18.1 Mission and Purpose of .COUPONS
Coupons.com Incorporated (“Coupons.com”) is the recognized leader in digital coupons, including online printable, social, mobile, and save to loyalty card promotions. With approximately 500 employees worldwide, Coupons.com and its digital coupons network, including the Coupons.com website, is by far the largest provider of digital coupons in the world. Coupons.com offers products and services for consumers, brand marketers, retailers, publishers and developers. Coupons.com has filed this application for a .COUPONS gTLD with the intention of bringing to market a trusted, hierarchical, and intuitive namespace for consumers to access content related to coupons worldwide.

As the multibillion-dollar coupon industry is shifting online, Coupons.com has expanded both the supply of coupons (by using the Internet to lower the cost of entry for coupon issuers), as well as the demand for coupons (by introducing a new consumer demographic to coupons via websites, social media, and mobile devices). Coupons.com enables its clients’ coupon promotions on Web pages, in email campaigns, social media initiatives, mobile devices, store kiosks, shopping carts, consumer electronics and more. The company intends to further expand its reach across the digital landscape—anywhere there is a digital connection to consumers creating a digital marketplace where brands, retailers, and consumers can connect along the consumer’s path to purchase. Owning and operating the .COUPONS gTLD will be a vital asset to the company’s continued digital expansion.

Coupons.com will be analyzing and evaluating other .GENERIC gTLD applications as well as general market adoption to determine short- and long-term potential best-in-class use case options to most effectively serve and enhance Coupons.com’s online strategy as a leading provider of digital coupons.

The intended future mission and purpose of the .COUPONS gTLD is to serve as a trusted, hierarchical, and intuitive namespace provided by Coupons.com and qualified subsidiaries and affiliates for Coupons.com customers and interested parties.

Coupons.com intends to initially limit registration and use of domain names within the .COUPONS gTLD to Coupons.com and its qualified subsidiaries and affiliates. This initial limited use will allow Coupons.com to establish its operations and achieve full sustainability. This limited distribution, coupled with the other requirements set forth in Specification 9 of the template Registry Agreement, is intended to exempt Coupons.com from its annual Code of Conduct Compliance requirements.

After the fifth year operation, Coupons.com will evaluate whether opportunities exist to carry out the business strategy for the .COUPONS gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to parties other than Coupons.com and its qualified subsidiaries and affiliates.

The current best thinking involves a four-stage rollout:

Stage 1
The initial stage of implementation of the gTLD will involve Coupons.com registering a limited number of second-level domain names. This will provide Coupons.com’s information technology and security personnel with the time to run a number of tests to ensure seamless and secure access to .COUPONS domain names, as well as interoperability with various software and Web-based applications. This initial allocation will also allow the appropriate Coupons.com staff to coordinate with the internal and external staff responsible for the delegation and setup phases of the .COUPONS gTLD to ensure a proper transition from delegation to full operation.

Stage 2
Once the appropriate security and stability issues have been satisfactorily addressed, Coupons.com plans to begin allocating a limited number of domain names for internal corporate use. During this period of time, Coupons.com may also evaluate potential strategies to migrate Internet traffic away from its current gTLD and ccTLD domain name registrations.

It is in Stage 2 that Coupons.com will evaluate expanding the operations of the gTLD to permit registration by other registrants, such as licensees and⁄or strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other parties, this expansion is currently planned to take place during Stage 3. However, any expansion would be conditioned upon a review of the Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Coupons.com’s business model.

Stage 3
Depending upon the outcome of evaluations undertaken in prior stages, the third stage may involve the permanent migration of Internet traffic away from the TLDs in which Coupons.com’s domain names are currently registered, and toward the .COUPONS gTLD. It is in this stage that Coupons.com also may implement its decision to extend registration rights to licensees or strategic parties, depending upon compliance with Specification 9, as noted above. The dates of such expansion are subject to change depending upon business, strategic, and industry factors at the time.

Based on the company’s analysis of its existing domain name portfolio and its planned use strategy, coupled with the fact that it will have full control over the number of registrations in the .COUPONS gTLD namespace, Coupons.com’s business plan contemplates domain name registrations totaling well under 10,000 in the first five years of the .COUPONS gTLD’s operation.

Stage 4
Based on its experience with any expansion implemented in Stage 3, Coupons.com will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, including potential customers of Coupons.com. It is anticipated by Coupons.com that changes to the domain name industry will take at least five years to be realized and assessed. Any decision to expand the gTLDs beyond corporate, qualified subsidiary and affiliate, and licensee use will take into account this experience as well as the technical analysis of potential expansion.

The potential use of the .COUPONS gTLD by Coupons.com and its business segments will also be driven by Coupons.com’s future business strategies as identified on its website, see http:⁄⁄www.couponsinc.com⁄.

Utilizing current projections based upon Coupons.com’s existing businesses, future business plans, current domain name portfolio, and other strategic factors, Coupons.com estimates second-level domain name registrations to be in line with the projections set forth in the financial template provided in the response to Question 46 of this application.