.ged Pre-Register Domain - .ged Domain Information

The primary mission and purpose of the .GED gTLD is to provide a trusted, verified, vetted, and intuitive online community to aggregate GED® test information and quality GED® products and services for potential candidates, consumers, states, and authorized licensees and partners. Forty million adults in the United States alone lack high school credentials as well as the associated access to opportunities for training, higher education, and family-sustaining jobs. Every day, however, new websites are created online to defraud this audience by selling bogus online high school diplomas, tests, and preparation systems that are not part of the nationally recognized GED® testing program. The .GED gTLD will become a recognizable symbol of quality products and services associated with the official GED® testing program. GED Domains LLC, the entity which has filed this application, will be the vehicle which brings the .GED gTLD to market.

GED Domains LLC is a wholly owned subsidiary of GED Testing Service LLC which is a joint venture between the American Council on Education (ACE) and NCS Pearson Inc, a wholly owned subsidiary of Pearson Plc (Pearson), two industry-leading organizations with a common focus on adult learning. ACE is a major coordinating body for the nation's higher education institutions, representing more than 1,600 college and university presidents, and more than 200 related associations nationwide. For 70 years, ACE has served as the steward of the GED® testing program overseeing all aspects of the GED® test, including but not limited to: policy, development, testing, and compliance.

Pearson is the worldʹs leading learning company, providing educational materials and services, business information through the Financial Times Group, and consumer publishing through the Penguin brand. Pearson serves learners of all ages around the globe, employing 36,000 people in more than 70 countries, and is listed on the London and New York stock exchanges.

18.1.1 History of the GED® Brand
GED® is a registered trademark for the nationally recognized test administered by states and jurisdictions to measure high school-level skills and knowledge for adults who did not complete a traditional high school program. At the request of the United States military, the GED® test was first developed in 1942 to help World War II veterans finish their high school studies and reenter civilian life. New York was the first state in 1947 to accept a GED® test credential as a high school equivalency credential and by 1974 all states accepted the credential. GED® test credentials are now awarded in all 50 U.S. states, the District of Columbia, U.S. territories and insular areas, Canada and internationally. The GED® test credential is now the most widely accepted and respected high school equivalency credential.

18.2 GED Domains LLC believes the proposed .GED gTLD will provide the following benefits:

A trusted online community for the nearly 800,000 individuals that take the GED® test every year and the millions more that aspire to attain a high school equivalency credential. The .GED gTLD will be the standard for vetted and verified GED® testing information, differentiating official websites from misleading websites. Individuals will now have greater access to information about the GED® testing program and know what information is coming from legitimate sources. With increased access, comes greater choice - individuals will be able to access products and services provided by a range of providers. Access won't just be limited to what's available at just their local education centers and programs.

It will provide states that are struggling with budgetary cutbacks the option of using standard GED Testing Service web pages to provide accurate and consistent information about the services they offer their constituents. By providing information that will be readily accessible to individuals, the states will be able to reach populations that they currently can't reach because of the high cost of marketing to people in rural areas.

It will provide GED Testing Service partners and licensees with short and memorable Internet addresses to help offer their services to prospective candidates and distinguish them as legitimate service providers. These partners will have been vetted to ensure that the products and services they offer are legitimate, thus providing assurance to consumers on the purchases they make. Individuals interested in earning a high school equivalency credential are vulnerable to internet scams offering fake GED credentials or high school diplomas. Scams of this nature have been the target of numerous public protection suits by States Attorneys General and the GED Testing Service, itself.

There are literally thousands of community-based organizations underwritten by a variety of foundations that provide access to programs and funding for people wishing to complete their high-school education. These organizations often operate with limited visibility and both the programs and prospective students would benefit once a .GED gtld program is established.

