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18(a) Describe the mission/purpose of your proposed gTLD

gTLDFull Legal NameE-mail suffixDetail
.pornICM Registry PN LLCicmregistry.comView
Applicant’s parent company, ICM Registry LLC (“ICM”), brought into existence the Internet’s only existing adult-targeted top level domain (“.XXX”). .XXX is a sponsored top level domain (“sTLD”), whose sponsoring organization is the International Foundation for Online Responsibility (“IFFOR”). ICM was entrusted to certify that each of its registrants adopt responsible business practices designed to combat child abuse images, facilitate user choice and parental control regarding access to online adult entertainment, as well as protect privacy, security and consumer rights.

Applicant, a wholly owned subsidiary of ICM, will leverage ICM’s experience and consumer trust by providing the proposed gTLD at a more competitively priced offering.
Applicant will utilize the best practices, expertise, relationships, resources, and goodwill the parent company has generated throughout the decade it has been focusing on the sensitivities, opportunities, and responsibilities inherent in operating an adult-targeted TLD. In doing so, Applicant strives to empower entities around the globe, spur innovation, facilitate trade and commerce, and enable the free and unfettered flow of information while ensuring the protection of minors, respecting the free speech rights of the adult industry, increasing brand protection for non-adult brands and facilitating user choice for Internet users who are not interested in accessing adult content on the new gTLD.

In light of .XXX’s unparalleled exposure through its multi million dollar marketing campaigns and significant first mover advantage as the adult domain extension of choice for the global adult entertainment industry (“AEI”), Applicant believes that the .XXX TLD is and will likely continue to be universally recognized as the pre-eminent TLD for the AEI. Applicant believes that .XXX will maintain its status as the first choice adult-targeted TLD because the protections offered on each .XXX website, such as daily malware scanning and automated family safety tagging, as well as the other benefits that accrue to .XXX registrants and consumers as a result of IFFOR’s polices, are impossible to replicate in a lower cost TLD.

That said, throughout ICM’s successful pursuit and launch of .XXX, Applicant learned that there are members of the AEI who chose not to, or were unable to, participate in .XXX, whether on the basis of price, inability to satisfy the sTLD membership criteria, or a general unwillingness to adopt or implement the policies promulgated by IFFOR. ICM learned that these constituencies within the AEI maintain a philosophical skepticism about, or an outright rejection of, granting a third party organization, i.e. IFFOR, the authority to create TLD policies that they perceive as potentially interfering with their own business policies and practices.

Applicant notes that while some constituents within the AEI have expressed the above -mentioned concerns regarding IFFOR’s policy making authority with respect to .XXX, Applicant itself believes that the multi-stakeholder approach embodied in the IFFOR policy making process, which includes a formal and transparent Policy Development Process (“PDP”) resulting from community-based participation, is ultimately a safer and more trustworthy process for policy making than the proposed lack of process available to all registry operators under the new gTLD Registry Services Agreement. Under the new gTLD Registry Services Agreement, registry operators are authorized to establish policies and TLD registration criteria without any of the oversight required under the Sponsoring Organization model. Applicant believes there is a potential risk under the new gTLD Registry Services Agreement that registry operators, especially unscrupulous registry operators who are not held accountable to a PDP-like process, may have more flexibility and less restraint required when making and imposing policies that impact their TLDs. These potentially unscrupulous registry operators, with unfettered limitations, may elect to impose new policies over their registrants that impact not only registrants, but also end-users and Internet stakeholders-at-large, without the benefit of the commentary, representation, or transparency that inherently exists in a sponsored TLD model, like .XXX. Applicant is, however, not currently aware of any existing AEI commentary regarding registry operators unrestricted policy making freedom available under the new gTLD program (as contrasted with the concerns Applicant is aware of by some constituents regarding the IFFOR policy making process).

In light of these concerns, certain AEI constituents have elected not to register .XXX names and thus Applicant believes that this new, competitively priced gTLD will provide these AEI constituents an opportunity to obtain adult-related TLD names without the IFFOR-related opportunities for policy making authority that they have expressed concerns regarding. Essentially, Applicant has listened to the concerns expressed to ICM by these constituencies and wishes to offer a new, alternative, adult targeted TLD that operates at a lower price point and does not have the same qualifying and operational requirements as those that exist in a sTLD like .XXX. Applicant’s mission and purpose is to expand the pool of adult-targeted TLDs and to provide the AEI an adult-targeted gTLD that clearly identifies their products and services to end-users, without certain perceived barriers to entry expressed by certain constituents within the global adult entertainment industry.
gTLDFull Legal NameE-mail suffixDetail
.gallerySugar House, LLCdonuts.coView
Q18A CHAR: 7985

ABOUT DONUTS
Donuts Inc. is the parent applicant for this and multiple other TLDs. The company intends to increase competition and consumer choice at the top level. It will operate these carefully selected TLDs safely and securely in a shared resources business model. To achieve its objectives, Donuts has recruited seasoned executive management with proven track records of excellence in the industry. In addition to this business and operational experience, the Donuts team also has contributed broadly to industry policymaking and regulation, successfully launched TLDs, built industry-leading companies from the ground up, and brought innovation, value and choice to the domain name marketplace.

DONUTS’ PLACE WITHIN ICANN’S MISSION
ICANN and the new TLD program share the following purposes:
1. to make sure that the Internet remains as safe, stable and secure as possible, while
2. helping to ensure there is a vibrant competitive marketplace to efficiently bring the benefits of the namespace to registrants and users alike.

