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18(c) What operating rules will you adopt to eliminate or minimize social costs?

gTLDFull Legal NameE-mail suffixDetail
.chatdot Chat Limitedfamousfourmedia.comView
Q18C
What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

The Applicant fully appreciates the concerns of ICANN, the GAC and other consumer protection authorities about the need to operate new gTLDs in ways that minimize social costs, consumer vulnerabilities as well as other time and financial resource costs. To achieve these goals this gTLD will not only employ the ICANN mandated minimum protections, but will also deploy the following innovative protection measures that will put the gTLD at the forefront of addressing these critical issues:

1) Abuse Prevention and Mitigation Policies and Procedures

The Applicant’s core mission and purpose is to create an environment where individuals and companies can interact and express themselves in ways never before seen on the Internet, in a more targeted, secure and stable environment. To achieve this goal the Applicant will be implementing a range of Abuse Prevention and Mitigation (ʺAPMʺ) policies and procedures.

These Policies and Procedures will include: 1) gTLD APM Plan, 2) Policies and Procedures to Minimize Abusive Registrations ,3) Abuse Point of Contact, 4) Policies for Handling Complaints Regarding the Abuse Policies, 5) Acceptable Use Policy (“AUP”), 6) Proposed Measures for Removal of Orphan Glue Records, 7) Resourcing plans for the initial implementation of, and ongoing maintenance of, the APM initiatives, 8) Registry semi-annual WHOIS verification, 9) Regular monitoring of WHOIS registration data for accuracy and completeness, 10) Registrar WHOIS self-certification, 11) WHOIS data reminder process, 12) Establishing policies and procedures to ensure Registrar compliance, which may include audits, financial incentives, penalties, or other means, 13) Registrar verification of WHOIS, 14) Abuse Response Process, 15) Policies and procedures that define malicious or abusive behaviour, 16) Service Level Requirements for resolution regarding APM issues, 17) Service Level Requirements for Law enforcement requests regarding APM issues, 18) Coordination of APM efforts with sector Groups and Law Enforcement, 19) Rapid takedown and suspension, 20) Controls to Ensure Proper Access to Domain Functions, 21) Enabling two-factor authentication from Registrants to process update, transfers, and deletion requests, 22) Enabling multiple, unique points of contact to request and⁄or approve update, transfer, and deletion requests, 23) Enabling the notification of multiple, unique points of contact when a domain has been updated, transferred, or deleted, 24) Additional Mechanism for Protection of Capital City Names, 25) Additional Mechanisms to Protect and Reserve IGO Names, 26) Governance Council Structure, 27) Efforts to increase Registrant Security Awareness, 28) Registrant Disqualification, 29) Restrictions on Proxy Registration Services, 30) Registry Lock. (Q28 for detail)

2) Rights Protection Mechanisms

The Applicant is firmly committed to the protection of Intellectual Property rights and to implementing all the mandatory Rights Protection Mechanisms (“RPMs”) contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Use of domain names that infringe upon the legal rights of others in the gTLD will not be tolerated and preventing abusive registrations is a core objective of the Applicant. The nature of such uses creates security and stability issues for the Registry, Registrars, and Registrants, as well as for users of the Internet in general. The Applicant will minimize time or financial resources costs by preventing abusive registrations and reduce opportunities for behaviours such as phishing or pharming. This will be achieved by implementing comprehensive registration, anti-abuse, and rights protection guidelines as defined in its AUP, as well as innovative additional RPMs such as the Mechanism to Protect IGO Names by blocking second level labels currently present in the .int zone file and the Mechanism for Further Protection of Capital City Names, as described below. In order to identify and address the abusive use of registered names on an ongoing basis, the Applicant will also incorporate and abide by the following RPMs and all other RPMs as specified in Specification 7 of the Registry Agreement and as adopted by the ICANN Board of Directors as ICANN Consensus Policies.

