18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
|gTLD||Full Legal Name||E-mail suffix||Detail|
|.llc||Top Level Design, LLC||gmail.com||View|
i.) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
Our .llc TLD is catered to a special market within American commerce. We hope to quickly achieve a positive reputation within this market by providing a safe and secure platform that allows these companies to create better and more relevant domains than are currently available through other TLDs. The .llc TLD will allow companies to clearly and specifically identify through their officially registered LLC standing; as entrepreneurs move forward with creating their new Limited Liability Companies, they will no longer be constrained to choose a company name that has an attractive .com available. This is a problem that many entrepreneurs have noted, not only finding a marketable and appropriate name for their company, but also finding a marketable name that also has the related domain available. Creating new gTLDs, especially .llc, will allow these individuals to make decisions based on creativity and marketing savvy, and not be constrained by unavailable and unattractive domain options. Additionally, consumers will be able to confirm that the company running the website they are viewing is a registered LLC, which will create a certain level of trust as to the legitimacy of the company.
ii.) What do you anticipate your proposed gTLD will add to the current space, in terms of areas of competition, differentiation, or innovation?
A .llc TLD brings the innovative potential of ICANN’s New gTLD Program to a specific and large contingent of American businesses. Implementing a .llc TLD will have the positive effect of further focusing current, more general commerce related TLDs. That is, .com and .biz can move away from being the only commerce specific TLDs and instead become the most general commerce related TLDs, while .llc and other similarly specific new gTLDs will become the innovative niche commerce options. So while we will compete with current TLDs such as .biz and .com, we will also improve the way in which they are organized and differentiate how a specific type of commercial entity is able to utilize the Internet.This will certainly facilitate more TLD competition, and allow the current offerings to become significantly more differentiated.
Top Level Design, LLC believes the .llc extension is largely self-explanatory and its content readily apparent to both potential registrants and end-consumers. We hope that the Internet experience of both types of users will therefore be enhanced and simplified by the implementation of .llc into the root zone. Registrants will have the opportunity to clearly identify themselves as a LLC, and Internet users browsing and using sites with a .llc extension will know that the website they are visiting is indeed a verified and authentic LLC.
We will create a safe and secure TLD, and believe that this is the most important way to ensure that our users have positive experiences when using .llc.
iv.) Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
Registration of a .llc TLD will be restricted to verifiable Limited Liability Companies. This designation is common across United States jurisdictions, and it is generally the Secretary of State offices for the state in which the company is registered maintains public or query-based databases of these entities. Our registration policies will be implemented in conjunction with ICANN-accredited registrars that agree to work with us and our specific registration terms and processes. Registration of a .llc domain will in effect work like an application process, where a given entity pays for the available domain they are interested in obtaining and discloses all necessary information to verify their LLC status in a given U.S. jurisdiction. This will generally include the state issuing LLC status, the date of LLC issuing, the registered name of the LLC, the unique LLC registration number, and the individual⁄applicant associated with both the LLC registration and the .llc domain registration. We will then verify this information with the appropriate Secretary of State’s office, and then either delegate the TLD to the registrant following positive verification, or inform them via writing that their status was not verifiable and that we are unable to immediately delegate the domain they requested. This latter option will be available to an appeals process where they are allowed to submit further or amended information to allow for successful verification and delegation. It is unclear at this point whether or not a nominal fee will be necessary to facilitate this appeals process.
