.loans Pre-Register Domain - .loans Domain Information

The mission of .Loans is to represent the loan and mortgage industry and organizations involved in granting loans globally in its own differentiated namespace. Credit and Mortgage today make up a large Global Industry. The industry comprises of various participants including financial and mortgage institutions, loan brokers, loan agents and loan and mortgage correspondents.

There are an estimated 200,000 loan and mortgage related institutions and another 20k banks worldwide (refer our response to Q48 for the source of this information). These are some of the elements that make up the addressable market for .Loans.

More and more consumers are seeking information as well as making purchase decisions concerning loans and mortgages online further increasing the need for loan granting and related institutions to have an online presence that truly signifies what they do. As of March 2012, Google keyword tool data shows over 16million global searches contain the word ʺloanʺ every month.

With the exponential growth of the Internet we see business processes evolving and moving online. Banking services have been available online to consumers worldwide since a long time now and customers are quite accustomed to viewing their statements as well as transacting online. Trust in the Internet is tenuous. The Internet became the vast communication medium it is by unrestricted access. This unrestricted access has also come at a potentially unrestricted cost in fraud and theft. Consumers are frequently victims of phising attacks and other forms of internet abuse that result in financial losses and even worse threaten consumer trust in the online medium.

With the advent of the new Top Level Domain program, we have the opportunity, to develop more trustworthy systems, without imposing additional identification requirements on other generic TLDs. Many business sectors seek to build trust. The economic events of the past few years have caused financial institutions to build new forms of trust with their customer public.

Within the current gTLD and ccTLD environment, there are constant attempts of fraudulent representation of financial institutions on the Internet. Fraudulent "Nigerian Scam Emails" or "Chinese Funds Transfer emails" have occurred so often they have become common spam. Using the new gTLD program, it is possible to build a unique and trusted Internet space for loan and mortgage organizations and institutions. In this gTLD, all registrations will be fully restricted to organizations from the financial sector. The organization's identity will have been verified prior to name resolution. The .Loans TLD will be a more trustworthy system.

.Loans will cater to the hundreds of 1000s of companies in the loan and mortgage business. A differentiated namespace that directly relates to the loans industry will provide a strong weapon in their arsenal to ensure they continue to thrive in these times of competition.

The mission/purpose for .Loans is to be the TLD of choice for loan and mortgage related businesses. Keeping this in mind, .Loans will look to contribute to the Internet Namespace in several ways:

1.1 ENHANCE TRUST

To create a "trusted and secure" namespace for the loan and mortgage industry and its users. The ..Loans extension is intended to provide a .registrants from the loans and mortgage industry, an immediately recognized domain name that tells Internet users that they are interacting with a legitimate organization. The ..Loans TLD will require registrants to achieve specific verification. This will create a TLD for which there is unprecedented accountability for web services launched on its domains. This will eliminate phishing and fraud resulting from mistaken identity creating a trusted and secure namespace and a trusted environment for Registrants

1.2 ENHANCE SEARCHABILITY AND RECOGNITION

To create a namespace that enables loan and mortgage businesses to easily distinguish themselves from countless others in unrestricted gTLDs. This benefits the Registrants as well as the end users. End users will be able to find the website of a business they are looking for easily amongst the sea of other sites.

1.3 ENHANCE REGISTRANT CHOICE

To create a namespace that provides loan and mortgage businesses greater choice to represent their brand online in the manner they please. Due to the saturation and unrestricted nature of the existing gTLD space many loan and mortgage businesses have to opt for a name that does not best reflect their brand. ..Loans will provide legitimate Registrants a higher guarantee of obtaining their desired name

1.4 CREATE A CLEANER INTERNET SPACE

To create a cleaner internet experience for end users by implementing pioneering registration policies, content and usage policies, and abuse mitigation processes.