It will minimize the need for defensive registrations because domain names will only be allocated by the registry after the identity of the registrant has been verified as a GED Testing Service partner/licensee.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .GED gTLD is to provide a trusted, verified, vetted, and intuitive online community to aggregate quality GED® test information and quality GED® products and services for candidates, consumers, states, and authorized licensees and partners. Through this initiative, the approximately one in five adult Americans (40 million) that lack high school credentials will have easy access to a trusted online community under the GED® brand, where the partners and licensees have been vetted. This innovation, that improves access and availability of the testing program, also puts candidates at risk for confusion regarding online testing scams

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

As a brand gTLD, the primary driving factors of .GED are differentiation and innovation. The success of the gTLD will not be measured by the number of domain names registered. Instead it will be measured by the level of consumer recognition and trust that is placed in the .GED gTLD. Using this benchmark, GED Domains LLC strives to build the consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.

Over the past seventy years the GED® test has been administered exclusively as a paper-based test. However, beginning in 2012, candidates are able to take a computer-based test at authorized test centers in many states, and we expect the whole GED® testing program to be available on computer nationwide by end of 2013. The .GED gTLD will ensure that candidates can trust the websites they are visiting, receive accurate information, and take the official GED® test that opens doors to college, training, and careers.

Through the .GED gtld program, legitimate providers of training materials will be able to market and sell their products and services to a broader base of consumers. Foundations and other not-for-profits will now be able to disseminate information about their programs more effectively. The benefits of the digital age will be brought to the GED® consumers in the form of access to reliable information and electronic forms of test preparation materials, all of which have been vetted by the organization responsible for the GED® testing program. With these innovations in place, we will allow a greater number of people to achieve their dreams of obtaining a high-school credential and get them on a path to pursuing higher education or a career.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

GED Domains LLC believes that the .GED gTLD will provide a single trusted eco-system experience for the approximately 800,000 annual candidates, the more than 3,000 facilities that currently administer the test, and the thousands of other entities that provide test preparation services. This verified eco-system provides candidates with a single repository of information for test preparation, scheduling, and other services. This gTLD also provides a platform to reach other consumers that might currently be underserved and may not have access to the financial and technology education resources otherwise.

While the Internet has been a transformative technology to empower human interaction, learning and commerce, it has also empowered criminals that seek to steal and commit fraud. GED Testing Service has engaged in an outreach campaign with its partners and licensees to educate candidates about potential fraud regarding "online" testing facilities and while awareness of the fraudulent programs continues to grow, more perpetrators continue to emerge and consumers find themselves as victims to such scams. GED Domains LLC believes that a .GED gTLD will serve as a virtual foundation for this proposed trusted eco-system.

18.2.4 Provide a complete description of the applicant's intended registration policies in support of the goals listed above.

Only partners and licensees authorized by GED Testing Service, the parent of GED Domains LLC, will be permitted to register domain names. This vetting will be done by GED Testing Service and will be part of a broader business and licensing agreement. As part of that licensing agreement businesses will be required to adhere to trademark usage and brand standards as well as proving that their products meet the standards set forth by the GED Testing Program to enhance the candidate experience. Only after this vetting has occurred will that entity be allowed to register a domain name with GED Domains LLC. In addition to this pre-validation, GED Testing Service LLC will incorporate post-registration safe guards to ensure ongoing monitoring and compliance with these requirements.
Because of this condition precedent, any registration and use requirements are more appropriately vested in these licensing agreements and not in a domain name registration agreement. Because GED® is a valuable brand whose protection is of paramount importance, any registration and use (e.g. trademark quality control provisions) must vest in these other agreements.

18.2.5 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

GED Domains LLC recognizes first hand that this is an evolving area of law in which there is no international standard. However, due to fact that every domain name will initially be registered to commercial entities, GED Domains LLC has a vested interested to make sure that accurate and current domain name information is readily available in connection with each .GED domain name. This commitment to Whois accuracy is reflected in the robust policies described above and set forth in greater detail in the response to Questions 28, 29 and 30. GED Domain will ensure that the operation of the .GED gTLD will be consistent with GED Testing Service's global privacy policy available on its website at http://gedcbt.org/gedts/privacypolicy.html.
GED Domains LLC also intends to incorporate contractual language in its Registry Registrar Agreement (RRA) modeled after language which has been included in the template Registry Agreement and which has been successfully utilized by existing ICANN gTLD registry operators. Specifically, Registry Operator shall notify Registrar of the purposes for which Personal Data submitted to Registry Operator by Registrar is collected, the intended recipients (or categories of recipients) of such Personal Data, and the mechanism for access to and correction of such Personal Data. Registry Operator shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars. Registry Operator may from time to time use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use
Notwithstanding GED Domains LLC' commitment to operating in compliance with applicable rules and regulations regarding the protection of individual registrant's private or confidential information, GED Domains LLC is proposing to prohibit the use of proxy/anonymous registration services that would mask the identity of registrants within the .GED namespace.


