.bet Pre-Register Domain - .bet Domain Information

Q18A
Mission and Purpose of .bet?
The Applicant's 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. Its aim is to become the premier online destination for such creators and their wide range of users. The Applicant will create an Internet space whose central function is to provide a platform for creating, producing and disseminating informative, creative and innovative content that is easily recognizable as pertaining to its stakeholder group. The Applicant is acutely aware of the importance of ICANN's mission in coordinating the global Internetʹs systems of unique identifiers and ensuring their secure and stable operation. The Applicant's core focus is to create a secure, sustainable, and specialized gTLD, thus supporting ICANN's primary goals for this program in promoting consumer trust, consumer choice, competition and innovation.

Why .bet?
Betting, when practiced responsibly, can be extremely enjoyable. It can also excite the passions, and command phenomenal attention and interest. Knowing this, we aim to unite these feelings under one electronic roof within .bet.

Since its inception the internet has revolutionized the way we communicate, empowered hundreds of millions with knowledge and created a platform where global commerce can thrive. However, access to the countless benefits and opportunities which the internet offers can often be hindered when navigating the ever-expanding sea of irrelevant and sometimes malicious content which also exists.

Thus, the aim of .bet is to create a blank canvas for the online bet sector set within a secure environment. The Applicant will achieve this by creating a consolidated, versatile and dedicated space for the bet sector. As the new space is dedicated to those within this affinity group the Applicant will ensure that consumer trust is promoted. Consequently consumer choice will be augmented as there will be a ready marketplace specifically for bet enterprises to provide their goods and services. All stakeholders within the sector will be able to sample reactions to new ideas, or gather thoughts on the improvements of established ones. This will drive innovation and competition within the bet sector as there will be new channels available not yet fulfilled by current market offerings. This new environment will cause registrants to seek new ways to separate themselves from the competition.

How will .bet take shape?
The Applicant believes that the success of the gTLD will be determined largely by the sector's key global stakeholders. These stakeholders will be interested in registering a domain and additionally be motivated to protect their sector from detrimental practices. The Applicant believes that stakeholders should have the opportunity to influence the gTLD and the way it is governed. Accordingly, the Applicant is establishing a Governance Council ("GC"), consisting of key stakeholders that will serve as an advisory body.

Why Applicant?
The Applicant has substantial combined experience amongst its team in managing global businesses from a financial, legal and operational perspective and an exceptionally strong financial position. The Applicant's Team has previous experience with the entire gTLD life-cycle significantly lowering any launch and ongoing operational risks associated with this application. The Applicant has engaged a world-class Registry services provider to manage the technical infrastructure of the .bet gTLD. The Applicant is further advised by the leading sector experts in all other areas required to ensure a responsible and successful launch and ongoing management of the gTLD to the benefit of all stakeholders in the ICANN community.

Information for future studies and reviews
The Applicant recognizes the connection of the new gTLD application to the Affirmation of Commitments ("AoC"). To gauge the success of the new gTLD program, the Applicant recognizes that an AoC Review Team will be formed one year after the first delegation. To prepare for this, the ICANN Board resolved the creation of a Working Group to formulate definitions of competition, consumer trust and consumer choice and possible metrics for the future AoC team to consider in its gTLD review. The Applicant understands this effort has not been adopted by the ICANN Board, but many of the proposed metrics may be used to gauge the Applicant's gTLD effectiveness and the gTLD program. The Applicant intends to track costs and benefit metrics to inform future studies and reviews. Proposed definitions are:
- Consumer Trust is defined as the confidence registrants and users have in the consistency of name resolution and the degree of confidence among registrants and users that a TLD Registry operator is fulfilling its proposed purpose and is complying with ICANN policies and applicable national laws.
- Consumer Choice is defined as the range of options available to registrants and users for domain scripts and languages, and for TLDs that offer choices as to the proposed purpose and integrity of their domain name registrants.
- Competition is defined as the quantity, diversity, and the potential for market rivalry of TLDs, TLD Registry operators, and Registrars.