1.5 CREATE A STABLE AND RESILIENT INTERNET SPACE

To deliver a stable and resilient internet experience to registrants and end-users by going above and beyond the ICANN mandated SLAs and delivering 100% resolution uptime

This completes our response to Q18(a)

1. GOAL OF .LOANS

1.1 SPECIALTY

Our goal for .Loans in terms of area of specialty is to provide a trusted, secure and restricted TLD among qualifying new registrants in the loan and mortgage business. The .Loans registry will provide qualifying registrants the opportunity for their preferred domain name on a restricted global TLD. Our area of specialty will be the global loan and mortgage industry. Over time, as the .Loans TLD demonstrates the trust and security of a specialized namespace, more and more loan related content and transactions will be moved to the .Loans TLD from current gTLD and ccTLD domains.

1.2 SERVICE LEVELS

Our goal for .Loans in terms of service levels is to go above and beyond the ICANN SLAs. ICANN provides for its expected SLA in Specification 10 in the Registry Agreement in the Applicant guidebook.

We have engaged ARI Registry Services (ARI) to deliver services for this TLD. ARI provides registry services for a number of TLDs including the .au ccTLD.

Our contract with ARI is attached to our response to Q46. This contract details the SLA we intend on achieving with this TLD. As can be seen in the contract we have exceeded the ICANN required SLA on every parameter.

Our response to Q34 and Q35 provides details on ARI's distributed anycast DNS network. ARI's DNS network provides for 16 geo distributed sites resulting in a very low resolution latency for end-users, amongst the lowest in the industry.

It is our objective to provide 100% uptime, a resilient global DNS infrastructure, and very low latency in terms of DNS resolution for this TLD

1.3 REPUTATION

Reputation of our TLD is of paramount importance to us. The reputation of our TLD directly relates to how end-users on the internet perceive our Registrants. We will ensure the highest reputation of .Loans by ensuring the following -
* Maintaining a high quality bar with respect to Registrants in the TLD
* Well defined Acceptable usage and content policies
* Well defined eligibility requirements and name selection policies
* Well defined dispute resolution mechanisms
* Ensuring Whois accuracy to support abuse mitigation
* Well defined and implemented abuse mitigation processes
* Well defined and implemented rights protection mechanisms
* Exceptional service levels

To this effect we have created unprecedented Abuse mitigation policies and Rights protection mechanisms that go significantly above and beyond mandatory requirements and common practice described in considerable detail in our response to Q28 and Q29. We also commit to extremely high service levels that go beyond the stipulated service levels in the applicant guidebook.

2. CONTRIBUTION OF .LOANS TO THE NAMESPACE

2.1 CONTRIBUTION IN TERMS OF COMPETITION

Per ICANN's Bylaws as amended June 24, 2011, ICANN's core value number six is "Introducing and promoting competition in the registration of domain names where practicable and beneficial in the public interest."

* The .Loans registry will be a new direct and boutique competitor to the current group of global generic TLDs. The .Loans registry will introduce consumer choice by creating an alternative viable option that is much more trusted and secure for loan and mortgage businesses to register domain names. It will create competition amongst Registries with respect to serving the loan and mortgage community and provide an alternative for loan and mortgage businesses who wish to establish an online presence.

* Most gTLDs have largely focused on developed markets with 70%+ internet penetration. Domain Name and website growth is yet to occur in other developing markets like India, Brazil, Russia, China, Indonesia etc. However as the market for websites and domain names grows in these economies the existing gTLD space in TLDs like .com, .net, .org etc will already be saturated with all tier 1 names no longer available to markets like asia, africa. 70% of .com check availability checks return unavailable (data obtained from our Internal Research data). New companies have to resort to 2nd tier long multi-word names for their businesses in these markets. .Loans will broaden the namespace by providing an alternative for loan and mortgage businesses in developing markets to register the domain name of their choice creating competition.

2.2 CONTRIBUTION IN TERMS OF DIFFERENTIATION

The .Loans registry's differentiation will be "accountability in practise". More than any of the other global gTLD registries, we will provide end-users a domain space that assures the qualifications and identity of a registrant.