18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

There have been over 18 million candidates that have earned their GED® test credentials since the program was first introduced in 1942, and there are nearly 800,000 candidates that take the test every year. GED Testing Service has an extensive network of partners and licensees that include but are not limited to state institutions, colleges, correctional facilities, faith-based organizations, literacy organizations, as well as for-profit educational and commercial institutions. The strength of the GED Testing Service partnership is that both ACE and Pearson are leading organizations in their respective fields, with a common focus on education. But the current ecosystem, while large, operates in a fragmented manner and the .GED gTLD program, along with the outreach associated with it, will help bind together the organizations currently serving this ecosystem.

Outreach and public awareness communications will be an integral part of the .GED gTLD benefits. The .GED gTLD will provide a trusted online community for all candidates to find, purchase, and use GED® test information from vetted partners and licensees, and for these partners to classify and market their materials as legitimate and differentiate their products from those being sold by entities perpetrating fraud. As the owner of the GED® brand and the testing program, GED Testing Service is the source of truth for all things related to the GED® program, and will market the existence of the gTLD program to consumers and partners. As more candidates learn about the .GED eco-system, it will lessen the chance that these individuals will find themselves the victims of online scams.

18.3

GED Domains LLC's proposed operating rules to limit registration to authorized licensees and partners will provide a trusted online environment for GED® candidates. This limits the impact on trademark and brand owners to defensively register in the gTLD. This verified eco-system also provides candidates with a single repository of information for test preparation and test scheduling, with a substantially lower risk of fraud and/or scams.


GED Domains LLC believes that the proposed operation of the .GED gTLD as set forth in this application has no known negative consequences or cost implications on consumers. To the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to candidates, e.g. additional test preparation choices, consistent and accurate test information, a secure community of vetted providers, greater access to educational programs, etc.

18.3.1 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come/first-serve basis?

GED Domains LLC does not envision multiple applicants for the same domain name. With an anticipated universe of only a couple of thousand domain names, there should not be any instances of multiple applicants for the same domain name. If such an instance should arise, GED Domains LLC would look at a number of potentially equitable allocations mechanisms that have been used in the domain name industry such as an Request for Proposal (RFP) to evaluate potential use cases in allocating the domain name.

18.3.2 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

GED Domains LLC does not envision any pricing, introductory discounts, bulk registration discounts because these marketing/commercial initiatives are inconsistent with the mission and purpose of the .GED gTLD which is primarily a branded community. The .GED domain name is intended as a value added service to an existing commercial relationship between GED Testing Service and its licensees/partners.

18.3.3 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.

GED Domains LLC is committed to providing the domain name registration periods set forth in the registry agreement. However, as noted above as a .brand gTLD the registration and use of the domain name is conditioned upon a separate partnership/licensee relationship with GED Testing Service. Therefore providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate.

THE RESPONSE FOR THIS QUESTION USES ANGLE BRACKETS (THE "〈" and "〉" CHARACTERS, or 〈 and 〉), WHICH ICANN INFORMS US (CASE ID 11027) CANNOT BE PROPERLY RENDERED IN TAS DUE TO SECURITY CONCERNS. HENCE, THE ANSWER BELOW AS DISPLAYED IN TAS MAY NOT RENDER THE FULL RESPONSE AS INTENDED. THEREFORE, THE FULL ANSWER TO THIS QUESTION IS ALSO ATTACHED AS A PDF FILE, ACCORDING TO SPECIFIC GUIDANCE FROM ICANN UNDER CASE ID 11027.

