gTLD	Full Legal Name	E-mail suffix	Detail
.GAP	The Gap, Inc.	fairwindspartners.com	View

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Gap Inc. believes that a proposed .GAP gTLD has the potential to offer the following benefits to Internet users and consumers:

-Establish a trusted source of information and an online marketplace for the millions of consumers who purchase goods and services from Gap, for investors and third parties seeking information, and for the general Internet user population;

-Provide Gap Inc., its partners, and affiliates with short and memorable Internet addresses; provide increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;

-Minimize the cost and need for defensive registrations because domain names will only be allocated by Gap Inc. within the .GAP gTLD to Gap Inc. and verified partners⁄affiliates; and

-Develop a potential platform for the secure access to, and purchase and distribution of Gap brand products and information to consumers, in order to minimize the potential for counterfeit or infringing goods and services.

Also, through the adoption of new gTLDs by the wider Internet user community, consumers may benefit from a lower incidence of phishing and malware often associated with mistypes of domain names in the .COM space that are owned by cybersquatters, since consumers will be navigating to domain names in the .GAP gTLD.

Currently, Gap Inc. operates a number of company websites using a combination of second-level and top-level domain names. A representative sampling of Gap Inc. websites that incorporate geographical identifiers into the domain name include:

-GapNewYork.com
-GapNYC.com
-GapSanFrancisco.com
-GapBoston.com
-GapCanada.com
-GapStore.ca
-Gap.cn
-GapStore.eu
-Gap.eu

Gap Inc. believes that a .GAP gTLD can provide an online single-source identifying function for its current and future customers around the world, instead of the mix-and-match approach currently required for expansion into different global markets.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .GAP gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to deliver Gap brand retail content, information about business and focus, and other goods and services. As Gap Inc. continues to expand, the company will continue to pursue and develop opportunities to market and distribute its online content and products to consumers, in the U.S. and internationally, and on various platforms, including the Internet and mobile devices. Given that customers increasingly demand access to Gap Inc. brands through a variety of channels, which include domain names and the address bar, Gap Inc. believes that a .GAP gTLD has the potential to provide an innovative, virtual avenue to Gap brand products that will deepen and broaden its relationship with consumers.

Most importantly, Gap Inc. will be able to provide access to its products and online content in a namespace void of piracy, cybersquatting and other malicious activities. Providing consumers with a trusted experience is paramount to Gap Inc., and a .GAP gTLD will be used to further that goal.

While retail companies such as Gap Inc. must constantly fight to protect their valuable intellectual property from piracy on the Internet, a .GAP gTLD potentially offers consumers a safe and intuitive means of accessing authorized content from Gap Inc. and its affiliates.

Gap Inc. is supportive of existing anti-cybersquatting legislation and consumer protection measures, including the U.S. Anti-Cybersquatting Consumer Protection Act (ACPA) and others. As Gap Inc. invests in expanding the domain name space through the establishment of a .GAP gTLD, it will also actively prevent cybersquatting, fraud, phishing, and other malicious activities within the .GAP gTLD. Maintaining the highest standards within the .GAP gTLD will give Gap Inc. the opportunity to take a proactive approach to protecting intellectual property rights and fostering a safer online experience for all Internet users.

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

As a branded gTLD, the primary driving factors of a .GAP gTLD are differentiation and innovation. The success of the gTLD will be measured not by the number of domain names registered, but rather by the level of consumer recognition and trust that is placed in the .GAP gTLD. Using this benchmark, Gap Inc. will strive to build consumer recognition and trust through usage of the .GAP gTLD that rise to the level found in the .EDU and .GOV gTLDs.

As noted above, Gap Inc. is a leading global retail company that leverages numerous distribution channels and emerging technologies to deliver its online content and consumer goods to customers internationally. A .GAP gTLD has the potential to serve as a cornerstone of this online strategy.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

Gap Inc. believes that the .GAP gTLD will provide a single trusted ecosystem experience for the millions of consumers worldwide who purchase the company’s products, as well as those who seek information about Gap Inc., including investors and members of the press. Consumers will know that domains and content on .GAP are owned and controlled by Gap Inc. and are thus more likely to be protected from infringing, pirated, or harmful content.

The initial use of the .GAP gTLD will involve a limited number of second-level domain names. This initial use will provide Gap Inc. the ability to ensure seamless and secure access to the Gap website and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Gap Inc. expects to begin allocating domain names for internal corporate use and may redirect new .GAP domain names to pre-existing content. This phased rollout will likely take place over a multi-year period, subject to change depending upon a range of external factors.