For the first time, loan and mortgage businesses will have a viable option to provide to their end-users a URL they can trust. Consumers of such a businesses will know to only trust a URL that ends in .Loans. This will almost eliminate phishing scams.

.Loans will also allow Registrants in the loan and mortgage community to differentiate themselves from the 200+ million domain names out there. As of now a typical loan and mortgage business's domain name appears identical to any other domain name in a .gTLD (com) or .ccTLD extension (eg .in). .Loans provides the ability for Registrants to create a differentiated identity wherein just by looking at the URL end-users will be assured of the fact that they are dealing with a loan and mortgage business.

Lastly .Loans will provide loan and mortgage businesses to register more desirable and shorter names as opposed to names they would have otherwise registered in existing gTLDs due to the high saturation of the existing namespaces.

2.3 CONTRIBUTION IN TERMS OF INNOVATION

.Loan's provides a trusted and secure namespace through various innovative measures described below -

* Restricted registrant participation with extensive registrant verification providing an assurance to end-users of the identity of the registrant
* Despite the prevalence of English as a language of commerce, past gTLD registries have largely focused on North America and European marketplaces. We will be offering the .Loans TLD to international markets, with the goal of a truly global distribution of registrants.
* Our intent is to operate .Loans with a focus on trust and security for the .Loans brand. This entails running robust abuse mitigation programs and pioneering Rights Protection Mechanisms from initiation, which in our case not only meets ICANN's requirements, but extends significantly beyond it as described in our response to Q28 and Q29

3. USER EXPERIENCE GOALS

.Loans considers both its Registrants and the end-users that access .Loans websites as its users. Our goal is to create a clean, trusted and highly reliable namespace and provide an outstanding user experience to both Registrants and end-users of .Loans.

Registrants of .Loans have an assurance of a scalable, resilient registry with 100% uptime, low latency, and the highest security standards. Registrants will have the option to register the domain name of their choice, without much saturation of the namespace. Our registration policies alongwith our eligibility criteria, name selection policies and abuse mitigation policies ensure that Registrants will get advantages like higher recognition, better branding, shorter names, elimination of phishing, identity verification and enhanced consumer trust

End users who visit a .Loans URL have an assurance that they are visiting the website of a loan and mortgage business that conducts business under that name. They get the benefit of a trusted secure namespace and are unlikely to be victims of phishing attacks. Our content and acceptable use policies and abuse mitigation processes ensure that end-users are benefited from a clean namespace. These are described in further detail in our response to Q28 and Q29.

3.1 AUGMENTED LEVEL OF SECURITY AS PER BITS RECOMMENDATIONS

This TLD is a financial TLD and as such requires special security considerations. Our goal with this TLD is to provide a safer and secure browsing experience for consumers of this TLD. 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 TLD.

We welcome the recommendations from SSWG. We have adopted all of the recommendations 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] except recommendation 23, 30 and 31 which we believe need to be further looked at.

Our description of our implementation of these recommendations is provided in our responses to Q24, Q25, Q27, Q28, Q29, Q30, Q40 and Q43

4. REGISTRATION POLICIES IN SUPPORT OF GOALS

4.1 GENERAL NAMES

The goals of .Loans are outlined in the sections above. These goals are supported by the following artifacts:
* Registration policies and processes
* Acceptable usage policies and content guidelines
* Abuse mitigation processes
* Rights protection mechanisms
* Dispute resolution polices

To this effect we have created unprecedented Abuse mitigation policies and Rights protection mechanisms that go significantly above and beyond mandatory requirements and common practice. The salient aspects of all of the above are described below:

* DotServe Inc. is a wholly owned subsidiary within the Directi Group. The Directi Group runs various businesses including several ICANN Accredited Domain Registrars (ResellerClub.com and BigRock.com) and Web Hosting companies. With over four million active domain names registered through its registrars, Directi has significant experience (over 10 years) of managing domain name abuse mitigation and rights protection. Directi has been heralded as a white hat registrar and the undisputed leader with respect to abuse mitigation.

