.safety Pre-Register Domain - .safety Domain Information

18.1.1 Mission and Purpose of .SAFETY
The content of this Answer to Question 18 set forth below which describes the plans for the Applicant's registry constitutes the "purpose" of the registry as that term is used in Paragraph 1.b. of Specification 9 of the Draft New gTLD Registry Agreement found in Module 5 of the Applicant Guidebook dated January 11, 2012 (the "Purpose"). This .SAFETY gTLD will be brought to market by Safety Registry Services, LLC ("Safety Registryʺ) a wholly owned subsidiary of W.W. Grainger, Inc. ("Grainger").

The intended mission and purpose of .SAFETY is to serve as a trusted, hierarchical, intuitive namespace for a network of customers, potential customers, corporations, first responders, experts, and other service organizations to interact with peers, and have access to authoritative content, and generally needed and valuable safety information. In furtherance of this goal, Safety Registry aims to publish a Charter and all associated policies, guidelines, and other supporting documentation related to the implementation of the registry consistent with the Purpose, all prior to launch. All second-level domain names registered by Safety Registry on behalf of itself or a parent/affiliate will be registered through an ICANN-accredited registrar and will be consistent with the Purpose.

18.1.2 Grainger's Commitment to Safety
As the largest distributor of safety products in North America, Grainger understands the safety needs of companies and organizations operating facilities safely and helping keep employees safe. Grainger helps them achieve their facility and people-related safety goals by providing products/solutions that help to maintain regulatory compliance and reduce the of fines; improve facility safety and reduce accident/injury rates; and decrease operating costs such as worker compensation, litigation, and lost productivity. Grainger does this through its 50,000+ safety SKUs in many different safety categories like PPE, First Aid, and Workplace/Environmental/Public Safety as well as its services capabilities that include safety program management, safety training, customizing of safety products, and managing of safety inventory.

There are a number of Grainger resources that companies and organizations are able to utilize to support their safety efforts such as the online Safety catalog; Strategic Alliances with Safety Product Manufacturers; On the Job Webinar Series; Safety Specialists to answer safety questions; and Quick Tips on key safety topics and issues. Grainger is also a member of some of the leading associations in safety, such as NSC and ASSE, and regularly participates in their tradeshows and conferences.

Grainger has a long history of supporting and serving community organizations through its philanthropy. It has been recognized by the U.S. Chamber of Commerce for its leadership in partnering with the American Red Cross to recruit and train volunteers from the business community to respond to disasters. Grainger is the national founding sponsor of the Ready When the Time Comes disaster volunteer program in the U.S. and Canada. Graingerʹs strong commitment to community safety is evident in its ongoing service and partnership in emergency preparedness with a spectrum of corporate, not-for-profit, and government organizations.

18.1.3 Potential Business Model
Safety Registry does not intend to apply for a community designation under ICANN's Applicant Guidebook criteria, however, it is committed to operating .SAFETY with a relatively narrow Charter and focus.

Depending upon the reception of .SAFETY, Safety Registry envisions the creation of a Safety Network that could serve as an independent membership organization. Membership in the Safety Network could be a prerequisite to being eligible to register a .SAFETY domain name. While Grainger intends to commit to the initial funding and launch of .SAFETY, it views this future creation of the Safety Network as an important step in the long-term independence, viability, and credibility of .SAFETY. Through the Safety Network, Safety Registry aims to vet the potential registrant pool to ensure that .SAFETY will be a trusted and authoritative namespace of safety-related information, including guidelines and requirements. As currently planned, all members of the Safety Network will also be bound by the Charter, and will be required to abide by the rules and standards set forth in order to maintain registration rights of a .SAFETY domain. Eligible entities may include, but are not limited to the following:

Manufacturers/resellers of safety products (even if they are competitors of Grainger)
Public safety departments
Fire departments
Educational institutions
Hospitals
Non-governmental organizations

18.1.4 Registry Launch Phases
To facilitate the strategic and sustainable development of .SAFET, Safety Registry currently envisions a three-stage rollout:

Stage 1
This initial stage will likely involve Safety Registry reserving ICANN and GAC required reserved domain names along with a limited number of second-level domain names for future registry use. In addition, Safety Registry would register a limited number of generic second-level domain names to develop information portals to begin to seed the registry with relevant content in order to attract traffic.

During this initial phase, Safety Registry, with support from Grainger's IT personnel, plans to run a number of tests to ensure seamless and more secure access to .SAFETY websites, and interoperability with various software and Web-based applications. The registration and use of these domain names are intended to be within the scope of Section 1B of Specification 9, regarding the maintenance, operation, and purpose of the gTLD.