At the same time, Gap Inc. will evaluate potential strategies to migrate traffic away from the current network of second-level domains registered in various gTLDs, to the .GAP gTLD, which offers the potential to provide customers with a single, trusted online source for Gap brand products and services.

After consideration of the following factors: analysis of Gap Inc.’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Gap Inc. will have full control over the number of registrations in the .GAP gTLD namespace, Gap Inc. reasonably assumes that the number of domain name registrations will be less than 10,000 in the first five years of operation.

18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

Gap Inc. currently intends for the .GAP gTLD to be used exclusively by Gap Inc. and its partners⁄affiliates. Because of this condition, and because the Gap mark is a valuable brand, the protection of which is paramount to the company, Gap Inc. intends to address registration and use requirements in its partner⁄affiliate agreements, rather than in a domain name registration agreement.

Gap Inc. will, of course, incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each partner⁄affiliate will execute.

18.2.5 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 a global retail company, Gap Inc. respects the privacy of its customers and other consumers. The company employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information in its stores and on its websites. Gap Inc. will take similar precautions to protect registrant and user data associated with the .GAP gTLD. Furthermore, given that every domain name will be registered to Gap Inc. or a partner⁄affiliate, Gap Inc. has a vested interest in ensuring that accurate and current registrant information is readily available in connection with each .GAP domain name.

Gap Inc. will ensure that the operation of the .GAP will be consistent with Gap Inc.’s Privacy Policy, available on its website at http:⁄⁄www.gap.com⁄.

In addition, Gap Inc. intends to include contractual provisions to protect confidential and personal data in its registrar agreement, including provisions modeled after language in the template Registry Agreement that has been successfully utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states, “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (‘Personal Data’) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.ʺ

18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Gap Inc. sees the potential for the .GAP gTLD to play a large role in the company’s future online strategy. While the extent of likely benefits is currently uncertain due to questions of consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace, all of which will influence the communication and usage strategies for the gTLD, Gap Inc. anticipates a phased-in approach to using and promoting the .GAP gTLD.

As a first step, Gap Inc. plans to start using .GAP domains initially as redirects to existing .COM domains. Subsequently, Gap Inc. expects to initiate a targeted rollout using select gTLD domains as primary addresses and, after careful analysis and study of this rollout, Gap Inc. may engage in a broader initiative, should the results be satisfactory and in accordance with the company’s overall strategic goals. The actual usage of .GAP domain names will dictate what public communications and consumer outreach is conducted to encourage navigation to the .GAP gTLD, including advertising, media outreach, in-store communications, email campaigns, etc.

gTLD	Full Legal Name	E-mail suffix	Detail
.GROCERY	Safeway Inc.	fairwindspartners.com	View

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Safeway believes that the proposed .GROCERY gTLD has the potential to offer the following benefits to Internet users:

1) Establish a trusted source of information about Safeway and its subsidiaries and affiliates for the millions of consumers who purchase goods in its stores and online, for investors seeking information, and for the general Internet user population as a whole;

2) Provide Safeway and its qualified subsidiaries and affiliates with short and memorable Internet addresses;

3) Improve navigation to Safeway products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;

4) Through the adoption of new gTLDs by the wider Internet community, benefit users from a lower incidence of phishing and malware, which are often associated with typos of domain names in the .COM space and owned by cybersquatters, since they will be navigating to domain names in gTLDs like .GROCERY instead;

5) Minimize the cost and need for defensive registrations because domain names within the .GROCERY gTLD will be allocated by Safeway only; and

6) Develop a potential platform for the secure access to, and purchase of, Safeway products and information, in order to minimize the potential for counterfeit or infringing goods and services.

In addition, given its broad consumer base and operations in the U.S. and Canada, Safeway believes that the .GROCERY gTLD can provide an online, single-source identifying function for consumers.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .GROCERY gTLD is to provide a trusted, hierarchical, and intuitive online vehicle to deliver Safeway content and products, as well as information about the companyʹs brands, business, and focus. As Safeway continues to expand, it is the companyʹs desire to continue to pursue and develop opportunities to market and distribute its products and brands, in the U.S. and internationally, through a variety of platforms, including the Internet. Given that consumers are increasingly demanding access to companies and brands via a number of online channels, including domain names, Safeway believes that the .GROCERY gTLD has the potential to provide an innovative, virtual avenue to Safeway products and information that will deepen and broaden the companyʹs relationship with consumers.