These Rights Protection Mechanisms will among other things include: 1) Trademark Clearinghouse, 2) Applicant’s Sunrise Period, 3) Trademark Claims Service , 4) Uniform Domain Name Dispute Resolution Policy, 5) Uniform Rapid Suspension System, 6) Trademark Post-Delegation Dispute Resolution Procedure, 7) Mechanism to protect IGO Names, 8) Mechanism for Further Protection of Capital City Names, 9) Efforts to promote WHOIS Accuracy, 10) Thick Searchable WHOIS, 11) Semi Annual Audits to Ensure Accurate WHOIS, 12) Policies Handling Complaints Regarding Abuse and Rights Issues, 13) Registry Acceptable Use Policy (“AUP”), 14) Monitoring for Malicious Activity. (Q29 for detail)

3) Governance Council Structure

The Applicant believes that sector stakeholders should be afforded the opportunity to influence the manner in which the gTLD is governed. Accordingly, the Applicant will establish a Governance Council (the “GC”) comprised of key sector stakeholders that will serve as an advisory body tasked with defining best practice recommendations for the gTLD space. The Applicant believes that the success of the gTLD will be determined largely by the sector’s key stakeholders. Not only will these stakeholders have the primary interest in registering domains in the gTLD, but they will also be motivated to protect the sector from practices that would negatively impact the sector overall. The GC exists to provide guidance on matters related to best practices, intellectual property, authentication, certification, and other matters of importance to the sector and it will elect its own Board of Directors, which will be responsible for self-governance, the recommendation of sector-specific policies, and other best practices related to the gTLD.

4) BITS and Coalition for Online Accountability (“COA”) Recommendations

The Applicant will further structure its policies around the BITS and COA Recommendations where relevant to this gTLD. The Applicant’s goal is to provide a safe and secure experience for consumers. A domain within this gTLD that is owned, operated by or compromised by a malicious party could cause harm to consumers, to the gTLDʹs reputation and to the reputation of the Internet itself. As such, additional controls are in place relating to the validity of registrations, as well as measures to ensure the correct identity of both Registrants and Registrars relating to changes made within the SRS, and to protecting the integrity of the DNS service as a whole.

The Security Standards Working Group (SSWG) formed by BITS drafted a set of policy recommendations that should be applied to financial TLDs. The policy comprises of a set of 31 recommendations that should be adopted by ICANN in evaluating any applicant of a financial gTLD. The recommendations were posted by BITS in the form of a letter to ICANN at [http:⁄⁄www.icann.org⁄en⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf].

The Coalition for Online Accountability have drafted a set of policy recommendations, also endorsed by many other international organizations representing the creative industries, that should be applied to entertainment gTLDs - especially those dependent on copyright protection. The policy comprises of a set of 7 recommendations that should be adopted by ICANN in evaluating any applicant for an entertainment-based gTLD. The recommendations were posted by COA in the form of a letter to ICANN at http:⁄⁄bit.ly⁄HuHtmq.

We welcome the recommendations from BITS and the COA and will strongly consider the recommendations relating to the implementation of this gTLD where considered relevant.

5) Registry Operators Startup Plan

The Applicant proposes to implement the following start-up plan so that the new gTLD is introduced in an orderly, transparent and stable manner. This will safeguard competition, fairness, trust and reliability for Registrants, the User Community, ICANN Accredited Registrars, and other Stakeholders.
The Applicant’s startup plan is designed to minimize social costs (e.g., time or financial resources costs, as well as various types of consumer vulnerabilities) by instilling a number of RPMs as well as APMs.
The plan consists of the following multi-phase process that will be executed by the Registry Operator. The timeline for the gTLDs start-up process and associated RPMs in the Applicants gTLD is as follows:

Phase 1 – Sunrise Process:

- Day 1: Sunrise round opens
- Day 60: Sunrise round Closes
- Day 61: Sunrise Allocation Including contention resolution mechanisms opens
- Day 71: Sunrise Allocation contention resolution mechanisms closes

• The following Rights Protection Mechanisms apply:
a. Trademark Clearinghouse (“TMCH”)
b. Sunrise Eligibility Requirements (“SER”)
c. Sunrise Dispute Resolution Policy (“SDRP”)
d. Uniform Domain Name Dispute Resolution Policy (“UDRP”)
e. Uniform Rapid Suspension System (ʺURSʺ)
f. Mechanism for the Protection of IGO Names (“PIN”)
g. Trademark Claims Service (“TCS”) *

Phase 2 – Landrush process:

- Day 72: Landrush opens
- Day 102: Landrush closes
- Day 103: Landrush contention resolution mechanisms opens
- Day 113: Landrush contention resolution mechanisms closes