Stage 2
Once all testing has been successfully completed, select partners meeting the Charter/ membership requirements mentioned above will likely be eligible to register .SAFETY domain names. This may include, but is not limited to, government agencies, NGOs, and other service organizations with a dedicated mission and leading presence in the safety industry, such as Occupational Safety and Health Administration (OSHA), National Institute for Occupational Safety and Health (NIOSH), The Red Cross, and International Organization for Standardization (ISO), key universities in the safety arena, and other national and international organizations of similar stature.

Depending upon the reception of .SAFETY within the safety community, Safety Registry will begin evaluating the creation of the independent Safety Network discussed above. In undertaking this analysis, Safety Registry endeavors to enlist the support of Grainger and the current registrants within the gTLD.

Stage 3
Based on experiences gained through the first stages of operation and the analysis undertaken in Stage 2, Safety Registry intends to either retain its role as a trustee of the .SAFETY Charter, or it will transition this governance aspect of the registryʹs operation to the Safety Network. Either way, Safety Registry is presently committed to the future expansion of the namespace for the benefit of the safety community. It is currently anticipated that any creation or transition of rights to the Safety Network would not take place until after the third year of operation.

Depending upon the decision following the analysis referenced above, there are a number of potential funding options to ensure the continued secure and stable operation of the .SAFETY registry including, but not limited to: dues from the Safety Network to fund the registry on a cost recovery basis; an additional funding from Grainger, or a combination of both. Notwithstanding any potential expanded use of .SAFETY, Safety Registry currently anticipates implementing a throttle mechanism to ensure that any expansion is controlled and responsible. This mechanism is explained in more detail in the response to Questions 46.

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

Safety Registry believes that the proposed .SAFETY gTLD has the potential to offer the following benefits to Internet users, customers, and potential customers:

1) Establish a leading source of information and an online marketplace for the millions of Internet users, businesses, governments, and others that consume, rely upon, and interact with safety information as well as safety-related products and services on the Internet;

2) Provide short and memorable domain names for the provision of relevant safety content to the Internet population. The domains may facilitate the ease by which customers and potential customers can locate critical information or products online;

3) Potentially minimize the social costs and harm to Internet users by reducing incidents of phishing and malware often associated with mistypes of domain names in the .COM space;

4) Potentially minimize the social costs and harm to customers by giving them access to safety-related information and products via a trusted and reputable namespace in .SAFETY.

5) Incorporate enhanced intellectual property rights protection mechanisms (RPMs), specifically an additional safeguard to enhance the chances that any initial reserved/allocated names for use by Safety Registry that are in connection with the management and operations of the gTLD do not violate any potential third-party rights.

6) The incorporation of Registrant Eligibility (i.e., who is eligible to register domain names within the .SAFETY gTLD); Name Selection Criteria (i.e., ensuring that the domain name corresponds to a trademark, service mark, or business name); and Authorized Usage policies that will be established in accordance with the .SAFETY Charter prior to launch.

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

Through the .SAFETY gTLD, Safety Registry intends to develop a leading online resource that will provide Internet users, customers, potential customers, corporations, and first responders with the framework to access and interact with experts and peers, relevant content, and generally needed and valuable safety information.

Safety Registry will also ideally be able to provide access to safety-related products and online content in a gTLD that aims to minimize piracy, cybersquatting, and other malicious activities. Providing customers and potential customers with a more secure online arena is of paramount importance to Safety Registry and Grainger, and the .SAFETY gTLD will be used to further that goal.

Safety Registry is driven by the same core values as its parent company, Grainger, and it plans to leverage this experience to bring a spirit of public service to the .SAFETY gTLD.

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

Unlike most generic gTLDs that ICANN has approved over the last decade, which have largely been operated by Internet startups, Safety Registry's parent company, Grainger, is an established global company with the ability to leverage its existing network of businesses, partners, and customers in the safety space to increase the profile of the .SAFETY gTLD. While most registries have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD, Grainger intends to provide Safety Registry with the ability to leverage its large market share, strong reputation, longstanding commitment to philanthropy, and existing relationships with various organizations and businesses in the safety community to achieve its goals.

While some of ICANN's new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, from its launch, .SAFETY will aim to be a trusted source of safety-related content, goods, and services for Internet users. Safety Registry looks to follow the established good business practices of its parent company, Grainger, to create a network of sites and information with safeguards designed to minimize fraud and other illegal activity.

