What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
The Applicant fully appreciates the concerns of ICANN, the GAC and other consumer protection authorities about the need to operate new gTLDs in ways that minimize social costs, consumer vulnerabilities as well as other time and financial resource costs. To achieve these goals this gTLD will not only employ the ICANN mandated minimum protections, but will also deploy the following innovative protection measures that will put the gTLD at the forefront of addressing these critical issues:
1) Abuse Prevention and Mitigation Policies and Procedures
The Applicant’s core mission and purpose is to create an environment where individuals and companies can interact and express themselves in ways never before seen on the Internet, in a more targeted, secure and stable environment. To achieve this goal the Applicant will be implementing a range of Abuse Prevention and Mitigation (ʺAPMʺ) policies and procedures.
These Policies and Procedures will include: 1) gTLD APM Plan, 2) Policies and Procedures to Minimize Abusive Registrations ,3) Abuse Point of Contact, 4) Policies for Handling Complaints Regarding the Abuse Policies, 5) Acceptable Use Policy (“AUP”), 6) Proposed Measures for Removal of Orphan Glue Records, 7) Resourcing plans for the initial implementation of, and ongoing maintenance of, the APM initiatives, 8) Registry semi-annual WHOIS verification, 9) Regular monitoring of WHOIS registration data for accuracy and completeness, 10) Registrar WHOIS self-certification, 11) WHOIS data reminder process, 12) Establishing policies and procedures to ensure Registrar compliance, which may include audits, financial incentives, penalties, or other means, 13) Registrar verification of WHOIS, 14) Abuse Response Process, 15) Policies and procedures that define malicious or abusive behaviour, 16) Service Level Requirements for resolution regarding APM issues, 17) Service Level Requirements for Law enforcement requests regarding APM issues, 18) Coordination of APM efforts with sector Groups and Law Enforcement, 19) Rapid takedown and suspension, 20) Controls to Ensure Proper Access to Domain Functions, 21) Enabling two-factor authentication from Registrants to process update, transfers, and deletion requests, 22) Enabling multiple, unique points of contact to request and⁄or approve update, transfer, and deletion requests, 23) Enabling the notification of multiple, unique points of contact when a domain has been updated, transferred, or deleted, 24) Additional Mechanism for Protection of Capital City Names, 25) Additional Mechanisms to Protect and Reserve IGO Names, 26) Governance Council Structure, 27) Efforts to increase Registrant Security Awareness, 28) Registrant Disqualification, 29) Restrictions on Proxy Registration Services, 30) Registry Lock. (Q28 for detail)
2) Rights Protection Mechanisms
The Applicant is firmly committed to the protection of Intellectual Property rights and to implementing all the mandatory Rights Protection Mechanisms (“RPMs”) contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Use of domain names that infringe upon the legal rights of others in the gTLD will not be tolerated and preventing abusive registrations is a core objective of the Applicant. The nature of such uses creates security and stability issues for the Registry, Registrars, and Registrants, as well as for users of the Internet in general. The Applicant will minimize time or financial resources costs by preventing abusive registrations and reduce opportunities for behaviours such as phishing or pharming. This will be achieved by implementing comprehensive registration, anti-abuse, and rights protection guidelines as defined in its AUP, as well as innovative additional RPMs such as the Mechanism to Protect IGO Names by blocking second level labels currently present in the .int zone file and the Mechanism for Further Protection of Capital City Names, as described below. In order to identify and address the abusive use of registered names on an ongoing basis, the Applicant will also incorporate and abide by the following RPMs and all other RPMs as specified in Specification 7 of the Registry Agreement and as adopted by the ICANN Board of Directors as ICANN Consensus Policies.
