18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

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18b. How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

(b) .bbb Q18 Application Text Responses

Due to the unregulated nature of the Internet and the proliferation of fraud and criminal activity on the web, Applicant sees a critical need to extend marketplace trust to the online environment. Applicant is pursuing the proposed .bbb TLD with the purpose of creating an online community of BBB Accredited Businesses and Accredited Charities where trust, standards and accountability are the norm and consumers can confidently transact business and interact online with organizations that have been vetted against BBB standards.
I. Goals of the Proposed .bbb TLD in Terms of Specialty, Service Levels and Reputation

• Specialty – The number one mission of BBB is creating marketplace trust. The BBB’s accreditation process creates marketplace trust in traditional “bricks and mortar” businesses and charities and, in the past 15 years, also online. CBBB believes the proposed .bbb TLD has the potential to expand dramatically marketplace trust in the online environment. The combination of BBB’s rigorous accreditation processes for businesses and charities combined with proposed restrictive domain registration policies limiting registrations to the BBB community (Accredited Businesses, Accredited Charities, CBBB, local BBBs, and the BBB Wise Giving Alliance) uniquely positions the .bbb TLD as the destination for trusted online commerce and interaction.

• Service levels –One of the key goals of the proposed .bbb TLD is to create a restricted, community TLD where consumers and donors can be assured that registrants have demonstrated a history of adhering to BBB standards such as the Standards for Trust and Charity Accountability. BBB’s Standards for Trust and Charity Accountability are a comprehensive set of policies, procedures and best practices focused on how businesses and charities should treat the public – fairly and honestly in all circumstances. Applicant believes that creating a trusted online environment will expand its service to the growing online market by offering consumers a positive online experience while reducing fraud in online transactions.

• Reputation – BBB is a strong advocate for ethical businesses and informed consumers in the marketplace. Research shows that more than 90 percent of consumers know of and trust BBB; 70 percent of consumers prefer to buy from BBB Accredited Businesses. With the online channel growing in importance, one of the goals of the proposed .bbb TLD is to further solidify BBB’s reputation as a creator of cost-effective and reliable solutions that add trust and confidence to the marketplace.

II. The Proposed .bbb TLD Will Add to Competition, Differentiation, and Innovation

• Competition – As technology advances so too do consumer expectations of companies and charities online. They expect that they will utilize the latest and best technologies and online practices to improve the user experience, protect their information and deliver quality service. CBBB anticipates that the proposed .bbb TLD will enable its community members to communicate, interact and protect data in ways and under conditions not possible under the existing namespace, thus enabling members of the CBBB community to meet future client expectations and competitive market demands.

• Differentiation – While today entities like CBBB can register brand strings at the second-level (e.g., bbb.org), the proliferation of cybersquatting, trademark violations (e.g, use of BBB seals and logos), and typosquatting has placed a great burden on consumers to tread carefully online because there is no guarantee that what looks like a branded website is indeed an authorized website of the brand owner. The proposed .bbb TLD will enable consumers to distinguish on the face of the domain name that the business or charity behind the domain registration is who it purports to be because the .bbb TLD will be a restricted, community-based online environment where the only web properties and email that will exist will be those of qualified members of the BBB community.

• Innovation - The proposed .bbb TLD as a restricted, community-based TLD will provide the BBB community members with a new platform on which to build future innovation of their online brand and business presence.

III. Goals of Proposed .bbb TLD in Terms of User Experience

The Internet has been plagued by cybersquatting, typosquatting, phishing, pharming, trademark and copyright infringement, counterfeiting, and identity theft scams. In addition, the BBB Accreditation seals are constantly infringed by fraudulent businesses online. This malicious online conduct has shaken the trust and confidence of consumers to share information and transact business online. Thus, the proposed .bbb TLD has the following user experience goals:

• Elevate the trusted status of BBB Accredited Businesses and Accredited Charities among all organizations online through the qualified use of .bbb domain names.
• Foster consumers’ trust and confidence in online interactions with BBB community members.
• Reduce the risk of Internet users being misled, believing in and⁄or acting on erroneous information about fraudulent businesses, charities and nonprofit organizations presented online by unauthorized third parties claiming to be BBB accredited.
• Create .bbb as the destination for online marketplace trust for consumers, donors and BBB community members worldwide.

IV. Intended Registration Policies

A. Eligible Registrants

The proposed .bbb TLD will be used exclusively by eligible members of the BBB community and there will be strict limitations on which persons, organizations and entities are allowed to acquire a .bbb domain. This restriction on registrant eligibility will ensure that the BBB mission of marketplace trust is maintained in the .bbb namespace. The .bbb domain will be rescinded if anyone loses their rights to eligibility or if they do not abide by the terms and conditions of registration.