Promoting Competition
Given the proposed definition for competition, the Applicant will attain this by contributing to the quantity and diversity within the Registry Operator space. The Applicant is a new entrant enhancing competition among the providers. The Applicant will promote competition for Registrants by amongst other things:
- Building a healthy growth trend of domain registrations
- Measure migration of content from other TLDs
- Maintain competitive pricing of domains

Promoting consumer trust
.bet will be developed with consumer trust and satisfaction in mind. After 2 years of operations, the Applicant will conduct a survey to measure consumer trust and consumer satisfaction. This will be used to improve the service. The Applicant will among other things measure the following:
- Service Availability of Critical Registry Systems
- Abuse and Takedown incidents
- Rights protection incidents
- WHOIS data accuracy

Promoting consumer choice
The Applicant intends to promote consumer choice by achieving the following:
- Display of registration requirements and restrictions in the gTLD
- Highly available and geographically diverse Registrar channel
- Effective sunrise and trademark services

Domain names will be available globally, although the Applicant's initial marketing efforts will be predominately directed to potential Registrants represented by the six (6) official languages of the United Nations ("UN Languages"), Arabic, Chinese (Mandarin), English, French, Russian and Spanish.
After the initial 2 years it is the Applicant's aim that:
- Registrants globally should have access to Registrar services for the gTLD in at least the six UN Languages
- The gTLD is offered by Registrars covering at least 40 Countries and territories globally

Information on the effectiveness of safeguards
The Applicant takes rights protection and abuse prevention and mitigation very seriously and has developed policies accordingly. Amongst others, the Applicant will collect and evaluate data regarding:
- Effectiveness of the Sunrise process in limiting abusive registration practices
- Effectiveness of the additional Abuse Prevention and Mitigation (ʺAPMʺ)and Rights Protection Mechanisms (ʺRPMʺ)in limiting abusive registration practices
- Effectiveness of the mandatory APMs and RPMs
-end-

Q18b
How do you expect that your proposed gTLD will benefit Registrants, Internet users, and others?

The Applicantʹs primary intention is to provide a favorable ecosystem for the growth and evolution of the sector. The key to achieving this aim are significant provisions for brand integrity and protection of intellectual property. The Applicant intends to push the boundaries of what can be done through innovative design of the new top level domain, including technologies that capitalize on the sectorʹs needs. A close relationship with the sectorʹs stakeholders is essential to this purpose, and will enable .bet to grow in response to both Registrant and user needs. The gTLD also contains significant opportunities as a next generation organizational scheme for online content, including provisions for abuse prevention to defend users against malicious registrations. The gTLD has been meticulously designed by a team of industry leaders from an array of different fields. This has enabled the creation of an airtight financial strategy, an inspired technological development plan as well as a close and dynamic relationship with the sector community - all critical needs on the path to the enduring success of the gTLD.

18(b)(i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

Specialty

The Applicant's key specialty goal is to enable a secure and stable gTLD dedicated to providing global Internet users with a targeted space for subject matter of interest. This gTLD will serve as a home for both Registrants and end-users who feel an affinity with this sector and its associated content. Consequently they will prefer to register domain names, create and post content and seek information in a highly targeted manner.

Allowing users the ability to create a targeted, unique space within the new gTLD will enable them to customize their online offering and presence. The .bet gTLD will by itself clearly signal the nature and purpose of such websites to Internet users.

The applicant intends to actively promote gTLD specific vertical searching in the gTLD for the benefit of Registrants, end-users and other stakeholders. This specialization through Vertical Search will also benefit Internet users seeking authentic online information and products or services as they will no longer have to wade through content completely unrelated to their desired results.

As the gTLD is sector specific it will provide a better context for second level strings allowing for a much higher number of relevant and more conscise domains. This more targeted environment will simplify the user experience across multiple platforms specifically with smartphones and tablets where minimal input is favoured.


Service Levels

The goal of the gTLD Registry is to offer domain name registration services of the highest level, exceeding both ICANN requirements and current sector norms. To achieve these goals, the Applicant has contracted with well established, proven service providers offering the highest possible level of quality in Registry and Registrar services. The expertise of the service providers will ensure that the security and quality of the gTLD will be uncompromised.

The Applicant will further provide the highest level of service to trademark, legal rights owners and second-level domain owners. To achieve this goal the Applicant will be implementing a range of Abuse Prevention and Mitigation policies and procedures. The Applicant is also firmly committed to the protection of Intellectual Property rights and will implement all the mandatory Rights Protection Mechanisms (RPMs) contained in the Applicant Guidebook. Aswell as these The Applicant will further protect the rights of others through the implementation of additional RPMs. The RSPʹs experience will ensure that the gTLD provides this high level of service to trademark and other legal rights owners to combat abusive and malicious activity within the gTLD.