* Our Abuse and compliance processes will be run by the Directi Group

* Proxy Registrations will not be permitted in .Loans

* .Loans has a well defined eligibility criteria and name selection policy. General domain names in .Loans will only be activated after a thorough check against our eligibility criteria, name selection policy and identity verification at the time of registration resulting in a zero abuse namespace at registration time.

* We have an elaborate and detailed Accepted usage and content policy that covers over 11 macro forms of violations

* .Loans will create a zero-tolerance reputation when it comes to abuse

* We have a defined SLA for responding to abuse complaints ensuring guaranteed turn-around time on any abuse complaint depending on its severity

* We will work closely with LEA and other security groups to mitigate abuse within TLD by providing them with special interfaces (eg searcheable whois) and interacting with them regularly in terms of knowledge sharing.

* Other abuse mitigation steps we undertake include profiling, blacklisting, proactive quality reviews, industry collaboration and information sharing, regular sampling, contractual enforcements and sanctions

* The protection of trademark rights is a core goal of .Loans. .Loans will have a professional plan for rights protection. It will incorporate best practices of existing TLDs, going above and beyond the ICANN mandated RPMs to prevent abusive registrations and rapidly take-down abuse when it does occur.

* Standard RPMs such as Sunrise, Trademarks claims service, URS, UDRP, SDRP, PDDRP, SPOC etc are all provided for. Additional RPMs such as Optional Trademark declaration, profiling and blacklisting, proactive quality reviews, APWG Review and others will also be provided.

The above salient points barely scratch the surface in detailing the steps that .Loans will take in order to build a reputation of operating a clean, secure and trusted namespace. Significant details of all of the above and more are provided in our responses to Q26, Q27, Q28 and Q29

4.2. OTHER NAMES

* We will reserve the following classes of domain names, which will not be available to registrants via the Sunrise or subsequent periods:

** The reserved names required in Specification 5 of the new gTLD Registry Agreement.
** The geographic names required in Specification 5 of the new gTLD Registry Agreement, and as per our response to Question 22. See our response to Question 22 ("Protection of Geographic Names") for details.
** The registry operator will reserve its own name and variations thereof, and registry operations names (such as nic.Loans, registry.Loans, and www.Loans), so that we can point them to our Web site. Reservation of the registry operator's names was standard in ICANN's past gTLD contracts.
** We will also reserve names related to ICANN and Internet standards bodies (iana.Loans, ietf.Loans, w3c.Loans, etc.), for delegation of those names to the relevant organizations upon their request. Reservation of this type of names was standard in ICANN's past gTLD contracts. The list of reserved names will be published publicly before the Sunrise period begins, so that registrars and potential registrants will know which names have been set aside.

* We will reserve generic names which will be set aside for distribution via special mechanisms.

5. PROTECTING PRIVACY OF REGISTRANTS' OR USERS' INFORMATION

.Loans is committed to providing a secure and trusted namespace to its Registrants and end-users. To that extent we will have several measures for protecting the privacy or confidential information of registrants or users -

* Our Whois service (web-based whois, port 43 whois and searchable whois) all have built in abuse prevention mechanisms to prevent unauthorized access, data mining, data scraping and any other abusive behavior. Details of this are provided in our response to Q26

* As per the requirements of the new gTLD Registry Agreement (Article 2.17), we shall notify each of our registrars regarding the purposes for which data about any identified or identifiable natural person ("Personal Data") submitted to the Registry Operator by such registrar is collected and used, and the intended recipients (or categories of recipients) of such Personal Data. (This data is basically the registrant and contact data required to be published in the WHOIS.)

* We will also require each registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. As the registry operator, we shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.

* As the registry operator we shall take significant steps to protect Personal Data collected from registrars from loss, misuse, unauthorized disclosure, alteration, or destruction. In our responses to Q24, Q30 and Q38 we detail the security policies and procedures we will use to protect the registry system and the data contained there from unauthorized access and loss.

