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

gTLDFull Legal NameE-mail suffixDetail
.artDadotart, Inc.deviantart.comView
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)?

Dadotart believes the proposed operating rules that undertake to initially reserve key names including trademarks, as well as its proposed policies on eligibility, name selection and name use will provide clarity and predictability to name registration, thereby reducing social costs. In full operation the .ART gTLD will provide a trusted online environment for the arts community. There should be no need for other trademark and brand owners to defensively register in the gTLD. This verified eco-system also provides consumers with a single trusted source for arts information and communication. Dadotart also believes that the safeguards set forth in the Applicant Guidebook and the proposed business modeled outlined in Sections 18.1 and 18.1.2 and the policies planned and noted in 18.2.4 will minimize and potential negative social costs.


18.3.2 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
Dadotart believes that the proposed operation of the .ART gTLD as set forth in this application has no known negative consequences or cost implications for consumers. To the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to consumers. Dadotart believes that by following the core values as identified in Section 18.2 it will be able provide real value to the consumer and minimize any potential negative consequences⁄costs.

More particularly, the three phases of PAB creation, pre-launch, and launch and ongoing registration of the .ART gTLD are designed to minimize social costs and negative externalities. They protect potential registrants and potentially affected parties while maximizing the value of the name space to its registrants and users.

This approach is based on the premise that extensive screening efforts by the registry in the early stages will create a fair and orderly name space with lower compliance costs in the long term.

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?
In phases and areas where the first-come-first-served principle tends to yield perverse results, alternative modes will be used.

(1) In the PAB creation phase community research will identify names to be entered into reserved lists and the rules by which they will be allocated;
(2) In the pre-launch phase key portal names of use to the entire community will be registered and used for communication and outreach; and
(3) A launch phase led by protection for and registration by trademark holders and those eligible to hold names on reserved lists.


It is anticipated that the pre-launch portal development program identified in (2) above will involve key participants in the Art Community. The portal development program will allocate domain names based on an open and transparent project selection process. This process is highly economical in terms of social costs and yields substantial external benefits.

The portal development program is an essential part of .ART outreach. It begins before delegation of the TLD. In terms of workload and it mainly affects proposers who themselves are required to demonstrate support for their projects. Support will be required to come from the segment of the community concerned with the respective portion of the name space. Given the high value of the resulting on-line resources for the community and the public interest, and given the economic benefits that can be derived from their operation, the administrative effort is largely justified. To further protect affected parties, all adjudications in name space mandates have a safety-valve clause, allowing for later adjustments based on community input. The principle of the safety-valve is that affected parties can obtain adjustments to a component of a mandate if they propose (and commit to) an improved use of the underlying domain names from a public interest perspective.

The launch programs referred to in (3) above combine the so-called “sunrise” and “landrush” processes simultaneously in one phase. The use of domain applications instead of domain registrations means that the registry accepts multiple applications the same domain name. (By contrast, only a single registration can exist for a given domain.) In this way, contention resolution can take place without time pressure in a transparent, fair and orderly manner.


At the time of ongoing registration the first-come rule will be followed. Registrations will be checked in a post-validation process and subject to an enforcement program based on statistically targeted random investigation and complaint follow-up. This program minimizes both costs to registrants and third parties. In particular, it strongly diminishes the attractiveness of rights violations, abuse or malignant behavior. Having been preceded by a controlled launch phase, the validation and enforcement workload faces no resource bottleneck and thus achieves a high degree of credibility, further dissuading abuse from the start. This mode of operation has a strong positive side effect in the interest of trademark holders.


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?
As described below, during pre-launch and launch phase, the first-come-first-served principle is NOT applied. Adjudication by auction is one of the solutions available to the parties in the context of the contention resolution process. In the phase of ongoing registrations the first-come⁄first-served basis of name allocation will be followed, unless the name is one that is on a reserved list, in which case the allocation rules applicable to that list will be followed.

In phases and areas where the first-come-first-served principle tends to yield perverse results, alternative modes will be used.

(1) In the PAB creation phase community research will identify names to be entered into reserved lists and the rules by which they will be allocated;
(2) In the pre-launch phase key portal names of use to the entire community will be registered and used for communication and outreach; and
A launch phase led by protection for and registration by trademark holders and those eligible to hold names on reserved lists.