As a gTLD dedicated to the safety community, the primary driving factors behind the .SAFETY gTLD application are differentiation and innovation. Today, the Internet is plagued with fraudulent sites, harmful viruses, and misinformation. .SAFETY aims to protect customers and potential customers of safety-related information, services, and products by establishing a trusted network of websites and content related specifically to safety issues, services, and products.

The success of the .SAFETY gTLD will not be measured by the number of domains registered, but rather by the levels of customersʹ and potential customers' recognition that are placed in the .SAFETY gTLD. Using this benchmark, Safety Registry strives to build recognition and trust through the usage of the .SAFETY gTLD that rise to the level of that found in the .EDU and .GOV gTLDs.

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

Safety Registry envisions that the .SAFETY gTLD can provide a single, more secure ecosystem experience for customers, potential customers, and many organizations worldwide that seek safety-related information, products, and services via existing online, print, mobile, and social platforms. Internet users and the general public will be able to access authoritative safety-related information from trusted sources within the .SAFETY gTLD. By providing the foundation of this trusted ecosystem, domain name registrants in the .SAFETY gTLD will likely be able to share in the benefits of this collective resource.

Through a collection of core generic domain names and geographically designated domain names, the .SAFETY gTLD plans to provide users with a seamless and more secure experience with all related content.

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

In line with the mission stated in 18.1.1 above, Safety Registry plans to initially have safeguards in place to ensure that only approved agencies, organizations, and businesses operating in the safety industry are able to register second-level domain names in the .SAFETY namespace. However, as stated above, Safety Registry reserves the right to extend registration rights to potentially a broader class of registrants.

In addition, Safety Registry intends to provide for three base line policies that will be identified in the Charter and which must be fully designed and implemented prior to the launch of the registry. These policies include: Registrant Eligibility (i.e., who is eligible to register domain names within the .SAFETY gTLD); Name Selection Criteria (i.e., ensuring that the domain name corresponds to a trademark, service mark, or business name); and Authorized Usage policies. These policies are set forth in greater detail in the response to Questions 28, 29, and 30 of this application.

While these are the likely initial policies that Safety Registry will adopt for the operation of the .SAFETY gTLD, it recognizes that minimizing online harm to users of websites within the .SAFETY namespace will require diligence and a continued evolution of the policies. Therefore, Safety Registry is evaluating the potential creation of a policy advisory body that could draw upon a representative composition of the community to recommend best practices.

As noted above, depending upon the reception of the .SAFETY gTLD within the broader community, Safety Registry and Grainger envision the creation of a Safety Network that could serve as an independent membership organization, membership in which could be a prerequisite prior to being eligible to register a .SAFETY domain name. Grainger views this future creation of the Safety Network as an important step in the long term independence, viability, and credibility of the .SAFETY gTLD. If the Safety Network is to be created, the policy advisory board functions may shift to Safety Network.

Safety Registry endeavors to implement all of ICANN's consensus policies and other Rights Protection Mechanisms ("RPMs") identified in the Applicant Guidebook. In addition, Safety Registry intends to provide best-in-class safeguards that will evolve over time.

At the time of completing this application, Safety Registry has identified an RPM that will allow trademark owners to challenge domain names initially reserved by the registry (e.g., generic and geographic names identified in Section 18.1.1). This process will likely be modeled after the dotAsia Pioneer Policies adopted by dotAsia in connection with its launch, see http://www.wipo.int/amc/en/domains/gtld/asia/.

18.2.6 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.

Safety Registry recognizes that this is an evolving area of law for which there are no international standards. However, due to the fact that domain names within the .SAFETY namespace will be registered to members of the aforementioned Safety Network, Safety Registry has an interest in maintaining accurate and current domain name information, and making it readily available in connection with each .SAFETY domain name.

In addition, Safety Registry intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states "Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person ("Personal Data") submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use Personal Data in a way that is incompatible with the notice provided to registrars.ʺ

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

As noted in 18.2.3, most of the generic gTLDs that ICANN has approved have primarily been operated by Internet startups created solely for the provision of domain name registration services, e.g., .INFO (Afilias), .BIZ (Neustar), and .TRAVEL (Tralliance). Grainger is an established global company with the ability to leverage its extensive network of partners, suppliers, customers, and related websites to establish the .SAFETY gTLD. While most registries have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD, Safety Registry will leverage current and future relationships both inside and outside of the Safety Network to increase the profile of the .SAFETY gTLD.

Through the initial phases of use, the .SAFETY gTLD will aim to allow Safety Registry to properly and sustainably develop the .SAFETY gTLD in such a manner as to ensure that the .SAFETY gTLD is viewed by Internet users as a trusted source for authoritative information, content, and products related to safety. Moreover, appropriate outreach and communication efforts will likely be done in conjunction with the initial stages of the rollout to market the .SAFETY gTLD to Internet users.