Through use of the .GROCERY gTLD, Safeway will also be able to provide access to its content, brands, and products in a namespace devoid of piracy, cybersquatting, and other malicious cybercriminal activities. Providing consumers with a safe experience is paramount to Safeway, and the .GROCERY gTLD will be used to further that goal.

While Fortune 500 companies such as Safeway must fight a never-ending battle to protect their intellectual property from piracy on the Internet, the .GROCERY gTLD has the potential to offer consumers a safe and intuitive means of accessing authorized Safeway content and products.

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

Unlike most generic gTLDs that ICANN has approved over the last decade, which have largely been operated by Internet startups and have been primarily dependent upon ICANN-accredited registrars to market and promote their gTLD, Safeway is an established Fortune 500 company with the ability to leverage its existing brands and its commercial network of stores and their customers to increase the profile of the .GROCERY gTLD.


Safeway believes that the success of the gTLD will not be measured by the number of domain names registered, but by the levels of consumer recognition and trust that are placed in .GROCERY. Using this as a benchmark, Safeway will strive to build consumer recognition and trust, through the usage of .GROCERY, that rise to the levels of those found in the .EDU and .GOV gTLDs.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

Safeway believes that the .GROCERY gTLD will provide a single, trusted, ecosystem experience for Internet users worldwide, particularly consumers seeking Safeway products or information online. In addition to providing Safeway with short, memorable, and intuitive domain names, the .GROCERY gTLD will also indicate to users that they are navigating in a secure space where all domain names and content are owned and controlled by Safeway, thereby assuring them that they are protected from potential unauthorized, infringing, pirated, or malicious content.

The initial use of the .GROCERY gTLD will involve the registration of only a limited number of second-level domain names. This initial use will provide Safewayʹs IT and security personnel with the ability to run a number of tests to ensure seamless and secure access to Safeway websites, and interoperability with various software and Web⁄mobile-based applications. Once the appropriate security and stability issues have been satisfactorily addressed, Safeway will likely begin allocating domain names for internal use and may redirect new .GROCERY domain names to pre-existing content. This phased rollout will likely take place over a multi-year period.

During this same period of time, Safeway will evaluate potential strategies to use the .GROCERY gTLD in other ways that will advance the companyʹs corporate mission and goals.

18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

Safeway currently intends for the .GROCERY gTLD to be initially used exclusively by Safeway and its qualified subsidiaries and affiliates. Because of this condition, any registration and use requirements are more appropriately vested in these corporate⁄affiliate agreements and not in a domain name registration agreement.

Notwithstanding this, Safeway will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each qualified subsidiary or affiliate would execute.

18.2.5 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.

Due to the fact that every domain name within the .GROCERY gTLD will be registered to Safeway, the company has a vested interest in ensuring that accurate and current domain name information is readily available in connection with each .GROCERY domain name. For the .GROCERY gTLD, all private and confidential information will be protected.

Safeway will ensure that the operation of the .GROCERY gTLD will be consistent with its U.S. Privacy Policy, see http:⁄⁄www.safeway.com⁄ShopStores⁄Privacy-Policy.page.

In addition, Safeway intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement that has been successfully utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states, “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (“Personal Data”) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.ʺ

18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

While Safeway sees the potential for this gTLD to play a role in Safewayʹs future online strategic initiatives, this role will likely be shaped by consumer recognition and the adoption of new gTLDs, as well as the response from search engines in the marketplace. These factors will also likely influence the degree to which .GROCERY is used and communication about that usage.

Notwithstanding this, Safeway plans to initially start using .GROCERY domain names as redirects to existing Safeway .COM domain names. Safeway also plans to carefully review the release of new gTLDs by others, the response from search engines to new gTLDs, and consumer perception. As the marketplace evolves, Safeway will invest in outreach and communication as needed, to ensure that consumers, as well as Internet users as a whole, continue to interact online with Safeway in a simplified and efficient manner.

As noted in 18.2.2, most of the generic gTLDs that ICANN has approved have primarily been operated by Internet startups created solely for the provision of domain name registration services, e.g., .INFO (Afilias), .BIZ (NeuStar), and .TRAVEL (Tralliance). Safeway is an established Fortune 500 company with the ability to leverage its extensive network of stores, partners, consumers, and related websites to increase the profile of the .GROCERY gTLD.