- The following Rights Protection Mechanisms apply:

a. UDRP
b. URS
c. PIN
d. Mechanism for Further Protection of Capital City Names (“CCC”)
e. TCS *

Phase 3 – General Availability⁄Registrations:

- Day 114: General availability begins

- The following Rights Protection Mechanisms apply:

a. UDRP
b. URS
c. PIN
d. Trademark Post-Delegation Dispute Resolution Procedure (“PDDRP”)
e. TCS for the 90 days after day 114 *

* To ease the concerns of trademark owners and mitigate the impact of infringing registrations, the Applicant will be implementing the TCS in all three phases of launch. It is important to note that during the General Availability Phase, the TCS will be used for 90 days, 30 days longer than the ICANN mandated minimum.

18(C)(i) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?

Sunrise and Landrush periods:

During the gTLDs launch period, multiple applications for a particular domain name will be resolved through a Contention Resolution Mechanism (“CRM”) involving auctions. These CRMs will apply to the Sunrise and Landrush application phases. The CRMs will be conducted by Sedo GMBH, an experienced provider of domain auction services. The mechanisms offered will involve closed auctions where only specific bidders can participate.

During the Applicants Sunrise process, if there are two or more eligible applicants for one domain name string, then the contention will be resolved by auction. Auctions held during the Sunrise phase (“Sunrise Auctions”) will be closed and the only bidders will be eligible applicants according to the gTLDs Sunrise eligibility requirements including the TMCH.

During the Applicants Landrush process, if there are two or more eligible applicants for one domain name string, then the contention will be resolved by auction. Auctions held during the Landrush phase (“Landrush Auctions”) will be closed and the only bidders will be eligible applicants according to the gTLDs Landrush eligibility requirements.

General Availability:

After the two initial startup phases of the Registry the allocation of domain names will occur on a first-come first-serve basis, taking into account the registries APM and RPM mechanisms.

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

Incentive, Marketing and Outreach Programs

The Applicant will implement a number of incentive, marketing assistance, awareness and PR programs to assist the Registrar channel in providing a sector leading experience to end-users and to provide cost benefits for registrants. The Applicant will work with the global Registrar channel to ensure that the new gTLD offer is clearly visible on registrar sites resulting in an increase in the awareness and in the number of new gTLD registrations. Achieving this visibility requires (1) a clear business case and incentives for registrars to motivate them and (2) mechanisms and assets to make it easy for them to do so.

The Applicant will at the time of launch depending upon market conditions consider incentive programs that will deliver cost benefits to registrants through either the use of advantageous pricing, introductory discounts, bulk registration discounts or other similar methods. The Applicant is aware of Specification 9 – Registry Operator Code of Conduct, and will not directly or indirectly show any preference or provide any special consideration to any Registrar in its marketing efforts.

Example incentive mechanisms the Applicant will provide to the registrars may include:

Marketing Incentives

The Applicant intends to provide expertise, tools and creative assets to the registrars as part of general marketing and co-marketing programs. There is a significant cost saving if the expertise, tools and assets are developed centrally and the costs amortized across the registrar base. Significant cost savings can occur relating to Market Research, Social Customer Relationship Management (“SCRM”), Content Management Systems (“CMS”), Direct Marketing Tools, Marketing Collateral and Analytics Solutions.

The Applicant will employ some or all of the following marketing techniques jointly with registrars globally: (1) Direct Response Print, (2) General Web Marketing, (3) Email campaigns without Incentive, (4) Email with Incentive, (5) Email Marketing - Prospect List, (6) Email Marketing - Sponsored Newsletter, (7) Direct Marketing with Incentive, (8) Web Marketing with Incentive, (9) Viral Marketing (Social, Video, Micro-sites), (10) Develop User Interface Improvement best practices, (11) Develop Search Engine Optimization best practices, (12) Email Marketing - Registrar List
As an example of a marketing initiative, the Applicant will forward leads to the Registrars “buy” pages as an incentive via the means of Pay-Per-Click (“PPC”) search marketing. The Applicant will run multiple PPC campaigns targeting gTLD Registrants and point these to landing pages on the Registrar’s websites. Conversions are directly trackable from all PPC campaigns and keywords with a high Click-Through-Rate (“CTR”) or conversions will also be leveraged for SEO best practice purposes.