22.1 Background

Recognizing the sensitivity of this issue, GED Domains LLC has worked in close partnership with its preferred partners that are subject matter experts in this area. The collective qualifications of these subject matter experts include:

• Afilias, LTD - a leading registry infrastructure provider that has been selected to provide backend registry service for his application. Afilias expertise in this subject matter is specifically referenced in the Applicant Guidebook. Over the last decade Afilias has worked in close coordination with the ICANN Government Advisory Committee (GAC) to ensure that .INFO domain names covered by ICANN Board Resolution 01-92 have been properly allocated to the respective national governments.
• Pharos Global, Inc - a leading DNS consulting company which has administered Afilias' .INFO country name process, and its President and CEO Michael Palage who served on ICANN's GNSO Reserved Names Working Group and chaired its subgroup on Geographical and Geopolitical Names.

To ensure a best in class response to this answer, these subject matter experts researched and reviewed the following relevant background material regarding the protection of geographic names in the DNS in briefing GED Domains LLC:


• ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain, see http://www.icann.org/en/minutes/minutes-10sep01.htm;
• ICANN's Proposed Action Plan on .INFO Country Names, see http://www.icann.org/en/meetings/montevideo/action-plan-country-names-09oct01.htm;
• Second WIPO Internet Domain Name Process - The Recognition and Rights and the Use of Names in the Internet Domain Name System, Section 6, Geographical Identifiers, see http://www.wipo.int/amc/en/processes/process2/report/html/report.html;
• The GAC Principles Regarding New gTLDs, see https://gacweb.icann.org/download/attachments/1540128/gTLD_principles_0.pdf?version=1&modificationDate=1312358178000
• ICANN's Generic Names Supporting Organization Reserved Names Working Group - Final Report, see http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.htm

22.2 Initial Reservation of Country and Territory Names

GED Domains LLC is committed to initially reserving the country and territory names contained in the internationally recognized lists described in article 5 of Specification 5 attached to New gTLD Applicant Guidebook at the second level and at all other levels within .GED gTLD. Specifically, GED Domains LLC will reserve;

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〉;

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

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.

22.2 Fair & Non-Misleading Use of Geographical Identifiers

GED Domains LLC's parent company, GED Testing Service LLC currently has established relationships with an extensive network of public and private licensees and partners located around the global. Although the majority of the over 800,000 tests that are administered to Candidates annually take place within the United States and Canada, GED Testing Service has a number of licensees and partners that administer the GED internationally and at US military installations.

GED Domains LLC in designing a hierarchical and intuitive .GED namespace would like to make extensive use of geographic identifiers at the second level to facilitate increased consumer navigation, e.g. NEWYORK.GED, FLORIDA.GED, PHILADELPHIA.GED, SFO.GED, NYC.GED., etc. GED Domains LLC believes that use of these geographical identifiers in a domain name constitute a fair and non-misleading use.

22.3 The Legal Protection of Geographical Identifiers

One of the more authoritative resources on the current state of the law in connection with the protection of geographical identifiers was authored by the World Intellectual Property Organization in its 2001 Second WIPO Internet Domain Name Process, The Recognition of Rights and the Use of Names in the Internet Domain Name System. Chapter six of this report was devoted exclusively to the protection of Geographical Identifiers.

In analyzing the well-established framework against the misuse of geographical identifiers at the international, regional and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications. See Second WIPO Internet Domain Name Process (Paragraphs 206 and 210). Neither of these elements is present in GED Domains, LLC's proposed use of geographical identifiers.

Notwithstanding WIPO's recommendation that the protection of geographical identifiers is "a difficult area on which views are not only divided, but also ardently held" (Paragraph 237) national governments within the ICANN Government Advisory Committee (GAC) and other international forums have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the domain name system.

One of the drivers in GED Domains LLC pursuing this new gTLD opportunity was the desire to combat the online fraud to which Candidates are exposed. Therefore, GED Domains LLC strives to minimize any potential business practices that might mislead Candidates. However, at the same GED Domains LLC believes that it is important to be able to use geographical identifiers in a fair use and non-misleading manner, if such use can benefit Candidates in proposed .GED business model set forth in Answer #18.