ICANN harnesses the power of private enterprise to bring forth these public benefits. While pursuing its interests, Donuts helps ICANN accomplish its objectives by:

1. Significantly widening competition and choice in Internet identities with hundreds of new top-level domain choices;
2. Providing innovative, robust, and easy-to-use new services, names and tools for users, registrants, registrars, and registries while at the same time safeguarding the rights of others;
3. Designing, launching, and securely operating carefully selected TLDs in multiple languages and character sets; and
4. Providing a financially robust corporate umbrella under which its new TLDs will be protected and can thrive.

ABOUT DONUTS’ RESOURCES
Donuts’ financial resources are extensive. The company has raised more than US$100 million from a number of capital sources including multiple multi-billion dollar venture capital and private equity funds, a top-tier bank, and other well-capitalized investors. Should circumstances warrant, Donuts is prepared to raise additional funding from current or new investors. Donuts also has in place pre-funded, Continued Operations Instruments to protect future registrants. These resource commitments mean Donuts has the capability and intent to launch, expand and operate its TLDs in a secure manner, and to properly protect Internet users and rights-holders from potential abuse.

Donuts firmly believes a capable and skilled organization will operate multiple TLDs and benefit Internet users by:

1. Providing the operational and financial stability necessary for TLDs of all sizes, but particularly for those with smaller volume (which are more likely to succeed within a shared resources and shared services model);
2. Competing more powerfully against incumbent gTLDs; and
3. More thoroughly and uniformly executing consumer and rights holder protections.

THIS TLD
This TLD is attractive and useful to end-users as it better facilitates search, self-expression, information sharing and the provision of legitimate goods and services. Along with the other TLDs in the Donuts family, this TLD will provide Internet users with opportunities for online identities and expression that do not currently exist. In doing so, the TLD will introduce significant consumer choice and competition to the Internet namespace – the very purpose of ICANN’s new TLD program.

This TLD is a generic term and its second level names will be attractive to a variety of Internet users. Making this TLD available to a broad audience of registrants is consistent with the competition goals of the New TLD expansion program, and consistent with ICANN’s objective of maximizing Internet participation. Donuts believes in an open Internet and, accordingly, we will encourage inclusiveness in the registration policies for this TLD. In order to avoid harm to legitimate registrants, Donuts will not artificially deny access, on the basis of identity alone (without legal cause), to a TLD that represents a generic form of activity and expression.

DONUTS’ APPROACH TO PROTECTIONS
No entity, or group of entities, has exclusive rights to own or register second level names in this TLD. There are superior ways to minimize the potential abuse of second level names, and in this application Donuts will describe and commit to an extensive array of protections against abuse, including protections against the abuse of trademark rights.

We recognize some applicants seek to address harms by constraining access to the registration of second level names. However, we believe attempts to limit abuse by limiting registrant eligibility is unnecessarily restrictive and harms users by denying access to many legitimate registrants. Restrictions on second level domain eligibility would prevent law-abiding individuals and organizations from participating in a space to which they are legitimately connected, and would inhibit the sort of positive innovation we intend to see in this TLD. As detailed throughout this application, we have struck the correct balance between consumer and business safety, and open access to second level names.

By applying our array of protection mechanisms, Donuts will make this TLD a place for Internet users that is far safer than existing TLDs. Donuts will strive to operate this TLD with fewer incidences of fraud and abuse than occur in incumbent TLDs. In addition, Donuts commits to work toward a downward trend in such incidents.

OUR PROTECTIONS
Donuts has consulted with and evaluated the ideas of international law enforcement, consumer privacy advocacy organizations, intellectual property interests and other Internet industry groups to create a set of protections that far exceed those in existing TLDs, and bring to the Internet namespace nearly two dozen new rights and protection mechanisms to raise user safety and protection to a new level.

These include eight, innovative and forceful mechanisms and resources that far exceed the already powerful protections in the applicant guidebook. These are:

1. Periodic audit of WhoIs data for accuracy;
2. Remediation of inaccurate Whois data, including takedown, if warranted;
3. A new Domain Protected Marks List (DPML) product for trademark protection;
4. A new Claims Plus product for trademark protection;
5. Terms of use that prohibit illegal or abusive activity;
6. Limitations on domain proxy and privacy service;
7. Published policies and procedures that define abusive activity; and
8. Proper resourcing for all of the functions above.

They also include fourteen new measures that were developed specifically by ICANN for the new TLD process. These are:

1. Controls to ensure proper access to domain management functions;
2. 24⁄7⁄365 abuse point of contact at registry;
3. Procedures for handling complaints of illegal or abusive activity, including remediation and takedown processes;
4. Thick WhoIs;
5. Use of the Trademark Clearinghouse;
6. A Sunrise process;
7. A Trademark Claims process;
8. Adherence to the Uniform Rapid Suspension system;
9. Adherence to the Uniform Domain Name Dispute Resolution Policy;
10. Adherence to the Post Delegation Dispute Resolution Policy;
11. Detailed security policies and procedures;
12. Strong security controls for access, threat analysis and audit;
13. Implementation DNSSEC; and
14. Measures for the prevention of orphan glue records.

DONUTS’ INTENTION FOR THIS TLD
As a senior government authority has recently said, “a successful applicant is entrusted with operating a critical piece of global Internet infrastructure.” Donuts’ plan and intent is for this TLD to serve the international community by bringing new users online through opportunities for economic growth, increased productivity, the exchange of ideas and information and greater self-expression.