The Registry will respond to abuse or malicious conduct complaints on a 24/7/365 basis, respond to requests from governmental and quasi-governmental agencies and law enforcement in a timely manner, and promptly abide by decisions and judgments of UDRP and URS panels, in accordance with ICANN consensus policies.

The Applicant will also provide fast and responsive (24/7/365) customer support to both Registrars and end-users in a number of languages to assist with general enquiries as well as complaints of abusive or malicious conduct.


Service Levels related to Registry Backend Services

The Applicant will work with Neustar Inc. (hereinafter "RSP") whose extensive experience spans more than a decade. This will ensure delivery of the protected, trusted, and permanently-running Registry infrastructure necessary to reliably host and operate a gTLD. The Applicant will also work with its Registrars to ensure that consumers receive secure, fast, and reliable domain name registration services with a high-level of customer service.

The global DNS network that will be utilised for the resolution of domains in this gTLD has already been operating for over 10 years. It currently delivers DNS resolution for several TLD customers and provides low latency query responses with a 100% DNS uptime service level agreement.

The Applicant will further leverage the RSP's existing DNSSEC infrastructure, capabilities, and experience to provide a robust and standards compliant implementation that ensures DNSSEC services are always available as part of the DNS.

The Shared Registry System ("SRS") to be used for the Applicantʹs gTLD is a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that has been designed to operate at the highest performance levels. The Applicantʹs RSP has been able to meet or exceed their SLA requirements nearly every month since itʹs inception. Their Registry has achieved a 99.997% success rate in meeting SLAs since 2004.

The Applicantʹs RSP has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the gTLDs that it operates as a Registry Operator for both gTLDs and ccTLDs. The RSPʹs thick WHOIS solution is production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years.

The Applicant will comply with all the data escrow requirements documented in the Registry Data Escrow ("RyDE") Specification of the Registry Agreement and has a contract in place with Iron Mountain Intellectual Property Management, Inc. ("IM") for RyDE Services. The Applicant and its RSP will in conjunction with Iron Mountain work to ensure that the escrow deposit process is compliant 100% of the time.


Reputation

The Applicant will ensure that the Registry enjoys an excellent reputation through its core focus on creating a secure, sustainable, and specialized gTLD, thus supporting ICANN's primary goals for the new gTLD program in promoting consumer trust, consumer choice, competition and innovation.

The Applicant will strive to become a reputable and successful new gTLD by providing secure, fast and reliable customer service throughout the registration life cycle of all domains in the gTLD.

The Applicant will endeavour to ensure that only non-fraudulent Registrants have domain names in the gTLD via a WHOIS that is searchable, thick and reliable and by being highly responsive to complaints from legal rights owners. The Applicant will further implement an industry leading range of Abuse Prevention and Mitigation policies and procedures as well as RPMs.

The Applicant will provide the financial and operational stability to protect Registrants and ensure the reputation of the Registry. The Applicant has estimated the maximum costs of the critical functions for a three year period by taking the largest single year cost estimate (year 5) and multiplying this by 3. If the calculation used a lower figure the costs estimate would not be at the potential highest amount during the 5 years and the COI instrument would be too small in order to fund the costs of the 5 critical functions for at least 3 years.

The Applicant has decided to commit to providing the highest level of protection to Registrants and Stakeholders by providing ICANN with a COI for the maximum amount as recommended by ICANN in its COI Guidance. This ensures the Registry is reputable, remains conservative and mirrors ICANN's core objectives. In a worst case scenario where the Applicant will not receive any revenue Registrants will be protected not only by the COI, but also by the fact that the Applicant has enough capital to operate for over 3 years.

Question 18(b)(ii) What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

It is expected that .bet will provide significant competition for existing and forthcoming gTLDs. The .bet gTLD will provide a blank canvas of second level domains that will inevitably lead to increased consumer choice and significant innovation from the sector. It will allow Registrants to seek new and varied ways to separate themselves from the competition.