It is anticipated that the pre-launch portal development program identified in (2) above will involve builders and users in the Art community. The portal development program will allocate domain names based on an open and transparent project selection process. This process is highly economical in terms of social costs and yields substantial external benefits.

The portal development program is an essential part of .Art outreach. It begins before delegation of the TLD. In terms of workload, it mainly affects proposers who themselves are required to demonstrate support for their projects. Support will be required to come from the segment of the community concerned with the respective portion of the name space. Given the high value of the resulting on-line resources for the community and the public interest, and given the economic benefits that can be derived from their operation, the administrative effort is largely justified. To further protect affected parties, all adjudications in name space mandates have a safety-valve clause, allowing for later adjustments based on community input. The principle of the safety-valve is that affected parties can obtain adjustments to a component of a mandate if they propose (and commit to) an improved use of the underlying domain names from a public interest perspective.

The launch programs referred to in (3) above combine the so-called “sunrise” and “landrush” processes simultaneously in one phase. The use of domain applications instead of domain registrations means that the registry accepts multiple applications the same domain name. (By contrast, only a single registration can exist for a given domain.) In this way, contention resolution can take place without time pressure in a transparent, fair and orderly manner.

At the time of ongoing registration the first-com rule will be followed. Registrations will be checked in a post-validation process and subject to an enforcement program based on statistically targeted random investigation and complaint follow-up. This program minimizes both costs to registrants and third parties. In particular, it strongly diminishes the attractiveness of rights violations, abuse or malignant behaviour. Having been preceded by a controlled launch phase, the validation and enforcement workload faces no resource bottleneck and thus achieves a high degree of credibility, further dissuading abuse from the start. This mode of operation has a strong positive side effect in the interest of trademark holders.

18.3.4 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
The focus of the .ART gTLD is a competitive cost to registrants and stakeholders that takes into account the limited community nature of the gTLD. This takes into account all burdens, including the effort needed to register or the potential alternative cost to obtain a name on the secondary market. The direct per-unit cost is merely a component of the bottom-line cost.

The cost is greatly reduced by avoiding contention between legitimate community-based applicants and speculators. Community-specific promotion code programs will be used from time to time to offer registrations at low cost. This is a way to avoid perverse effects of low prices, such as speculation with ultimately high costs to registrants, large-scale confusion and waste of the name space, or cybersquatting.

The portal development program will have special terms in order ensure that key portions of name space are used in the public interest.

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.

The .ART TLD will not be based on or otherwise involve contractual clauses regarding price escalation between the .ART Registry and its registrars.

The .ART business plan is designed to avoid any future necessity to increase registry price in real terms. The fundamental principle is prudence: starting from conservative price levels that allow self-sustainability at the registration levels projected and gradually lowering prices as registration volumes increase beyond the minimum necessary for self-sustained operation. This method ensures sufficient financial reserves, favors optimal allocation of domain names, helps prevent misuse and supports an orderly registration process.

gTLDFull Legal NameE-mail suffixDetail
.doctorDotMedico TLD Inc.radixregistry.comView
.Doctor considers both its Registrants and the end-users that access .Doctor websites as its users. Our goal is to create a clean, trusted and highly reliable namespace and provide an outstanding user experience to both Registrants and end-users of .Doctor. To that extent it is our goal to –
* Reduce ⁄ minimize any incremental costs ⁄ negative consequences imposed upon our users
* Increase ⁄ maximize the value added to our Registrants and end-users
* Ensure that the net effect of .Doctor on its users is that of positive value creation

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

1 MINIMIZING COSTS

1.1 REGISTRANTS

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

1.1.1 SUNRISE, TMCH, RPMs

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

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

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

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

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

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

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

1.1.2 MULTIPLE APPLICATIONS FOR A DOMAIN

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

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

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

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

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

1.1.3 COST BENEFITS FOR REGISTRANTS

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

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

1.1.4 PRICE ESCALATIONS

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

1.2 END USERS

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

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

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

2 COST BENEFIT ANALYSIS

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

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

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

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

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

* In general increased competition always results in pricing benefits for Registrants. .Doctor will provide additional options to new Registrants resulting in overall benefits to Registrants

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

This completes our response to Q18(c).