gTLD	Full Legal Name	E-mail suffix	Detail
.dealer	Dealer Dot Com, Inc.	dealer.com	View

Dealer.comʹs proposed operating rules to limit registration to Dealer.com and its partners and affiliates will provide a trusted online environment for businesses that use Dealer.com’s content, solutions, and services. Therefore, Dealer.com will minimize social costs by eliminating the need for third-party brand owners to defensively register their trademark in the .DEALER gTLD, unlike other open registries. In addition, the .DEALER gTLD will provide businesses with a trusted source for Dealer.com’s content, solutions and services without the risk of fraud, misdirection, infringement, phishing, malware, and other scams that consumers are plagued with in .COM and other open gTLDs.

(i.)
Dealer.com believes that the proposed operation of the .DEALER gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to consumer benefits.

(ii.)
Dealer.com does not envision multiple applicants for the same domain name, as domain names will initially only be registered to Dealer.com and its partners and affiliates.

(iii.)
Dealer.com does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because it will not be marketing or creating commercial initiatives for the sale of .DEALER domain names. Its intention is to use the gTLD as a recognizable, trusted, virtual platform offering Dealer.comʹs and its partners’ and affiliates’ content, solutions, and services to customers and Internet users. Any potential registrant fees imposed upon licensees and other third parties will be made in the future if this class of registrants is permitted to register domain names in the .DEALER gTLD.

Dealer.com is committed to providing the domain name registration periods set forth in the Registry Agreement. As a .BRAND gTLD, the use of any .DEALER domain names is conditioned upon a partner or affiliate relationship with Dealer.com. Therefore, there is a natural incentive for Dealer.com to provide domain names with minimal price escalations and the maximum flexibility in domain registration terms possible under ICANN rules. Understanding the ownership of .DEALER domains as noted previously, contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations is not relevant or appropriate. That said, the .DEALER domain agreements will be in accordance with all ICANN requirements.

Dealer.com acknowledges that the current template Registry Agreement requires that the Registry Operator “shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar.” However, Dealer.com and its qualified subsidiaries and affiliates, as the sole registrants within the .DEALER gTLD, will initially only be registering domain names on an annual basis.

If Dealer.com moves forward with a validation process whereby parties outside the proposed network of Dealer.com and its partners and affiliates, without such a stringent commercial agreement, are permitted to register and use .DEALER domain names, Dealer.com is fully committed to providing these domain name registrants with annual registrations that include pricing predictability and notice in connection with the registration of domain names. However, in connection with potential premium generic or geographic domain names, there may be additional requirements that would legally bind these registrants in connection with the registration and use of these domain names. These terms will be known by this class of domain name registrants prior to the creation of any legal obligation between the parties.

gTLD	Full Legal Name	E-mail suffix	Detail
.cbre	CBRE, Inc.	cbre.com	View

The proposed operating rules to limit registration to CBRE Group and its qualified subsidiaries, affiliates, and business units will provide a trusted online environment for CBREʹs information and services. Since there will be no market in .CBRE domain names, CBRE will minimize social costs by eliminating the need for third-party brand owners to defensively register their trademark in the .CBRE gTLD, unlike other open registries. In addition, the .CBRE gTLD will provide the commercial real estate market with a trusted source for CBREʹs information and services with a reduced or eliminated risk of fraud, misdirection, infringement, phishing, malware, and other scams that consumers are plagued with in .COM and other open gTLDs.

18.3.1 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

CBRE believes that the proposed operation of the .CBRE gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to consumer benefits as described herein.

18.3.2 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first serve basis?

Since there will be no market in .CBRE second level domain name registrations, CBRE does not envision multiple applicants for the same domain name, as domain names will initially only be registered to CBRE Group and its qualified subsidiaries, affiliates, and business units.

18.3.3 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

Since there will be no market in .CBRE second level domain name registrations, CBRE does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because it will not be marketing or creating commercial initiatives for the sale of .CBRE domain names. Its intention is to use the gTLD as a recognizable, trusted, virtual platform offering CBRE Group and its qualified subsidiariesʹ, affiliatesʹ and business unitsʹ content, information and services to clients, potential clients and Internet users, all consistent with the Purpose. Any potential registrant fees imposed upon licensees and strategic partners having the Required License will be made in the future in the unlikely event that this class of registrants is permitted to register domain names in the .CBRE gTLD.

18.3.4 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.

CBRE is committed to providing the domain name registration periods set forth in the Registry Agreement. As a .BRAND gTLD, the use of any .CBRE domain names is conditioned upon a subsidiary or affiliate relationship with CBRE Group. Therefore, there is a natural incentive for CBRE to provide domain names with minimal price escalations and the maximum flexibility in domain registration terms possible under ICANN rules. Understanding the ownership of .CBRE domains as noted previously, contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations are not relevant or appropriate. That said, the .CBRE domain agreements will be in accordance with all ICANN requirements.