Competition

The Applicant will enhance competition by allowing new Registrants to create new online products and services serving the global marketplace and connecting geographically diverse Registrants and users with a common affinity for the specialized subject matter exemplified by the new gTLD. The new gTLD process and its resulting gTLDs are likely to incentivize top-level domains to improve the security and quality of their online products and services as well as introducing new ones. Thus, this gTLD will benefit consumers by increasing the likelihood of new innovative online products and services.The addition of a new gTLD such as .bet will also increase competition between existing registries.

The Applicant will promote competition to the benefit of the Registrants by amongst other things:

- Building a healthy growth trend of domain registrations to validate the specialty space
- Promote the migration of sector relevant content from other TLDs
- Maintaining competitive pricing of domains

Differentiation

Currently, there is no gTLD available on the Internet that signifies the specialized products, services, and subject matter encompassed by this gTLD. The gTLD string itself will give a clear indication to website visitors that the site has content relevant to the sector. This will result in the gTLD becoming globally recognizable and viewed as a trusted source of goods, services and information.

Innovation

The gTLD will demonstrate innovation through cutting edge RPMs.

Firstly the Applicant considers the Protection of Intergovernmental Organization (ʺIGOʺ) names to be very important. The Applicant will use strings registered as second level domains in the .int gTLD as the basis for this protection. To register in the .int domain, the Registrants must be an IGO that meets the requirements found in RFC 1591. The Applicant will reserve these strings and only allow for their future release if an IGO on the "reserve list" wishes to make use of the protected string in the gTLD and provides the Applicant with sufficient documentation.

Secondly, the Applicant will require that Registrants agree to the Registry's "Abuse and Rights Protection" Terms and Conditions as part of the registration process for the second-level domain, which includes displaying the APM Seal on the homepage. The APM Seal will provide users and legal rights holders with a direct link to an Abuse Prevention and Mitigation Report Website which will provide instructions on how to report abusive conduct to the Registry and law enforcement.

Finally if a Registrant during sunrise and landrush applies to register a domain name identical to a capital city name of a country or territory listed in the ISO 3166-1 standard it will receive a Capital City Claims ("CCC") notification stating this. Subsequently they will have to reply unconditionally agreeing to comply with requirements to protect the reputation of the capital city and any further terms.

These functions will enhance Internet stability, security and will demonstrate to Registrars, Registrants, and end-users of the Registry that abusive or malicious conduct will not be tolerated. They will further contribute significantly to the integrity of the gTLD enabling an environment where stakeholders can innovate with confidence.

Question 18(b)(iii) What goals does your proposed gTLD have in terms of user experience?

The Applicant's goals for the new gTLD are to provide a trusted, secure, and user friendly environment whereby domain names and content relating to its specific affinity group can flourish.

The Applicant believes that the success of the gTLD will be determined by the sector's key stakeholders globally. The Applicant believes that stakeholders should have the opportunity to influence the gTLD and the way it is governed. Accordingly, the Applicant is establishing a Governance Council ("GC"), to serve as an advisory body.

.bet will be developed with consumer trust, choice and satisfaction in mind and after the initial 2 years, the Applicant will conduct a survey to analyse the gTLDʹs success in these areas to help further improve the user experience.

To ensure a high level of service the Applicant will further measure:

- Service Availability Targets for the Critical Registry Functions
- The number of abuse incidents and takedowns
- ICANN Compliance
- Rights protection incidents (i.e. UDRP and URS)
- WHOIS data accuracy

The Applicant intends to promote consumer choice by providing the following:

- Highly available and geographically diverse Registrar distribution channel;
- Effective sunrise and trademark services.

Question 18(b)(iv) Provide a complete description of the applicantʹs intended registration policies in support of the goals listed above.

Registration Policies

The purpose and goal of the Applicant's policies are to ensure competition, fairness, trust and reliability for Registrars, Registrants, the user community, and other stake holders, while maintaining security and stability for the gTLD.

General Policy

Aside from certain start-up mechanisms, all domain names will generally be registered on a first-come, first-served basis. A Trademark Claims service will be offered for the first 90 days of general registration, with the intent of providing clear notice to potential Registrants of the existing rights of trademark owners with registered trademarks in the Trademark Clearinghouse.

Registration Policies

As per ICANN's requirements, the Applicant will be operating both a Sunrise and Landrush period ahead of general availability for the gTLD.