Eligible Registrants fall into the categories set forth below:
Accredited Businesses
There are approximately 400,000 businesses accredited by the BBBs throughout North America. These Accredited Businesses have contractually agreed with their local BBB to comply with BBB’s Code of Business Practices, which consists of eight primary principles that are designed to create and maintain trust in the marketplace, which are updated from time-to-time based on best business practices. A summary of the standards includes the following principles:
1. Build Trust

An Accredited Business must establish and maintain a positive track record in the marketplace including, but not limited to:

• having been operational in a BBB service area for at least 12 months
• fulfilling all licensing and bonding requirements
• being free from certain government actions
• being free of an unsatisfactory rating and maintaining at least a B rating
• honoring any settlements, agreements or decisions reached as an outcome of a BBB dispute resolution process

2. Advertise Honestly
An Accredited Business agrees to adhere to established standards of advertising and selling including, but not limited to:
• following federal, state⁄provincial and local advertising laws
• abiding by the BBB Code of Advertising
• substantiating advertising and selling claims
• correcting advertising and selling practices when recommended by BBB
• cooperating with BBB self-regulatory programs for the resolution of advertising disputes
• using the BBB name and logos in accordance with BBB policy

3. Tell the Truth
An Accredited Business must honestly represent products and services, including clear and adequate disclosures of all material terms.
4. Be Transparent
An Accredited Business must openly identify the nature, location, and ownership of the business, and clearly disclose all policies, guarantees and procedures that bear on a customer’s decision to buy.
If selling products or providing services on websites or via other electronic means an Accredited Business agrees to:
• provide any required product labeling information
• disclose the nature and terms of shipping, including any known delays or shortages of stock
• provide an opportunity to review and confirm the transaction before the sale is completed
• provide a receipt summarizing the transaction after the purchase
5. Honor Promises
An Accredited Business must abide by all written agreements and verbal representations.
6. Be Responsive
An Accredited Business must address marketplace disputes quickly, professionally, and in
good faith.
7. Safeguard Privacy
An Accredited Business agrees to protect any data collected against mishandling and fraud, collect personal information only as needed, and respect the preferences of customers regarding the use of their information.
A. Respect Privacy
Accredited Businesses conducting e-commerce agree to disclose on their website the following:
• what information they collect
• with whom it is shared
• how it can be corrected
• how it is secured
• how policy changes will be communicated and
• how to address concerns over misuse of personal data.
B. Secure Sensitive Data
Accredited Businesses that collect sensitive data online (credit card, bank account numbers, Social Security number, salary or other personal financial information, medical history or records, etc.) will ensure that it is transmitted via secure means. Accredited Businesses will make best efforts to comply with industry standards for the protection and proper disposal of all sensitive data, both online and offline.
C. Honor Customer Preferences
Accredited Businesses agree to respect customer preferences regarding contact by telephone, fax and e-mail, and agree to remedy the underlying cause of any failure to do so.
8. Embody Integrity
An Accredited Business agrees to approach all business dealings, marketplace transactions and commitments with integrity and to avoid involvement in activities that reflect unfavorably on, or otherwise adversely affect the public image of BBB or its accredited businesses.
Accredited Charities
BBB Accredited Charities will also be eligible to register for a .bbb TLD if they 1) meet the BBB Standards for Charity Accountability and 2) are licensed to participate in the BBB charity seal program. To date there are approximately 1,300 nationally soliciting charities that have been the subject of a BBB Wise Giving Alliance charity review. About 500 of these national charities are accredited (i.e., found to meet all 20 of the BBB charity standards). In addition, 55 of the local BBBs produce reports on 9,500 locally soliciting charities. Locally-soliciting charities that meet the BBB Standards for Charity Accountability are also eligible for accreditation. The BBB Standards for Charity Accountability fall under the following categories, broadly summarized as follows:
Governance and Oversight
The governing board has the ultimate oversight authority for any charitable organization. This section of the standards seeks to ensure that the volunteer board is active, independent and free of self-dealing.
Measuring Effectiveness
This section of the standards seeks to ensure that an organization has defined, measurable goals and objectives in place and has a defined process in place to evaluate the success and impact of its program(s) in fulfilling the goals and objectives of the organization and that also identifies ways to address any deficiencies.
Finances
This section of the standards seeks to ensure that the charity spends its funds honestly, prudently and in accordance with statements made in fund raising appeals.
Fund Raising and Informational Materials
A fund raising appeal is often the only contact a donor has with a charity and may be the sole impetus for giving. This section of the standards seeks to ensure that a charityʹs representations to the public are accurate, complete and respectful.
Council of Better Business Bureaus
The Council of Better Business Bureaus (CBBB) is a nonprofit organization based in Arlington, Virginia, that serves as the umbrella organization for the local BBBs, coordinates the standards and policies for all BBBs, and ensures compliance therewith. CBBB holds the trademarks for the BBB system, promotes the BBB brand, and protects the trademarks and copyright materials on behalf of the BBBs. CBBB also operates many self-regulatory and dispute resolution programs that serve the mission of promoting trust in the marketplace.
Local Better Business Bureaus
Currently there are 116 BBBs throughout North America. They operate independently and are all nonprofit corporations. All are required to follow the same operating standards and policies and promote the same overarching mission of marketplace trust as the CBBB.
BBB Wise Giving Alliance
The BBB Wise Giving Alliance (BBB WGA) is a U.S. tax-exempt nonprofit charitable organization which helps donors make informed giving decisions and advances high standards of conduct among organizations that solicit contributions from the public. The BBB WGA produces in-depth evaluative reports on national charities based on comprehensive Standards for Charity Accountability that address charity governance, finances, fund raising, donor privacy and other matters. It also publishes a magazine, the Wise Giving Guide, three times a year that summarizes the results of these evaluations. Nationally soliciting charities that meet all of the BBB charity standards can apply to participate in the National Charity Seal program.
B. Registration Use and Conduct of Registrants
Registrations under .bbb will only be used for business or charitable purposes related to the member’s accreditation by BBB. Registrations under .bbb shall not be used for personal, non-business-related purposes.
Registrants must act in accordance with all specified BBB standards and codes (as applicable and as may be amended) in their use of the .bbb TLD. Failure to adhere to standards and codes that are the basis of BBB accreditation can result in loss of accreditation and will be grounds for suspension or termination of .bbb registrations and⁄or community member status and privileges.
A registrant may not (a) register the .bbb domain name for an unlawful purpose or (b) knowingly use the domain name in violation of any applicable laws or regulations.
Registrants of .bbb domains may not delegate subdomains to external organizations, institutions, or individuals, or use such subdomains for purposes external to the basis for their entitlement to registration in .bbb.
Registrants of .bbb also may not register a domain name solely for the purposes of selling, trading or leasing the domain name for compensation, or for the unsolicited offering to sell, trade or lease the domain name for compensation. A .bbb domain name cannot be used by any organization, institution or individual other than the one to which it is registered.
Finally, no proxy or private registration will be permitted. True and accurate registrant information must be contained in the WHOIS.
V. A .bbb TLD Will Provide for the Protection of the Privacy or Confidential Information of Registrants and Users