22.4 Fair & Non-Misleading Use of Geographical Identifiers (Sampling)

In undertaking a thorough research of this subject matter prior to filing this application, GED Domains LLC's subject matter experts were able to uncover the following representative sampling of fair and non-misleading use of geographical identifiers used in the existing gTLD domain name space:

Fair Use of National Geographical Identifiers

〈AUSTRALIA.COOP〉 - Is operated by Co-operatives Australia the national body for State Co-operative Federations and provides a valuable resource about cooperatives within Australia.
〈UK.COOP〉 - Is operated by Co-operatives UK the national trade body that campaigns for co-operation and works to promote, develop and unite co-operative enterprises within the United Kingdom.
〈NZ.COOP〉 - Is operated by the New Zealand Cooperatives Association which brings together the country's cooperative mutual business in a not-for-profit incorporated society.
〈USA.JOBS〉 - Is operated by DirectEmployers Association (DE). While Employ Media the registry operator of the .JOBS gTLD is currently in a dispute with ICANN regarding the allocation of this and other domain names. Direct Employers has a series of partnerships and programs with the United States Department of Labor, the National Association of State Workforce Agencies and Facebook to help unemployed workers find jobs.
〈MALDIVIAN.AERO〉 - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.

Fair Use Regional /Local

〈TEXAS.JOBS〉 - Is operated a joint effort between DE, Texas Workforce Commission and the National Labor Exchange to connect job seekers with approximately 96,000 job openings. An additional domain name operated by this joint effort was 〈WORKINTEXAS-VETERANS.JOBS〉 a resource devoted to helping Texas veterans translate their military skills to jobs in the civil marketplace.
〈BOISE.COOP〉 - Is operated by Boise Co-op a member owned cooperative, founded in 1973 by a few dozen individuals who shared a mutual interest in buying healthy and organic food at reasonable prices.
〈BROOKLYN.COOP〉 - Is operated by Brooklyn Cooperative Federal Credit Union who began as a modest storefront business in 2001, but is now New York City's fastest growing credit union and a model for community development credit unions nationwide.
〈HYDERABAD.AERO〉 - Is operated by the Hyderabad International Airport and provides a range of interactive services and information for both business and leisure travelers.
〈SACRAMENTO.AERO〉 - Is portal website operated by Sacramento County to provide links to each of the airports serving the Sacramento area: Sacramento International Airport (SMF), Mather Airport (MHR), Executive Airport (SAC) and Franklin Field (F72).

22.5 Protection of Regional and Local Geographic Names for Misleading Use

Although GED Domains LLC has stated its intention to use non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading use to help consumers navigate the .GED namespace, GED Domains LLC is committed to operating the .GED namespace in a manner that minimizes potential consumer confusion, and will with actively work with others in the ICANN community regarding any future policy development in this area.

22.6 Potential Future Release of Initially Reserved Names

Given that the GED® test is provided in a number of international locations, GED Domains LLC looks forward to working in connection with other new gTLD registry operators (especially .BRANDs) in potentially collaborating with ICANN's Government Advisory Committee to explore potential processes that could permit the release of initially reserved country names (including ISO-3166 two characters). Specifically, GED Domains LLC is interested in exploring other Registry Service Evaluation Process (RSEP) that have been filed by existing gTLD registry operators in releasing previously reserved domain names.


22.7 Dispute Resolution

GED Domains LLC does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .GED gTLD based upon its proposed use set forth in Answer 18 above. However, GED Domains LLC is committed to working with governments, public authorities, or IGOs that may have a concern regarding the registration of names with national or geographic significance at the second level within .GED.

22.8 Creation and Updating the Policies - Should there arise some future need for the creation or updating of the policies regarding this class of domain names, GED Domains LLC will act in an open and transparent manner consistent with its prior practices to develop such a policy and/or recommendation.
GED Domains LLC is also committed to continually reviewing and updating these lists to prevent misleading use of geographical identifiers. Consistent with this commitment, GED Domains LLC intends to remain an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.