Governance Council

The Applicant is establishing a the GC, to be comprised of key sector stakeholders that will serve as an advisory body. Each GC will elect its own Board of Directors, which will be responsible for self-governance, the recommendation of sector-specific registration policies,the formulation of guidance on intellectual property and other best practices related to the gTLD.


The Applicant aims to develop an Abuse Prevention and Mitigation Working Group in conjunction with the GC. It will give the Applicant's team advice on abuse preventions and mitigation and how this may effect registration policies. The group will meet to regularly discuss the latest trends in domain name abuse and the most effective way to prevent and remedy them.

Question 18(b)(v) Will your proposed gTLD impose any measures for protecting the privacy or confidential information of Registrants or users? If so, please describe any such measures.

Data and Privacy Policies

The Applicant shall comply with all the Data, WHOIS, and Privacy requirements in the Applicant Guidebook required by ICANN. The Applicant will take all possible steps to maintain the security and privacy of information or data that it may collect in connection with the planned function and usage of names domains, and will remain in compliance with all confidentiality and security regulations in relevant jurisdictions. This data will be held by the Applicant in accordance with the Registry Agreement that the Applicant will execute with ICANN.

The Applicant has further ensured that its suppliers also understand that keeping information secure and private is of crucial importance and will take all available steps to maintain the security and privacy of information collected from the Applicants in the Sunrise, Landrush and General Availability Phases.

Question 18(b) Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

The Applicant plans on making the gTLD the premier gTLD where individuals and organizations can register, build and maintain websites relating to their specific interest area. Thus, communication with the public and development of an outreach campaign are important goals in connection with the gTLD.

During the gTLD evaluation process, the Applicant plans to conduct a two-to-three month communications campaign aimed at reaching sector stakeholders and informing them of the gTLD's mission and the opportunity to participate in the GC. The communication outreach will include email communications to hundreds of leading sector organizations. It will also be accompanied by the launch of a website for communicating information about the gTLD and allowing interested members of the related sector to express interest in serving on the GC. Other communications efforts, including but not limited to, press releases and social media campaigns may all be initiated to raise further awareness regarding the gTLD.

Shortly after completing the evaluation process and being awarded the gTLD, the Applicant will institute marketing and outreach efforts to inform the public about the new gTLD, its launch schedule, and its intended affinity group. The Applicant will use different outreach and communications methods and venues to get the new gTLD mission and message out to the public, including but not limited to the following: online and print press releases, communications with various media outlets, domain name sector groups, mobile apps and various social media platforms. The GC will be used as a further means of outreach and communication to the Internet community.
-end-

Q18C
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, 31) APM Seal. (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:

a. UDRP
b. URS
c. PIN
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:

a. UDRP
b. URS
c. PIN
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.

General Availability:

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:

Marketing Incentives

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.
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Q22
Introduction

The Applicant is aware of the substantial amount of work and effort that has gone into developing policy to address the issue of the reservation and release of geographic names under new gTLDs, including the valuable input from ICANNʹs Governmental Advisory Committee (ʺGACʺ), the Generic Names Supporting Organisation Reserved Names Working Group, Registry Operators and from elsewhere within the ICANN community.

The Applicant is aware of and understands the requirements set forth in the 11 January 2012 version of the New gTLD Applicant Guidebook (New gTLD Applicant Guidebook) and the GAC advice for protection of geographic names and will implement appropriate measures to ensure that it complies in all respects with ICANN policies and rules regarding both the reservation and release of geographic names at the second level (or other levels).

In addition to this, the Applicant proposes to implement an additional mechanism for the protection of capital city names at the second level that exceeds the requirements in the New gTLD Applicant Guidebook. See description of Capital City Claim service described below.

Reservation of Geographic Names

The initial GAC advice on the protection of geographic names is contained in the GAC document "Principles Regarding New gTLDs" which was presented by the GAC on 28 March 2007. Section 2.7(a) of this document states that new gTLD applicants should "adopt, before the new gTLD is introduced, appropriate procedures for blocking, at no cost and upon demand of governments, public authorities or IGOs, names with national or geographic significance at the second level of any new gTLD".

Specification 5 of the New gTLD Registry Agreement provides further clarity and details the Schedule of Reserved Names at the Second Level (or other levels) in gTLD Registries, whereby the Registry Operator undertakes to reserve certain domain names and prevent them from being registered, delegated or used.