* As registry operator we impose certain operational standards for our registrars. In order gain and maintain accreditation for our TLD, we require them to adhere to certain information technology policies designed to help protect registrant data. These include standards for access to the registry system. Please see our response to Q24, Q25 and Q30 for details.

* We offer a "registry lock" service, designed to help protect participating registrants' contact data from unauthorized modification, and against unauthorized domain transfers and deletions. Please see our response to Q27 for details.

* We follow all of the security specific recommendations in the policy drafted by BITS for financial TLDs. Our description of our implementation of these recommendations is provided in our responses to Q24, Q25, Q27, Q28, Q29, Q30, Q40 and Q43

* .Loans implements DNSSEC at the zone which guarantees origin authentication of DNS data, authenticated denial of existence, and data integrity. This protects end-users from a man-in-the-middle attack protecting the privacy of data of end-users.

6. OUTREACH AND COMMUNICATIONS

Our goal for .Loans is to create a trusted and secure name space for loan and mortgage businesses. To achieve this, we will emphasize distribution channels internationally - not just in one or more focused regions.

* We will focus our outreach through industry channels. We will develop relationships with regional authorities to assist in our registration verification process. As part of that relationship development, we will design our communication approach to target the loan and mortgage businesses in each individual region.

* We will also engage in relevant PR and outreach programs as well as ensure appropriate publication of information on our website.

* Lastly we will engage with ICANN Registrars worldwide to utilize their presence and channels to generate awareness concerning .Loans.

The communication and outreach will focus on:

* Education amongst the loan and mortgage industry
* Generating awareness of our Registration policies, Acceptable usage and content policies, Abuse mitigation processes and Rights protection mechanisms

This completes our response to Q18(b).

.Loans considers both its Registrants and the end-users that access .Loans websites as its users. Our goal is to create a clean, trusted and highly reliable namespace and provide an outstanding user experience to both Registrants and end-users of .Loans. To that extent it is our goal to -

* Reduce / minimize any incremental costs / negative consequences imposed upon our users
* Increase / maximize the value added to our Registrants and end-users
* Ensure that the net effect of .Loans on its users is that of positive value creation

In this response we explore how .Loans achieves a net benefit for Registrants and End-users.

1. MINIMIZING COSTS

1.1 REGISTRANTS

It is our goal to provide Registrants of .Loans incremental value and minimize any negative consequences and costs associated with .Loans. We address this in the following manner

1.1.1 SUNRISE, TMCH, RPMs

Rights protection is a core goal of .Loans. Our Rights Protection mechanisms go significantly above and beyond the mandatory RPMs ensuring protection of trademark and IP rights of domain registrants and reducing the costs associated with rights protection for Registrants. Our elaborate RPMs are described in significant detail in our response to Q29. Some salient aspects of these are as follows -

* We have an elaborate eligibility criteria, name selection policy and identity verification process before a general domain name is activated in .Loans ensuring an unprecedented zero-abuse at registration time. This ensures zero litigation costs and disputes post-facto.

* We offer a sunrise period to provide an opportunity for legitimate Registrants to block domain names in .Loans before general availability begins, preventing unnecessary post-facto litigation

* We will integrate with the Trademark Clearing House in the manner prescribed to provide the Trademarks claims service, so as to alert potential Registrants of any trademark violations prior to registration, as well as notify mark holders of potential mark violations

* We will provide SDRP, URS, UDRP, PDDRP and ERDRP reducing litigation costs by providing legitimate Registrants the opportunity to resolve disputes through standardized arbitration proceedings.

* Additionally we have pioneering RPMs like Optional Trademark Declaration, Profiling and Blacklisting, Proactive Quality assurance, APWG review etc - all intended to reduce rights violations and hence reduce costs for Registrants

The above salient points barely scratch the surface in detailing the steps that .Loans will take in order to reduce costs of Registrants with respect to rights violations. Significant details of all of the above and more are provided in our responses to Q26, Q27, Q28 and Q29.