Ideally, through working with the National Association of Secretaries of State and all of its members, we would be able to have limited access to all necessary databases and archives related to national LLC filings. This would allow us to verify continued LLC standing on a more frequent basis, and therefore create a .llc TLD that most accurately reflects actual LLC registration. At its optimum, the system we are proposing would check the relevant databases against our own registrations on a daily basis. However, without some sort of automated access to these LLC filings, we would rely on a manual method that would be more labor and cost intensive. If we depend on a manual method, we can still guarantee that LLC filing status would be verified at registration, renewal, and on an annual or even bi-annual basis. This manual process is defined as a Top Level Design LLC employee using the public facing query-based databases that are hosted on most Secretary of State’s web pages to verify each .llc registrant’s actual LLC registration. It seems that for certain jurisdictions it may be even more time intensive should a public facing database not be available online, and consequently confirmation has to be done via writing or telephone. Still, LLC status is consistently used throughout the United States of America, and public access to LLC certifications is required by national law; this requirement has been outlined in the Uniform Limited Liability Company Act (ULLCA) of 1996 (revised in 2006). Section 208 of Article 2 of this legislation requires that each Secretary of State office provide a certificate of existence to any person that requests corroborating information on any certificate of LLC organization that it has issued. Information that the Secretary of State’s office is required to provide includes:
“(1) the company’s name;
(2) that the company was duly formed under the laws of this state and the date of formation;
(3) whether all fees, taxes, and penalties due under this [act] or other law to the [Secretary of State] have been paid;
(4) whether the company’s most recent annual report required by Section 209 has been filed by the [Secretary of State];
(5) whether the [Secretary of State] has administratively dissolved the company;
(6) whether the company has delivered to the [Secretary of State] for filing a statement of dissolution;
(7) that a statement of termination has not been filed by the [Secretary of State]; and
(8) other facts of record in the [office of the Secretary of State] which are specified by the person requesting the certificate.”
Thus, our ability to verify a given LLC in any U.S. state is not a matter of question, and we unequivocally affirm that we intend to verify official LLC standing with the appropriate Secretary of State at the time or registration, renewal, and at least on an annual basis. What remains to be seen is if we can come to an agreement with the National Association of Secretaries of States to create a system that allows us to check our registrations against official LLC databases in a more efficient and potentially constantly verifiable manner.
Note that foreign companies may also be incorporated as LLCs in a given state, and this too would be subject to verification made possible through the Uniform Limited Liability Company Act. In these instances the foreign company is required to do business following all laws particular to that U.S. jurisdiction and they are issued a certificate of authority which is verifiable by the Secretary of State of that jurisdiction.
Still, we recognize that the abbreviation “LLC” is used in several other countries, and this is not necessarily a signifier that the entity has received a LLC certificate of authority from a given U.S. state in which it has been authorized to do business as an LLC. This case applies specifically to Egypt and The Philippines. We plan to work with the GAC representatives of these, and any other countries using “LLC” as a legal designation, to ensure that our registration and verification policies function appropriately with their national laws. We expect that registration of .llc will initially be available to only registrants who are verifiable LLC’s as per U.S. law (Uniform Limited Liability Company Act,1996, amended 2006) given the ease and unfiromity with which these registrations can be verified with the appropriate issuing authority. However, we hope to work with the GAC representatives of any country legally registering “LLC” designated entities to eventually make the TLD available for registration by these entities where appropriate. Of course, we are certainly amenable to working with the U.S. GAC representative to ensure any national concerns are met.
One further innovation we are considering is creating a platform whereby an interested party that does not currently have a given LLC can also register the LLC and the .llc domain associated with that company via an additional service. That is, this platform will act like a search engine that processes the availability of a given LLC name, .llc domain, and the necessary information to register both at the same time. We note this idea only as a further innovation made possible by the .llc TLD and not a firm commitment to immediately develop and implement the service with the launch of our TLD.
The .llc TLD will be priced higher than currently available open, gTLDs, and instead be priced on the level of more restricted TLDs. This reflects the extra work and expense involved in verifying each registrant and also the premium nature of a domain as specific as a .llc domain.
Given the labor intensive verification policies that will be in place fo .llc, the domains will be offered at a $50 wholesale in our Most Likely projections; this has been lowered to $40 in the case of anemic registrations in our Worst Case Scenario. This is in-line with other TLDs that utilize similarly restricted registration practices.
v.) 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.
As per the current requirements in Section 4 of the Registry Agreement, we will implement all necessary thick WHOIS services. We recognize how imperative it is for each registry and ICANN-accredited registrar to be in full compliance with ICANN’s current WHOIS standards, and we plan to update our policy in accordance with any future measures taken by the ICANN Board in regard to the continuous work by the GNSO’s WHOIS Task Force and other recommendations from the SOs. We have no plans to implement any privacy or confidential measures other than fully implementing any and all such measures required by ICANN.
We would not be publishing or retaining the information needed to verify LLC standing, it is to be accessed as the justification for registration, both on an initial and then any and all subsequent verifications, and not stored.
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|gTLD||Full Legal Name||E-mail suffix||z||Detail|