Section 2 of Specification 5 of the New gTLD Registry Agreement requires that all two character labels are initially reserved. This is to avoid conflicts and confusion with existing ccTLD extensions.

Section 5 of Specification 5 of the New gTLD Registry Agreement is more comprehensive and states that:

"5. Country and territory names contained in the following internationally recognized lists shall be initially reserved at the second level and at all other levels within the TLD at which the Registry Operator provides for registrations:

5.1. the short form (in English) of all country and territory names contained on the ISO 3166-1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union 〈http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166-1_decoding_table.htm#EU〉;

5.2. the United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and

5.3. the list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names".

In order to meet these requirements regarding country and territory names, the applicant will maintain and regularly update copies of the aforementioned internationally recognized lists. All labels appearing on those lists, and on any list promulgated or recognized by ICANN for reservation in the future, assuming the corresponding string is unregistered, The Applicant will afford the same protections to new states or cities as they are formed.

The Applicant will reserve all labels appearing on the above referenced lists from time to time, and prevent registration, delegation or use of such names in accordance with ICANN requirements and as described above. In order to ensure that this is implemented correctly, all such labels will be reserved in the name of the applicant in order to prevent their delegation and use.

Release of Reserved Geographic Names

Specification 5 of the New gTLD Registry Agreement also contains provisions for the release of country and territory names on the basis that agreement is reached with "the applicable government(s), provided, further, that Registry Operator may also propose release of these reservations, subject to review by ICANN's Governmental Advisory Committee and approval by ICANN".

As such the applicantʹs proposed policy for the release of such reserved terms is cognisant of the review and approval process from the GAC and ICANN.

Based upon a review of the available literature, documentation and guidance, the applicant proposes the following policy to ICANN and the GAC for the potential release of reserved terms under the TLD:

i) Further to the successful evaluation and delegation of the TLD all of the aforementioned labels, as specified under Section 5 of Specification 5 of the New gTLD Registry Agreement will be reserved and thus unavailable for registration during each stage of the launch process including, but not limited to the Sunrise period, the Landrush period through to General registrations.

ii) At any stage during the launch process through to General registrations and beyond, the aforementioned reserved names may only be assigned to the relevant Government or public authority. In such situation they would be assigned using the following process:

a) The corresponding Government or public authority submits a request to the GAC seeking the assignment of the reserved name to themselves and provides the details of the proposed registrant entity for the domain name registration.

b) The GAC will validate it and authenticate the request to establish that is a genuine bona fide request.

c) Once this has been established by the GAC, the request for delegation will be forwarded to the applicant to request the assignment of the domain name. Simultaneously the GAC will also notify ICANN of the GAC approval of the request for the assignment of the domain name.

d) The applicant will issue a unique authorisation code to the proposed registrant entity.

e) The proposed registrant entity will then be able to request the assignment of the domain name to themselves using the authorisation code with an ICANN accredited registrar for the applicant TLD.

In addition to the above, the applicant will also adhere to and implement ICANN policy with regards to the reservation and release of such terms as and when required.

Additional Mechanism for Further Protection of Capital City Names
In parallel with the Landrush Period defined in the answer to question 18, the applicant will implement a Capital City Claim ("CCC") service whereby additional protection will be granted to the capital city names of a country or territory listed in the ISO 3166-1 standard. The CCC process is described below:

a) Any prospective domain name registrant applying to register a domain name identical to the capital city name of a country or territory listed in the ISO 3166-1 standard will automatically receive from the Applicant a CCC notification highlighting the fact that the applied-for domain name corresponds to a capital city name of a country or territory listed in the ISO 3166-1 standard.

b) A potential domain name registrant receiving a CCC notification will have to send a response to the Applicant whereby it will unconditionally comply with the requirements as to representations and warranties required by the Applicant.

c) Unconditional acceptance of the representations and warranties set out in the CCC notification will be a material requirement for a prospective registrant to be eligible to register the domain name in question should said prospective registrant be successful in the Landrush period.

d) Upon registration during the Landrush period of a domain name identical to a capital city name of a country or territory listed in the ISO 3166-1 standard, the Applicant will send a notification listing the names in writing to the GAC Chair.
(see Q28 for more detail)
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