asia, commbank.com and commbank.mobi.

- country-code TLDs (ccTLDs): commbank.com.au, commbank.net.au, commbank.cm, commbank.co, commbank.jp, commbank.co.nz, commbank.com.sg, commbank.sg, commbank.tw and commbank.vn.

Additionally, CBA has four gTLDS and three ccTLDs containing the “CommBank” trademark. Recently, CBA was successful in securing Sunrise application for the .xxx domain space based on existing trademark registration.

CBA believes that the .commbank gTLD is unlikely to cause confusion with either a generic term or any existing TLDs. CBA trademarks are a leading brand with significant reputation in the Asia-Pacific region and particularly Australia. CBA has used the term CommBank in conjunction with its online banking businesses for almost 17 years and CommBank is a well-known short-form of Commonwealth Bank. As such, the CommBank brand is well known for banking and financial services.