These Rights Protection Mechanisms will among other things include: 1) Trademark Clearinghouse, 2) Applicant’s Sunrise Period, 3) Trademark Claims Service , 4) Uniform Domain Name Dispute Resolution Policy, 5) Uniform Rapid Suspension System, 6) Trademark Post-Delegation Dispute Resolution Procedure, 7) Mechanism to protect IGO Names, 8) Mechanism for Further Protection of Capital City Names, 9) Efforts to promote WHOIS Accuracy, 10) Thick Searchable WHOIS, 11) Semi Annual Audits to Ensure Accurate WHOIS, 12) Policies Handling Complaints Regarding Abuse and Rights Issues, 13) Registry Acceptable Use Policy (“AUP”), 14) Monitoring for Malicious Activity. (Q29 for detail)
3) Governance Council Structure
The Applicant believes that sector stakeholders should be afforded the opportunity to influence the manner in which the gTLD is governed. Accordingly, the Applicant will establish a Governance Council (the “GC”) comprised of key sector stakeholders that will serve as an advisory body tasked with defining best practice recommendations for the gTLD space. The Applicant believes that the success of the gTLD will be determined largely by the sector’s key stakeholders. Not only will these stakeholders have the primary interest in registering domains in the gTLD, but they will also be motivated to protect the sector from practices that would negatively impact the sector overall. The GC exists to provide guidance on matters related to best practices, intellectual property, authentication, certification, and other matters of importance to the sector and it will elect its own Board of Directors, which will be responsible for self-governance, the recommendation of sector-specific policies, and other best practices related to the gTLD.
4) BITS and Coalition for Online Accountability (“COA”) Recommendations
The Applicant will further structure its policies around the BITS and COA Recommendations where relevant to this gTLD. The Applicant’s goal is to provide a safe and secure experience for consumers. A domain within this gTLD that is owned, operated by or compromised by a malicious party could cause harm to consumers, to the gTLDʹs reputation and to the reputation of the Internet itself. As such, additional controls are in place relating to the validity of registrations, as well as measures to ensure the correct identity of both Registrants and Registrars relating to changes made within the SRS, and to protecting the integrity of the DNS service as a whole.
The Security Standards Working Group (SSWG) formed by BITS drafted a set of policy recommendations that should be applied to financial TLDs. The policy comprises of a set of 31 recommendations that should be adopted by ICANN in evaluating any applicant of a financial gTLD. The recommendations were posted by BITS in the form of a letter to ICANN at [http:⁄⁄www.icann.org⁄en⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf].
The Coalition for Online Accountability have drafted a set of policy recommendations, also endorsed by many other international organizations representing the creative industries, that should be applied to entertainment gTLDs - especially those dependent on copyright protection. The policy comprises of a set of 7 recommendations that should be adopted by ICANN in evaluating any applicant for an entertainment-based gTLD. The recommendations were posted by COA in the form of a letter to ICANN at http:⁄⁄bit.ly⁄HuHtmq.
We welcome the recommendations from BITS and the COA and will strongly consider the recommendations relating to the implementation of this gTLD where considered relevant.
5) Registry Operators Startup Plan
The Applicant proposes to implement the following start-up plan so that the new gTLD is introduced in an orderly, transparent and stable manner. This will safeguard competition, fairness, trust and reliability for Registrants, the User Community, ICANN Accredited Registrars, and other Stakeholders.
The Applicant’s startup plan is designed to minimize social costs (e.g., time or financial resources costs, as well as various types of consumer vulnerabilities) by instilling a number of RPMs as well as APMs.