The local BBBs, CBBB, and BBB Wise Giving Alliance all have in place privacy policies to protect the privacy of users of their programs and websites. In addition, BBBs and BBB WGA impose privacy requirements on their accredited businesses and charities.

As noted above, accredited business registrants will be required to comply, at a minimum, with the current BBB Code of Business Practices (“Code”), which encapsulates the BBB system standards for accredited businesses. The Code incorporates a baseline privacy and security standard, Standard 7, “Safeguard Privacy” which applies to organizations engaging in ecommerce or collecting sensitive data online. Standard 7 specifically states:
Protect any data collected against mishandling and fraud, collect personal information only as needed, and respect the preferences of customers regarding the use of their information.
An accredited business agrees to:

A. Respect Privacy
Businesses conducting e-commerce agree to disclose on their website the following:
• what information they collect,
• with whom it is shared,
• how it can be corrected,
• how it is secured,
• how policy changes will be communicated, and;
• how to address concerns over misuse of personal data.
B. Secure Sensitive Data
Businesses that collect sensitive data online (credit card, bank account and⁄or Social Security numbers, salary or other personal financial information, medical history or records, etc.) will ensure that it is transmitted via secure means. Businesses will make best efforts to comply with industry standards for the protection and proper disposal of all sensitive data, both online and offline.
For accredited charities, the BBB WGA Standards of Charity Accountability provide that a charity must protect the privacy of the donor by:
• providing in written appeals, at least annually, a means (e.g., such as a check off box) for both new and continuing donors to inform the charity if they do not want their name and address shared outside the organization, and

• providing a clear, prominent and easily accessible privacy policy on any of its websites that tells visitors (i) what information, if any, is being collected about them by the charity and how this information will be used, (ii) how to contact the charity to review personal information collected and request corrections, (iii) how to inform the charity (e.g., a check off box) that the visitor does not wish his⁄her personal information to be shared outside the organization, and (iv) what security measures the charity has in place to protect personal information.

VI. Outreach and Communications About the .bbb TLD Will Help to Achieve the Goals and Mission of Enhancing Marketplace Trust Online

Prior to launching the proposed .bbb TLD, CBBB anticipates conducting a multi-faceted outreach and communications campaign that will likely involve various media channels, which may include TV, radio, mobile, print, social media, direct mail, online advertising and marketing. These activities will endeavor to:
• Further communicate BBB’s commitment to online consumer safety and data privacy;
• Inform the market of BBB’s ownership, planned use and implementation of the proposed .bbb TLD;
• Clearly define the expected benefits to consumers, community members and other affiliated entities and Internet users at large.

BBB has an excellent working relationship with the media and assists national publications and networks on an almost daily basis with stories on fraud, scams and other deceptions. Interest by the national media on a secure, BBB-branded Internet domain will be high, and BBB’s media connections will help make the launch of the .bbb TLD a success. In addition, BBB reaches about 8 million consumers a month through its website, social media, and consumer education outreach. The new .bbb TLD would be incorporated into millions of consumer messages every month through these outlets.
Future outreach and communications campaigns will be carried out on an ongoing basis to reaffirm and clarify the above. CBBB believes outreach and communication will be critical to building trust and confidence in the legitimacy of the TLD.

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