PR and Awareness Incentives:

In addition to the core outreach to the Registrar Channel, the Applicant will engage in a wider outreach to build awareness of the new gTLD with customers, end-users and other stakeholders. The Applicant will engage with a number of high profile individuals associated with the gTLD and will seek to reach end consumers through webcasts, podcasts, traditional broadcast TV as well as radio.

Provision of customer retention toolkits to Registrars:

The Applicant will use propensity modelling to build retention marketing programs to minimize churn whilst building renewal sustainability. The Applicant will develop econometric models designed to measure the likelihood of a customer segment to purchase a product or offer bundle, at a certain point in the relationship lifecycle. They are used to predict the best time, and the best combination of products, to offer to customers who match a certain profile. They are especially effective where there are large numbers of customers and reliable data can be gathered. The Applicant expects that registration volume in the gTLD will provide sufficient data for this modelling.

Measure, benchmark and improve the customer experience:

The Applicant will engage in a program to develop best practice policies related to the customer experience at differing levels of the channel. This will include the entire ecosystem from Registry through Registrar to Resellers and finally end-users. One key metric might be, for example, to reduce the number of clicks to make a purchase equivalent to the most customer friendly e-commerce sites in the world.
The Applicant might, for example, provide website performance tracking tools to registrars, which would benchmark current performance and provide insights into customers’ needs and behaviour at the point of purchase.
The Applicant will engage in a Social Customer Relationship Management Program to monitor social media feedback to questions, concerns or other issues. The Applicant will further seek to measure marketing communication expenditure and activity.

Other initiatives that will be considered by the Applicant in its outreach efforts:

(a) Customized Vertical Search App for major mobile platforms.
(b) Designated Twitter channel for the stakeholder community.
(c) Social Media outreach through Facebook and other social media solutions.

Translation into other languages:

At present, the Applicant plans to translate marketing collateral and other content that it considers to have geographically diverse appeal in to the 6 official UN languages, namely Arabic, Chinese (Mandarin), English, French, Russian and Spanish.

18(c)(iii) Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

The Applicant will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator has in excess of ten years of experience managing numerous gTLDs that utilize standard and unique business rules and lifecycles.

Initial registrations of registered names may be made in the registry in one (1) year increments for up to a maximum of ten (10) years. For the avoidance of doubt, the registration term for registered names may not exceed ten (10) years. Further the renewal of registered names may be made in one (1) year increments for up to a maximum of ten (10) years. For the avoidance of doubt, renewal of registered names may not extend their registration period beyond ten (10) years from the time of the renewal.

The Applicant plans to review domain name registration rates on an annual basis and will make a determination at that time regarding adjustments, depending upon market factors. Thus, at this time, the Applicant does not plan to make specific guarantees regarding pricing increases.

The Applicant will provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the gTLD advance written notice of any price increase (including as a result of the elimination of any refunds, rebates, discounts, product tying or other programs which had the effect of reducing the price charged to registrars, unless such refunds, rebates, discounts, product tying or other programs are of a limited duration that is clearly and conspicuously disclosed to the registrar when offered) that complies with the requirements as outlined in the New gTLD Registry Agreement.
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gTLDFull Legal NameE-mail suffixDetail
.earthInterlink Co., Ltd.urbanbrain.comView
Numerous parties have expressed concerns over the introduction of the new gTLD program stating that new TLDs could harm consumer welfare due to consumer confusion. Trademark holders have also brought up the issue of new TLDs imposing additional costs due to the necessity of participating in “defensive” registrations.

Interlink believes that these concerns are valid and is confident that costs associated with these issues may be avoided by working together with the ICANN community to address the issues. The ICANN community has worked hard to implement new Rights Protection Mechanisms and rules for new TLDs that would minimize these costs. Interlink will fully comply with all consensus policies, including all ICANN required Rights Mechanisms, including:

 1. Trademark Clearinghouse
 2. Sunrise and Trademark Claims Process
 3. Uniform Dispute Resolution Policy (UDRP)
 4. Uniform Rapid Suspension URS
 5. Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
 6. Registration Restriction Dispute Resolution Procedure (RRDRP)


1. Trademark Clearinghouse

The trademark clearinghouse is a mandatory RPM that as been developed in order to serve as a central repository for information to facilitate other RPMs such as the Sunrise Period and Trademark Claims process. Though this RPM is still under development, Interlink has joined the Implementation Assistance Group (IAG) to monitor the progress and provide feedback on solidifying the policy for its implementation. In addition, the back-end registry services provider for “.earth”, Neustar, is actively playing a key role on the IAG to ensure that protections afforded by the clearinghouse and associated RPMs are feasible and implementable. Further information regarding the implementation of this mechanism can be found in reference to Question 29: Rights Protection Mechanisms.