1.1.2. MULTIPLE APPLICATIONS FOR A DOMAIN

All of the RPMs described in section 1.1.1 above ensure that applicants for domain names in .Loans are legitimate right holders for the applied string.

During general availability domain names will be allocated on a first come first serve basis amongst legitimate applicants. During the initial registry launch periods of Sunrise and Landrush if multiple applications for the same domain name are received from legitimate applicants then the same will be distributed in the following manner -

* Incase of multiple sunrise applications for the same domain name, all applications will be validated against the TMCH for a valid trademark. Applications that do not qualify will be dropped.

* Applications will be whetted against our Eligibility restrictions and name selection policies and any application that fails the validation will be dropped

* All remaining legitimate applications will be distributed through a fair auction.

1.1.3 COST BENEFITS FOR REGISTRANTS

The ICANN new gTLD program marks a historical event in the timeline of the Internet. It is an unprecedented event and one that will yield tremendous benefits for consumers. At this preliminary stage it is impossible to determine the true value consumers will derive from increase in competition and choice. However there is historical data to go by. Upon the launch of Domain Registrars and creation of competition amongst registrars, the Registrants benefited from reduced pricing.

With .Loans our goal is to provide fair pricing for domains within .Loans that reflect the value proposition derived by the Registrants of .Loans. While we do not have any committed pricing plans as yet and the same will be determined during the launch process, we do anticipate providing promotional offers through the life of .Loans for the purpose of customer acquisition. This is not too dissimilar from other gTLD registries currently in existence who offer ongoing promotional offers to their customer base.

1.1.4. PRICE ESCALATIONS

The ICANN new gTLD program is an unprecedented event and the actual nature of pricing pressures will only be determinable once several TLDs have successfully launched. At this preliminary stage it is impossible to commit to any pricing strategy on our part. We strongly believe that ultimately, the open market will determine the viability of pricing models and dictate pricing strategy for everyone. We intend to maintain the freedom to set pricing to accommodate for the existence of 100s of TLDs and business models and create a sustainable long term business model. Our goal is to provide fair pricing for domains within .Loans that reflect the value proposition derived by the Registrants of .Loans.

1.2. END USERS

It is our goal to provide end users of .Loans incremental value and minimize any negative consequences and costs associated with .Loans. We address this in the following manner

End-users bear a considerable amount of cost as a result of various forms of Internet abuse such as spam, malware, phishing, pharming, hacking, identity theft etc. Any TLD that implements policies and processes to create a clean namespace will result in a considerable reduction of these forms of abuse and hence a significant saving in terms of cost to consumers

.Loans intends to set an example when it comes to abuse mitigation and preventing abuse within .Loans. To this effect we have created unprecedented Abuse mitigation policies and Rights protection mechanisms that go significantly above and beyond mandatory requirements and common practice. These are detailed in our response to Q28. We strongly believe these practices will result in a significant reduction in online abuse and considerable savings for end users of .Loans. We similarly hope to set an example for other TLDs and cooperate with the industry in creating a clean internet experience for internet users.

2. COST BENEFIT ANALYSIS

There has been considerable debate within the community concerning the cost benefit analysis of launching new gTLDs. We strongly believe that the launch of new gTLDs and our implementation of .Loans will and add considerable value and result in a net positive effect on Registrants and end-users worldwide

We recognize that there will be a post launch review of the New gTLD Program, from the perspective of assessing therelative costs and benefits achieved in the expanded gTLD space.