While Safety Registry will initially rely upon Grainger in the initial outreach and communication, the long-term independence, viability, and credibility of the .SAFETY gTLD may rely upon the aforementioned Safety Network to serve as a trustee of the Safety Charter. Moreover, as the registry will likely operate on a cost recovery basis, the members of the Safety Network may consider ensuring that there is a diverse and representative membership to share in this future ongoing operation of the registry.

18.3.1 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)?

Over the past decade, ICANN has approved fifteen new gTLDs that have historically been classified as either generic (.INFO, .BIZ, .NAME) or sponsored (.ASIA, .COOP, .TRAVEL, .JOBS, etc.) gTLDs. It is anticipated that in this current new gTLD application round, many large international corporations will take the opportunity to register generic strings as top-level domains.

Safety Registry's plan presented here, which is a new approach to the operation of a gTLD and different from the approach of gTLDs that were approved in the 2001 and 2004 rounds of expansion, removes the risk and uncertainty of prior gTLDs by relying on these defining factors:

-.SAFETY is planned as a gTLD well within the registration range of those having more than a decade of gTLD industry development and experience;
-.SAFETY will rely on an experienced back-end provider; and
-Safety Registry will push to leverage the leading position of its parent company, Grainger, in the safety industry to bring the .SAFETY gTLD to market.

In addition, Safety Registry believes that the safeguards set forth in the Applicant Guidebook and the additional RPM identified in Section 18.2.5 are primary drivers to help minimize potential negative social costs.

Moreover, it is intended that all registrants within this gTLD will comply with the membership criteria established by Safety Registry, and/or be a member of the Safety Network if it is created. This requirement will hopefully create a legal obligation of the registrant to comply with all the Charter requirements, including but not limited to Registrant Eligibility, Name Selection Criteria, and Authorized Usage policies. These requirements will aim to establish that only authoritative and trusted organizations and individuals operating within the safety industry are entrusted to register domain names. This operating rule to limit registration will help to establish a more trusted online environment for customers and potential customers to access authoritative safety-related online content, and by default, will minimize social costs. This environment aims to provide customers and potential customers with a single, trusted source for safety-related information, goods, and services with a lower risk of fraud and/or scams.

18.3.2 What other steps will you take to minimize negative consequences/costs imposed upon consumers?

Safety Registry believes that the proposed operation of the .SAFETY gTLD as set forth in this application has no anticipated negative consequences or cost implications to customers or potential customers. To the contrary, the proposed operation of this registry may lead to direct and quantifiable benefits to customers and potential customers.

Due to the restrictive nature of the .SAFETY gTLD, there is no need for other trademark and brand owners to defensively register second-level domains in the .SAFETY gTLD. Safety Registry intends to limit registration to approved entities and individuals operating and involved in the safety industry.

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

If such instances should arise, Safety Registry believes that a phased equitable allocation approach modeled after those that ICANN has previously approved in connection with numerous ICANN Registry Service Evaluation Process ("RSEP") requests would probably be the most prudent path forward, e.g., RFP, auction, and then first-come, first-serve.

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

Safety Registry does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing/commercial initiatives are inconsistent with the mission and Purpose of the .SAFETY gTLD as a trusted online source identifier.

18.3.5 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.

Safety Registry aspires to provide domain name registration services in accordance with the periods set forth in the Registry Agreement and to provide domain name registrants with pricing notice and predictability. However, as noted in the proposed business model (18.1.3), Safety Registry intends to limit domain name registration services to only those registrants that agree with Charter/membership requirements. Should a Safety Network be created as envisioned above, membership in this organization would likely be a pre-requisite prior to being able to register in the .SAFETY gTLD. Therefore, failure to comply with these requirements in either scenario would likely result in the suspension and/or cancellation of the domain name registration.

Safety Registry acknowledges that the current template Registry Agreement requires that the Registry Operator "shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar." However, Safety Registry does not plan to offer any refunds should a domain name registration be canceled for non-compliance with the Charter and or other membership criteria.

22 Safety Registry Services, LLC has Properly Researched this Topic

Safety Registry Services, LLC ("Safety Registry") is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the DNS. Safety Registry is also very aware of the benefit to customers and potential customers that second-level geographic indicators can have in restricted registries, such as the one that is the subject of this application. In preparation for answering this question, Safety Registry reviewed the following relevant background material regarding the protection of geographic names in the DNS:

- 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;
- "Report of the 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;
- ICANN's Governmental Advisory Committee (GAC) Principles Regarding New gTLDs, see https://gacweb.icann.org/download/attachments/1540128/gTLD_principles_0.pdf?version=1&modificationDate=1312358178000; and
- 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.