2. Sunrise and Trademark Claims Process

The Sunrise Period is a mandatory launch phase that a registry is required to implement for a minimum of 30 days. As described above, the “.earth” Sunrise Period serves pre-launch phase in which eligible trademark owners have an opportunity to register second-level domains under the “.earth” TLD. Interlink has participated as a registrar, and a registrant in several sunrise periods, and its back-end registry service provider, Neustar has extensive experience in implementing sunrise registration periods, most recently under the .CO TLD. Interlink will build upon its own experience and the expertise of Neustar to ensure that a simple, seamless process is implemented.

The Trademark Claims process is tied into both the Trademark Clearinghouse and the Sunrise Period. The trademark claims process is also a mandatory RPM that is intended as means to provide ʺclear noticeʺ to a potential registrant if he⁄she attempts to secure a domain name that matches a trademark, which is currently registered in the Trademark Clearinghouse. Though only required by ICANN to implement for 60 days during open registrations, Interlink believes that implementing the service over the life of the registry will greatly reduce the number of cybersquatted domain names and other cases of abuse in its zone. Interlinkʹs back-end provider, Neustar became the first TLD with a Trademark Claims service with the launch of the .BIZ TLD in 2001 and Interlink plans to work closely with Neustar to ensure the service is run smoothly.

The sunrise implementation process is described in more detail above, and in response to Question 29: Rights Protection Mechanisms. More information about Interlinkʹs implementation of the Trademark Claims process can be found in answer to Question 29: Rights Protection Mechanisms.


3. Uniform Dispute Resolution Policy (UDRP)

The UDRP is an ICANN Consensus Policy that was instituted in 1998. The UDRP provides trademark holders an alternative method to resolve domain name disputes. Interlink will monitor UDPR decisions regarding domains in the “.earth” zone and take the necessary steps to ensure that the decisions are implemented by its registrars. In the event that the registry is notified by a trademark owner that a registrar failed to implement a decision Interlink will investigate the claim and take action by either notifying the registrar of its obligations or by proactively implementing the decision itself.


4. Uniform Rapid Suspension

During the planning and policy discussion that took place in the past few years regarding the New gTLD Program, trademark owners identified that the UDRP may not be the most cost effective means to protecting trademark owners marks when there are hundreds of new TLDs in operation. Furthermore, the majority of UDRP cases were clearly cases of cybersquatting, however the UDRP did not produce immediate results. The URS is the result of many discussions with rights holders and offers a more cost effective and speedy mechanism for trademark owners to enforce their rights.

The URS requires a greater deal of participation from the registry than the UDRP. Interlink is fully aware of the requirements involved in the URS and has been actively monitoring the discussions and the development of the RPM. In the event that a “.earth” domain name is part of a URS proceeding, Interlink will follow the procedures outlined in the final policy.

According to the current draft procedures Interlink will lock the name within 24 hours or receipt of the complaint from the URS provider in order to ensure the name is not transferred or deleted and to restrict all changes to the registration data. The name will continue to resolve as normal at this point.

Once a determination has been made, and the URS provider has received notification of such a decision, Interlink will act accordingly to implement the determination. Therefore, in the event of a decision for the complainant (trademark owner), Interlink will immediately suspend the name in accordance with the policy, currently for the balance of the registration period. Additionally, the name will no longer be allowed to resolve to the original website, thus the registry will change the nameservers to redirect to an informational page provided by the URS provider.

Finally, Interlink will take steps to ensure that the WHOIS information appropriately reflects the current status of the domain name. In doing so, Interlink will leave all the original registration data, except for the nameservers, in place, and clearly reflect that the domain name cannot be transferred, deleted, or modified for the remainder of the registration period.