The plan consists of the following multi-phase process that will be executed by the Registry Operator. The timeline for the gTLDs start-up process and associated RPMs in the Applicants gTLD is as follows:
Phase 1 – Sunrise Process:
- Day 1: Sunrise round opens
- Day 60: Sunrise round Closes
- Day 61: Sunrise Allocation Including contention resolution mechanisms opens
- Day 71: Sunrise Allocation contention resolution mechanisms closes
• The following Rights Protection Mechanisms apply:
a. Trademark Clearinghouse (“TMCH”)
b. Sunrise Eligibility Requirements (“SER”)
c. Sunrise Dispute Resolution Policy (“SDRP”)
d. Uniform Domain Name Dispute Resolution Policy (“UDRP”)
e. Uniform Rapid Suspension System (ʺURSʺ)
f. Mechanism for the Protection of IGO Names (“PIN”)
g. Trademark Claims Service (“TCS”) *
Phase 2 – Landrush process:
- Day 72: Landrush opens
- Day 102: Landrush closes
- Day 103: Landrush contention resolution mechanisms opens
- Day 113: Landrush contention resolution mechanisms closes
- The following Rights Protection Mechanisms apply:
d. Mechanism for Further Protection of Capital City Names (“CCC”)
e. TCS *
Phase 3 – General Availability⁄Registrations:
- Day 114: General availability begins
- The following Rights Protection Mechanisms apply:
d. Trademark Post-Delegation Dispute Resolution Procedure (“PDDRP”)
e. TCS for the 90 days after day 114 *
* To ease the concerns of trademark owners and mitigate the impact of infringing registrations, the Applicant will be implementing the TCS in all three phases of launch. It is important to note that during the General Availability Phase, the TCS will be used for 90 days, 30 days longer than the ICANN mandated minimum.
18(C)(i) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Sunrise and Landrush periods:
During the gTLDs launch period, multiple applications for a particular domain name will be resolved through a Contention Resolution Mechanism (“CRM”) involving auctions. These CRMs will apply to the Sunrise and Landrush application phases. The CRMs will be conducted by Sedo GMBH, an experienced provider of domain auction services. The mechanisms offered will involve closed auctions where only specific bidders can participate.
During the Applicants Sunrise process, if there are two or more eligible applicants for one domain name string, then the contention will be resolved by auction. Auctions held during the Sunrise phase (“Sunrise Auctions”) will be closed and the only bidders will be eligible applicants according to the gTLDs Sunrise eligibility requirements including the TMCH.
During the Applicants Landrush process, if there are two or more eligible applicants for one domain name string, then the contention will be resolved by auction. Auctions held during the Landrush phase (“Landrush Auctions”) will be closed and the only bidders will be eligible applicants according to the gTLDs Landrush eligibility requirements.
After the two initial startup phases of the Registry the allocation of domain names will occur on a first-come first-serve basis, taking into account the registries APM and RPM mechanisms.
18(c)(ii) Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
Incentive, Marketing and Outreach Programs
The Applicant will implement a number of incentive, marketing assistance, awareness and PR programs to assist the Registrar channel in providing a sector leading experience to end-users and to provide cost benefits for registrants. The Applicant will work with the global Registrar channel to ensure that the new gTLD offer is clearly visible on registrar sites resulting in an increase in the awareness and in the number of new gTLD registrations. Achieving this visibility requires (1) a clear business case and incentives for registrars to motivate them and (2) mechanisms and assets to make it easy for them to do so.
The Applicant will at the time of launch depending upon market conditions consider incentive programs that will deliver cost benefits to registrants through either the use of advantageous pricing, introductory discounts, bulk registration discounts or other similar methods. The Applicant is aware of Specification 9 – Registry Operator Code of Conduct, and will not directly or indirectly show any preference or provide any special consideration to any Registrar in its marketing efforts.
Example incentive mechanisms the Applicant will provide to the registrars may include:
The Applicant intends to provide expertise, tools and creative assets to the registrars as part of general marketing and co-marketing programs. There is a significant cost saving if the expertise, tools and assets are developed centrally and the costs amortized across the registrar base. Significant cost savings can occur relating to Market Research, Social Customer Relationship Management (“SCRM”), Content Management Systems (“CMS”), Direct Marketing Tools, Marketing Collateral and Analytics Solutions.
