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
.BOFA	NMS Services, Inc.	fairwindspartners.com	View

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

Given that many consumers search for and use Bank of America and its subsidiaries’ content online, Bank of America believes that the proposed .BOFA gTLD has the potential to offer the following benefits to Internet users and consumers:

-Provide a trusted online marketplace for the millions of consumers that use Bank of America’s Online services;
-Provide Bank of America and its qualified subsidiaries, affiliates, and business units with the use of short and memorable Internet addresses in order to facilitate increased ease for navigation to Bank of America online content and other services;
-Minimize the need for defensive registrations because domain names within the .BOFA gTLD will only be registered by NMS Services to verified Bank of America administrators and qualified subsidiaries, affiliates, and business units of Bank of America, at least for the first three years of operation;
-Serve as a secure platform for Bank of America’s Online Banking operations; and
-Incorporate enhanced intellectual property rights (IPR) protection mechanisms.

Also, through the adoption of new gTLDs by the wider Internet user community, consumers may benefit from lower incidents of fraud, misdirection, infringement, phishing, malware, or other scams often associated with mistypes of domain names in the .COM space that are owned by cybersquatters, since they will be navigating to domain names in the .BOFA gTLD.

Bank of America branches and ATMs are located in 41 states across the United States. As such, NMS Services would like to provide a hierarchical and intuitive framework for the .BOFA namespace by using geographical identifiers as second-level domain names. This use of geographical identifiers to the left of the gTLD and as part of the domain name itself is believed to have a direct and material impact on search engine algorithms and their corresponding query results. Bank of America would like to see if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality and innovation.

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

NMS Services and Bank of America have filed this application for a .BOFA gTLD in order to provide a secure, trusted, virtual platform to aggregate Bank of America’s already well-known and prestigious content and other goods and services. As technologies for delivering content and services evolve, Bank of America will pursue opportunities to distribute its content and services to consumers in the U.S. on various platforms, including the Internet and mobile devices. As noted above, Bank of America intends to use the .BOFA gTLD as an intuitive means to offer its content and to deepen and broaden its relationship with customers, potential customers, and Internet users in general.

Most importantly, the Bank of America content and services will be provided in an online namespace devoid of fraud, misdirection, infringement, phishing, malware, and other scams. While Bank of America fights to protect its Online Banking from fraud and cyber attacks, it would use the .BOFA gTLD to offer to consumers a safe and intuitive means of accessing authorized secure content from Bank of America and its qualified subsidiaries, affiliates, and business units.

With regard to service level and reputation, Bank of America will operate the .BOFA gTLD in accordance with the Bank of America Corporation Code of Ethics, see: http:⁄⁄investor.bankofamerica.com⁄phoenix.zhtml?c=71595&p=irol-govconduct.

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

The two factors driving Bank of America to seek the branded .BOFA gTLD are differentiation and innovation. Bank of America is one of the world’s leading banks, and it uses existing technology and leverages emerging technologies to deliver content and services to its millions of consumers. A .BOFA gTLD has the potential to serve as a cornerstone of this online strategy.

While some of ICANN’s new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, .BOFA from its launch will be a trusted online source of Bank of America information, goods, and services. Bank of America and NMS Services will follow Bank of Americaʹs established good business practices in working with law enforcement to create a marketplace with safeguards designed to minimize fraud and other illegal activity.

NMS Services believes that the success of the gTLD will not be measured by the number of domain names registered, but rather by the level of consumer recognition and trust that is placed in the .BOFA gTLD. Using this benchmark, NMS Services strives to build consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.

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

In addition to providing a trusted ecosystem experience for its millions of customers who use its content, goods, and services, NMS Services will minimize potential fraud, misdirection, infringement, phishing, malware, and other scams because domains will only be registered to Bank of America and its qualified subsidiaries, affiliates, and business units, at least for the first three years of operation. As a leading financial services company, Bank of America believes that it can be a pioneer in bringing innovation in consumer choice to this new Internet medium.

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

Bank of America is fully committed to implementing all of ICANN’s consensus policies and other Rights Protection Mechanisms (RPMs) identified in the Applicant Guidebook. Moreover, based upon Bank of America’s commitment and established track record in providing a safe ecosystem for consumers, Bank of America intends to provide best-in-class safeguards that will evolve over time.

Because the domains within the .BOFA gTLD are currently intended to be initially registered exclusively to Bank of America and its qualified subsidiaries, affiliates, and business units, any registration and use requirements are more appropriately vested in the corporate-subsidiary and corporate-affiliate agreements, or corporate policies and practices, and not in a domain name registration agreement.

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 leading financial services, with extensive online operations, Bank of America has a vested interest in making sure that accurate and current domain name information is readily available in connection with each .BOFA domain name. For the .BOFA gTLD, all private and confidential information will be protected.

NMS Services will ensure that the operation of the .BOFA gTLD will be consistent with Bank of America’s Online Banking Security Guarantee, available here: http:⁄⁄www.bankofamerica.com⁄onlinebanking⁄index.cfm?template=online_banking_security.

In addition, NMS Services intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and 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.

Bank of America sees the potential for the .BOFA gTLD to play a meaningful 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, NMS Services anticipates a phased-in approach to using and promoting the .BOFA gTLD.

NMS Services plans to start using .BOFA domains initially as redirects to existing .COM domains and other domains that Bank of America currently operates. Subsequently, NMS Services expects to initiate a targeted rollout using select gTLD domains as primary addresses and, after a careful review and analysis of this rollout and of the release of new gTLDs by others, the response from search engines to .BRAND gTLDs, and the perceptions of consumers, NMS Services and Bank of America may engage in a broader initiative, should the results be satisfactory and in accordance with the company’s overall strategic goals. As the marketplace evolves, the actual usage of the gTLD will dictate what outreach and communication is needed to ensure that consumers continue to interact with Bank of America content in this new namespace.