The current draft policy states that there shall be an option for a successful complainant to extent the registration period for one additional year at commercial rates.
Additional details regarding the implementation of the URS can be found in response to Question 29: Rights Protection Mechanisms

In addition to the implementation and compliance with proposed and existing rights protection mechanisms, Interlink will implement an Acceptable Use Policy (AUP) (described above in answer to “iv”) that will effectively secure the registry’s rights to swiftly takedown abusive domain registrations.

According to Dennis Carlton’s study “Impact of New gTLD on Consumer Welfare” new gTLDs introduced as a result of the application round in 2000, such as .info and .biz, indicates that the need for defensive registrations in new gTLDs is limited. Interlink is confident that proposed rights mechanisms listed above and enforcement of the AUP will be sufficient to minimize social costs resulting from abusive domain registrations.


i. How will multiple applications for a particular domain name be resolved?

The goal of the registry is to maximize the benefit “.earth” for its users. As such it is the Registryʹs responsibility to minimize the number of speculative registrations that ultimately turn into parked pages or remain unused.

Multiple applications for names under the Founders Program will be handled by objectively reviewing the application against the criteria set forth in the RFP. At which time, the Registry shall make a final selection based on how well each applicant fulfilled the evaluation criteria.

Multiple applications for the same domain name in both the Sunrise and Landrush will be resolved by an auction as described above in the section related to registration policies (section iv). The use of an auction to allocate names with multiple legitimate applications will benefit sunrise applicants because they will not have to rush in order to be the first to submit such an application. This also reduces the load to the systems as in past first-come, first-served launches, applicants have been known to place registration requests with several other registrars in order to optimize their chances of being the first in line.

In general, Interlink believes that settling competing applications though an auction mechanism is more desirable than a first-come, first-served method. This is due to a number of factors; for example, sunrise applicants (trademark holders) should not have to rush to submit an application for a domain name. If an applicant is forced to try to be first in line, the applicant is likely to submit a registration request through multiple registrars. This causes a sub-optimal use of energy on behalf of the applicant, causes unnecessary work on behalf of the registrars and registry. Another important factor in Interlinkʹs decision settle competing applications through an auction mechanism is due to an assumption that the highest bidder has more desire for the name, therefore, the winning applicant is likely provide more utility to Internet users.

Below is a brief description of the auction policy:

Auctions will be handled by Interlinkʹs auction partner. (Interlink is still evaluating potential partners, all of which have many years of experience in the domain name industry and have processed Sunrise and Landrush launches for several TLDs in the past).

The general rules of the policy are standard to auctions that have existed for recent TLD launches. Each participant of the auction will receive a notification at a certain time prior to the start of the auction and a subsequent email on the day of the auction that announces the commencement of the bidding. The Auction management system will notify participants of any bid changes as well as any extensions to the length of the auction. The winner will be announced at the close of the auction period and the domain name will be allocated accordingly.


ii. Explain any cost benefits for registrants you intend to implement.

The Registry will clearly communicate its registry policies and launch plans to potential registrants directly as well as though partner registrars. The registry will give special rights to governments to register their geographic names (names and two letter codes on the ISO 3166-1 list) at the second-level. The registry will offer the first rights to these names for a period of no less than a year. This special provision for governments will ensure that they have first rights to register their names for a minimal cost from an ICANN accredited registrar rather than have to dabble in the speculative markets.

Interlink will also hold a Sunrise and Landrush period as described in part “iv” above. Interlink anticipates that the several competing applications may be submitted in both periods, and, therefore, proposes to implement an auction mechanism as a fair way to solve the issue of competing applications. A traditional first come first served mechanism will create more load for registrars as one prospective registrant may chose to place the same application for a domain name through several registrars. Then there is the issue of which connection hits the registry first for a certain name.

An auction at the early stages of a registry will benefit registrants by allowing them to purchase the domain name for much less that the cost that they would incur in the domain aftermarket. Furthermore, an auction will allow the users to place a value on the domain name. It can be assumed that the bidder who places the higher bid places a higher value on the domain name, and therefore will be more likely to develop the domain name to be beneficial for Internet users.


iii. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation?

As stated in draft registry agreement in the New gTLD Applicant guidebook, the “.earth” registry will commit to only adjusting prices based on market conditions and staying consistent with the current inflation rate. The issue of price increases will be adequately reviewed on a biannual basis.