The Applicant will employ some or all of the following marketing techniques jointly with registrars globally: (1) Direct Response Print, (2) General Web Marketing, (3) Email campaigns without Incentive, (4) Email with Incentive, (5) Email Marketing - Prospect List, (6) Email Marketing - Sponsored Newsletter, (7) Direct Marketing with Incentive, (8) Web Marketing with Incentive, (9) Viral Marketing (Social, Video, Micro-sites), (10) Develop User Interface Improvement best practices, (11) Develop Search Engine Optimization best practices, (12) Email Marketing - Registrar List
As an example of a marketing initiative, the Applicant will forward leads to the Registrars “buy” pages as an incentive via the means of Pay-Per-Click (“PPC”) search marketing. The Applicant will run multiple PPC campaigns targeting gTLD Registrants and point these to landing pages on the Registrar’s websites. Conversions are directly trackable from all PPC campaigns and keywords with a high Click-Through-Rate (“CTR”) or conversions will also be leveraged for SEO best practice purposes.
PR and Awareness Incentives:
In addition to the core outreach to the Registrar Channel, the Applicant will engage in a wider outreach to build awareness of the new gTLD with customers, end-users and other stakeholders. The Applicant will engage with a number of high profile individuals associated with the gTLD and will seek to reach end consumers through webcasts, podcasts, traditional broadcast TV as well as radio.
Provision of customer retention toolkits to Registrars:
The Applicant will use propensity modelling to build retention marketing programs to minimize churn whilst building renewal sustainability. The Applicant will develop econometric models designed to measure the likelihood of a customer segment to purchase a product or offer bundle, at a certain point in the relationship lifecycle. They are used to predict the best time, and the best combination of products, to offer to customers who match a certain profile. They are especially effective where there are large numbers of customers and reliable data can be gathered. The Applicant expects that registration volume in the gTLD will provide sufficient data for this modelling.
Measure, benchmark and improve the customer experience:
The Applicant will engage in a program to develop best practice policies related to the customer experience at differing levels of the channel. This will include the entire ecosystem from Registry through Registrar to Resellers and finally end-users. One key metric might be, for example, to reduce the number of clicks to make a purchase equivalent to the most customer friendly e-commerce sites in the world.
The Applicant might, for example, provide website performance tracking tools to registrars, which would benchmark current performance and provide insights into customers’ needs and behaviour at the point of purchase.
The Applicant will engage in a Social Customer Relationship Management Program to monitor social media feedback to questions, concerns or other issues. The Applicant will further seek to measure marketing communication expenditure and activity.
Other initiatives that will be considered by the Applicant in its outreach efforts:
(a) Customized Vertical Search App for major mobile platforms.
(b) Designated Twitter channel for the stakeholder community.
(c) Social Media outreach through Facebook and other social media solutions.
Translation into other languages:
At present, the Applicant plans to translate marketing collateral and other content that it considers to have geographically diverse appeal in to the 6 official UN languages, namely Arabic, Chinese (Mandarin), English, French, Russian and Spanish.
18(c)(iii) Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
The Applicant will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator has in excess of ten years of experience managing numerous gTLDs that utilize standard and unique business rules and lifecycles.
Initial registrations of registered names may be made in the registry in one (1) year increments for up to a maximum of ten (10) years. For the avoidance of doubt, the registration term for registered names may not exceed ten (10) years. Further the renewal of registered names may be made in one (1) year increments for up to a maximum of ten (10) years. For the avoidance of doubt, renewal of registered names may not extend their registration period beyond ten (10) years from the time of the renewal.
The Applicant plans to review domain name registration rates on an annual basis and will make a determination at that time regarding adjustments, depending upon market factors. Thus, at this time, the Applicant does not plan to make specific guarantees regarding pricing increases.
The Applicant will provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the gTLD advance written notice of any price increase (including as a result of the elimination of any refunds, rebates, discounts, product tying or other programs which had the effect of reducing the price charged to registrars, unless such refunds, rebates, discounts, product tying or other programs are of a limited duration that is clearly and conspicuously disclosed to the registrar when offered) that complies with the requirements as outlined in the New gTLD Registry Agreement.