22.1 Initial Reservation of Country and Territory Names

Safety Registry aims to initially reserve the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and at all other levels within the .SAFETY gTLD at which Safety Registry will provide registrations. Specifically, Safety Registry plans to 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, see 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 six 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

Safety Registryʹs parent company, W.W. Grainger, Inc. (ʺGraingerʺ), is a leader in the distribution of maintenance, repair, and operating ("MRO") supplies and related information. Grainger had net sales of nearly $8.1 billion in 2011, and operates with over 700 branches across the globe that serve small to large business customers. Grainger's products can be purchased worldwide, and Grainger content is accessible in multiple TLDs, including the .COM gTLD and the .CN, .CA, and .MX ccTLDs.

In providing content, products, and services available online, Grainger makes regular use of ccTLDs in providing customers and potential customers with a geographical and intuitive namespace to navigate for relevant content, examples of which include AcklandsGrainger.ca.

Grainger currently operates a number of websites using a combination of second-level and top-level domain names. A representative sampling of Graingerʹs websites that incorporate geographical identifiers into domain names include:

GraingerChina.com
GraingerIndia.com
Grainger.cn
Grainger.com.mx
GraingerMexico.com
GraingerColombia.com
Grainger.ca
GraingerIndonesia.com
Grainger.tw

The above representative list of examples demonstrates fair and non-misleading use of geographical identifiers. As such, Safety Registry believes that the .SAFETY gTLD can provide an online, single source-identifying location for its current and future customers worldwide, as well as enhance and supplement the domain names that Grainger has used in different markets around the globe.

Safety Registry would like to provide a hierarchical and intuitive framework for the .SAFETY namespace by using geographical identifiers in second-level domain names. This use of geographical identifiers to the left of the gTLD and as part of the domain names themselves is believed to have a direct and material impact on search engine algorithms and their corresponding query results. Safety Registry will evaluate if this type of hierarchical and intuitive use of a second-level domain name within a gTLD will provide increased functionality and drive innovation, as premised by ICANN.

22.3 The Legal Protection of Geographical Identifiers

The World Intellectual Property Organization (WIPO) authored an authoritative resource on the current state of the law in connection with the protection of geographical identifiers, its 2001 "Report of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name System" ("WIPO Report"). Section six of the WIPO Report was devoted exclusively to the protection of Geographical Identifiers.

From its analysis of 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 WIPO Report Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in Grainger's current or Safety Registryʹs 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 ICANN's 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.

Safety Registry's parent company, Grainger, as a responsible international business, seeks to minimize any potential business practices that might mislead customers and potential customers. However, at the same time, it believes that it is important to be able to use geographical identifiers in a fair and non-misleading manner, if such use can benefit Internet users as proposed in Safety Registry's business model.

22.4 Samples of Fair & Non-Misleading Use of Geographical Identifiers

In undertaking thorough research of this topic prior to filing this application, Safety Registry'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 cooperation, and works to promote, develop, and unite cooperative enterprises within the United Kingdom.

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 by a joint effort between DE, the 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 the Brooklyn Cooperative Federal Credit Union, which 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 a 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 Non-Misleading Use

Safety Registry has stated its intention to consider using non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading manner to help customers and potential customers navigate the .SAFETY namespace. Safety Registry plans to operate the .SAFETY namespace in a manner that minimizes potential confusion by customers and potential customers, and will 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

Safety Registry looks forward to collaborating with other new gTLD Registry Operators in potentially working with ICANN's GAC to explore potential processes that could result in the release of initially reserved country names (including ISO-3166 two characters). Specifically, Safety Registry is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD Registry Operators in releasing previously reserved domain names.

22.7 Dispute Resolution

Safety Registry does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .SAFETY gTLD based upon its proposed Purpose set forth in the response to Question 18 of this application.

However, Safety Registry is interested in 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 .SAFETY. Therefore, should there arise any potential disputes, Safety Registry aims to undertake an immediate policy development process as identified below.

22.8 Creation and Updating the Policies

If there should arise some future need for the creation or updating of the policies regarding this class of domain names, Safety Registry plans to act in an open and transparent manner consistent with its prior practices to develop such a policy and/or recommendation.

Safety Registry also wishes to continually review and update these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, Safety Registry intends to be an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.