To this extent we would like to offer the following pointers concerning .Loans as well as the general expansion of the new gTLD space in determining the net positive value generated for Registrants and end users -

* .Loans will reduce overall cost for end-users in combating fraud and other forms of online abuse by implementing pioneering processes and anti-abuse policies as described in our response to Q28. Billions of dollars are spent worldwide combating various forms of fraud such as malware, phishing, spamming etc. Our abuse policies will result in overall reduction of these forms of abuses within .Loans resulting in a considerable reduction in global costs spent towards combating these abuses. We also strongly believe that introduction of new gTLDs will result in increased competition which will drive significant innovation as well as competitive pressures for everyone in the industry to improve their abuse mitigation processes resulting in overall cost reduction for end-users

* The value of a Registrant getting the name they want is immeasurably larger than any costs resulting from expansion of the namespace. DotServe Inc. is a subsidiary within the Directi Group which owns and operates several ICANN Accredited Registrars. Our stats show that 70% of the users who check for a .com domain name do not get their desired name. Until this launch of the new gTLD program there were very limited alternatives and none very viable/desirable for Registrants to choose from. The value in a Registrant being able to register their desired name as opposed to a coined name is huge. It can result in savings on branding, savings on loss of traffic and other form of savings. .Loans will expand the namespace thus providing a higher probability for new Registrants to obtain names they desire

* By virtue of registering a domain name within .Loans a Registrant declares themselves to be a loan / mortgage business. This adds considerable value in terms of searchability, SEO, creating trust, branding and a sense of belonging. As of now the only mechanism that exists for users to find a specific website are search engines. Search engines however do not classify the results in any manner to make it easier for users to determine which links are relevant to them with respect to their current search. .Loans offers Registrants to standout amongst search results and allow end users to directly co-relate as to whether a search result will likely be what they are looking for. This adds considerable value to Registrants who can be easily found now, and to end-users who will take lesser time to find and trust specific sites.

This completes our response to Q18(c).

We have engaged ARI Registry Services (ARI) to deliver services for this TLD. This response describes protection of geographic names as implemented by ARI.

1. PROTECTION OF GEOGRAPHIC NAMES

In accordance with Specification 5 of the New gTLD Registry Agreement, we will initially reserve all geographic names at the second level, and at all other levels within the TLD at which the registry operator provides for registrations.

ARI supports this requirement by using the following internationally recognised lists to develop a comprehensive master list of all geographic names that are initially reserved:

- The 2-letter alpha-2 code of all country and territory names contained on the ISO 3166-1 list, including all reserved and unassigned codes [http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166-1_decoding_table.htm].

- The short form (in English) of all country and territory names contained on the ISO 3166-1 list, 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].

- The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardisation of Geographical Names, Part III Names of Countries of the World. This lists the names of 193 independent States generally recognised by the international community in the language or languages used in an official capacity within each country and is current as of August 2006[http://unstats.un.org/unsd/geoinfo/ungegn/docs/pubs/UNGEGN%20tech%20ref%20manual_m87_combined.pdf].

- The list of UN member states in six official UN languages prepared by the Working Group on Country Names of the United Nations Conference on the standardisation of Geographical Names [http://unstats.un.org/unsd/geoinfo/UNGEGN/docs/9th-uncsgn-docs/econf/9th_UNCSGN_e-conf-98-89-add1.pdf].

Names on this reserved list in ARI's registry system are prevented from registration.

A corresponding list of geographic names will also be available to the public via our website, to inform Registrars and potential registrants of reserved names. The lists noted above, are regularly monitored for revisions, therefore the reserved list (both within the registry and publicly facing) will be continually updated to reflect any changes.

In addition to these requirements, ARI are able to support the wishes of the Governmental Advisory Council (GAC) or any individual Government in regard to the blocking of individual terms on a case by case basis. ARI's registry system allows such additions to be made by appropriately authorised staff, with no further system development changes required.

The following applies to all Domain Names contained within the registry's reserved list:

- Attempts to register listed Domain Names will be rejected.
- WhoIs queries for listed Domain Names will receive responses indicating their reserved status.
- Reserved geographic names will not appear in the TLD zone file.
- DNS queries for reserved domain names will result in an NXDOMAIN response.

2. PROCEDURES FOR RELEASE

We understand that if we wish to release the reserved names at a later date, this will require agreement from the relevant government(s) or review by the GAC, and subsequent approval from ICANN.

This completes our response to Q22.