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

gTLDFull Legal NameE-mail suffixDetail
.bankfTLD Registry Services LLCfsround.orgView
fTLD Registry Services, LLC (FRS) is submitting this application on behalf of the global banking community to ensure that the .bank gTLD will serve as a trusted, hierarchical, and intuitive namespace for this community, the businesses that are either supported by or represent the community and the consumers it serves. All registrants within .bank will be vetted prior to registration to ensure their identity and their commitment to industry best standards developed by FRS in conjunction with the financial services community. In addition, the registry will employ a network of both active and passive safeguards in the operation of the registry to make certain that registrants continue to abide by the terms and conditions set forth in the registration agreement.

The Internet represents a critical component of the global trade and commerce engine and the .bank gTLD is expected to address some of the online security challenges currently faced by the banking community. Whether spoofing, spamming, phishing or pharming, research shows that banks and consumers suffer tremendously from the growing threat of criminal and fraudulent activities conducted over the Internet. While FRS is keenly aware that there is no silver
bullet to eradicate these threats, the security and other protocols that will be supplanted within .bank are expected to curb some of the current online abuses. FRS will continue to engage in outreach and education within the global banking community and help raise awareness of various threats and the potential resources and security available to combat them.

A sampling of online threats faced by consumers and the banking community includes:
- The RSA Online Fraud Report of January 2012 found that phishing is on the rise, reaching 279,580 attacks in 2011, a 37% increase from 2010. Targeted brands including potential .bank registrants representing 31 different geographies experienced the most attacks throughout the U.S., the United Kingdom, Australia, Canada, India, and Brazil. RSA is a premier provider of security, risk and compliance management solutions for businesses.
- According to the Anti-Phishing Working Group (APWG), in the first half of 2011 almost half of all phishing emails purported to come from a financial institution. Phishing threatens customer confidence and trust in the online banking channel. APWG is a non-profit global pan-industrial and law enforcement association focused on eliminating fraud, crime and identity theft that results from phishing, pharming, malware and email spoofing of all types.

Due to the strict vetting process that will occur before a .bank domain is awarded, the frequency of phishing using the .bank gTLD will be greatly reduced. FRS will work with the banking industry to create a strategy that significantly reduces the risk of bank-related phishing and other malicious activities perpetrated on the Internet.

The .bank gTLD will provide the industry with an innovative space to explore cutting edge business opportunities and mechanisms to better serve and protect Internet users. With increased customer demand for faster and more convenient transactions and the need for a secure and innovative space, securing .bank presents the banking industry with an unparalleled opportunity. Over time, one of the goals of this gTLD is to become the consumer’s choice for information about the banking industry.

As awareness and use of .bank increases over time, Internet users will come to learn, understand and trust that websites ending in .bank are operated by legitimate members of the banking community. FRS’ implementation of stringent registration restrictions, enhanced security standards created by the financial services industry, content⁄use requirements and rigid enforcement will contribute to the security, stability, and resiliency of the bank gTLD and ultimately result in increased consumer trust and confidence in the gTLD.

Why FRS?
In 2008, the American Bankers Association (ABA) and The Financial Services Roundtable’s (Roundtable) executives and members allocated resources to work in conjunction with banker committees to examine the potential impact the Internet Corporation for Assigned Names and Numbers’ (ICANN) new gTLD program could have on the financial services industry and to make recommendations regarding next steps. Marked concern arose regarding the expansion program, especially in light of the resources and expenditures currently dedicated to stem existing online abuses.

During the last four years, the ABA and Roundtable united to play an active role in ICANN’s development of its new gTLD program. Both organizations engaged with ICANN to voice community concerns about the program, and were successful in raising awareness about the need to protect brands and intellectual property. In addition, the ABA and Roundtable were successful with their request to ICANN for a modification to the Security Policy question in the
Applicant Guidebook and it now includes that gTLDs with unique trust implications, such as those that are financial services-oriented, are expected to deploy appropriate levels of security. However, absent assurances that .bank and other financial gTLDs would be protected, the Executive Committee and Board of each respective organization voted and authorized staff to take all actions necessary to secure financial gTLDs including .bank.  

At the behest and approval of both the ABA and the Roundtable members and Boards, FRS was formed in 2011 for the explicit purpose of applying for and operating financial services-related gTLDs. In addition, FRS seeks to protect the brand space, improve the protection available for a more secure Internet ecosystem, collaborate on delivering more innovative and secure products and services, and zealously advocate for the interests of the global banking
community with ICANN.

The Operating Managers of FRS:
Founded in 1875, the American Bankers Association represents banks of all sizes and charters and is the voice for the U.S. banking industry’s $13 trillion banking industry and its 2 million employees. ABA marshals the talent, energy and perspectives of its members to bring about positive change for the banking industry. In conjunction with the financial services community, the ABA has developed and continues to own a number of innovative systems that support the financial services industry. The ABA Routing Number (“RTN”) system was developed in 1910 and serves to identify the specific financial institution responsible for the payment of a negotiable instrument. In 1964, the ABA organized the Committee on Uniform Security Identification Procedures (CUSIP), for the purpose of developing an identifier for financial instruments. ABA is also an active member of the International Banking Federation, formed in March 2004 to represent the combined views of a group of national banking associations. Collectively, the countries represented by the Federation reach more than 18,000 banks with 275,000 branches.

The first of the Roundtableʹs predecessor organizations, the Association of Reserve City Bankers, was formed in 1912. The Bank Holding Company Act of 1956 led to the 1958 formation of another independent organization, the Association of Registered Bank Holding Companies. The two organizations merged in July 1993, and became The Bankers Roundtable in October 1993. In early 2000, the first members from the securities, investment, and banking sectors
joined their banking brethren as founding members of the Roundtable. Today, the Roundtable represents 100 of the largest integrated financial services companies providing banking, investment products and services to the American consumer.

FRS has engaged the Australian Banker’s Association, British Bankers’ Association, European Banking Federation, and the International Banking Federation in conversations regarding use of the .bank gTLD and they endorse the initative.
gTLDFull Legal NameE-mail suffixDetail
.internationalWild Way, 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.