18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Prototypical answer:

Dot-Irish LLC
Question 18B

The Irish Diaspora is a community widespread in number, but strong in identity and cultural history. Our research has shown that while there are approximately 6 million people on the island of Ireland, there are nearly 80 million people worldwide that identify themselves as Irish.

With respect to the country-code Dot-Ie (.Ie), we believe it will continue to serve a valuable purpose as the top-level domain specifically for registered businesses and people located in the Republic of Ireland. However, we believe that people will find value in .Irish, both in the Republic of Ireland and throughout the Irish Diaspora.

Our consultations with Irish businesses, political and regulatory officials, charitable and cultural organizations, members of the ICANN community and more have confirmed the demand and appreciation for the concept of .Irish.

“I am excited for the creation of .Irish. I believe there is a widespread demand in Ireland and elsewhere for a TLD that communicates Irishness to the world. I know many of my customers will want one.”

-Michele Neylon,
Managing Director of Blacknight
ICANN Accredited Registrar, Ireland

The .Irish top-level domain will have several benefits to Internet users at its outset and will develop additional uses as time moves forward. As with many new top-level domains, the ability for Irish organizations and companies to register shorter and more meaningful domain names under .Irish will create positive implications for search and simple, easy tools for marketing. Businesses, groups and individuals that associate with being Irish will have the opportunity to clearly identify themselves as such.

“As a director of a major charity organization that operates between the United States and Ireland, I come across business owners, professionals and individuals every day that identify with the brand. I am very excited to be a part of this, and I know a lot of my contacts will want to get involved.”

-Patrick Tully
National Director, American Ireland Fund Young Leaders Society

“In the Irish tourism business, we thrive on promoting heritage, family history and the unique tradition and culture of the Irish people. My company will certainly benefit from the ability to register a domain name with .Irish.”

Keith Charlton
Co- Founder, Bunk Campers

Dot-Irish LLC has identified several compelling initiatives that could become valuable services or technologies in years to come. These opportunities include, but are not limited to social and business networking, genealogy and heritage programs, travel and tourism, charitable initiatives, economic or business services and much more.

Dot-Irish LLC intends to develop, promote and encourage programs that could enhance the connectivity and experiences of Irish peoples. A few of these services may be developed internally or in partnership with other organizations, and we expect many to be created and developed by other people or organizations that recognize the value potential.

Dot-Irish LLC is committed to establishing the .Irish domain space in a way that promotes innovative technologies, services and programs that benefit Irish culture, heritage and people. We intend to continue networking and taking consultations with appropriate people and organizations before and after launch in order to ensure the development of a quality TLD.

REGISTRATION POLICY

Dot-Irish LLC intends to operate the .Irish top-level domain under a coherent, transparent and sustainable process to minimize social costs and maximize the value for its audience and Internet users. The registry will correspond and comply with ICANN to incorporate the best practices and policies available. We will also coordinate with appropriate Irish bodies and organizations to ensure and maintain a quality domain in keeping with Irish culture and heritage. Wherever possible, we will contribute our thoughts, ideas and initiatives in a constructive manner to improve these processes.

ICANN has indicated over time a series of consensus policies for new gTLD applicants to incorporate into their registration policies. It is our intention to monitor and comply with policies set by ICANN, and to contribute to the formation of a fair, professional and transparent process.

It is also our understanding that many of these policies are subject to modifications, particularly as a result of issues that may be generated from the new gTLD application process in 2012. As a potential registry operator, we have reviewed the current public information, and taken numerous professional consultations to ensure that we will be able to comply with these policies in a timely manner at the appropriate stages.

We will also remain open and responsive to prospective registrants and intend to develop initiatives to encourage participation at the appropriate stages. In this regard, our applications have already been compiled or reviewed to varying extents by Loeb and Loeb LLP, attorneys at law, Edward White & Co., LLP, certified public accountants, our registry services provider Afilias and TLD Assets LLC. A number of other former ICANN staff, registries and registrars, companies and consultants in a number of fields have also informally contributed to our understanding of the New gTLD Program and the appropriate policies. Please review below a compilation of policies intended to address the issues referred to in this question.

Below is a preliminary description of policies for Dot-Irish LLC. Dot-Irish LLC plans to take additional consultations and interact with the appropriate governing bodies or service providers as necessary to update registration policies in relation to any potential changes by ICANN.

Trademarks & Dispute Resolution

The launch of .Irish will include the operation of a trademark claims service according to the defined ICANN processes for checking a registration request and alerting trademark holders of potential rights infringement.

Dot-Irish LLC will make a formal announcement to notify the public of an upcoming Sunrise period at least 30 days prior to the opening of Sunrise. Exact dates and parameters will be released prior to the beginning of Sunrise. Dot-Irish LLC intends to work with the Trademark Clearinghouse to check and verify registered marks. Dot-Irish LLC also intends to fully comply with Uniform Dispute Resolution Policy (UDRP), Uniform Rapid Suspension (URS), Post-Delegation Dispute Resolution Policy (PDDRP), any other rights protection mechanisms (RPMs) and WHOIS requirements throughout the Sunrise and Landrush periods, and after standard registrations begin. Further detail and descriptions of RPMs are given in our response to Question 29.

Sunrise will consist of a period of at least 30 days. Trademark and service mark holders will be able to reserve marks that are an identical match in the .Irish domain. Recurring annual fees will be standardized in accordance with fees set at preregistration levels. Those wishing to reserve marks in the .Irish domain during the Sunrise Period must own a current trademark or service mark listed in the Trademark Clearinghouse.

Notice will be provided to all trademark holders in the Clearinghouse if someone is seeking a Sunrise registration. This notice will be provided to holders of marks in the Clearinghouse that are an Identical Match (as defined in the Trademark Clearinghouse) to the name to be registered during Sunrise.

Each Sunrise registration will require a minimum term of five years.

Dot-Irish LLC will establish the following Sunrise eligibility requirements (SERs) as minimum requirements, verified by Clearinghouse data, and incorporate a Sunrise Dispute Resolution Policy (SDRP). The SERs include: (i) ownership of a mark that satisfies the criteria set forth in section 7.2 of the Trademark Clearinghouse specifications, (ii) description of international class of goods or services covered by registration; (iii) representation that all provided information is true and correct; and (iv) provision of data sufficient to document rights in the trademark.

The SDRP will allow challenges based on the following four grounds: (i) at the time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; (ii) the domain name is not identical to the mark on which the registrant based its Sunrise registration; (iii) the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or (iv) the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received.

A Landrush period will be held following the Sunrise period. The Landrush period will last at least 30 days. Registration will be open to the general public. However, Dot-Irish LLC will make efforts to publicize the Landrush period, particularly to the Irish Diaspora. Landrush will not consist of a first-come, first-serve basis, and is created primarily to allow the greater Irish community adequate opportunity to register a domain. On a case-by-case basis, multiple applications for the same domain name may be subject to dispute resolution mechanisms or an auction. The Landrush period may be extended beyond 30 days. Terms and conditions will be set by Dot-Irish LLC prior to the launch of Landrush.

Abusive conduct will not be tolerated during preregistration or at any time, and an abuse point of contact will be maintained at all times. Additional information on abusive conduct and terms of use can be found in response 18C.

After the completion of Sunrise and Landrush periods, standard registrations will begin, and domains will be awarded to registrants on a first-come first-serve basis.

Reserved Names

Dot-Irish LLC will also maintain a reserved list. Some of these names will be reserved for regulatory or informational purposes. ICANN has already determined several of these on behalf of registry operators. Examples can be found in Specification 5 of the sample New gTLD Registry Agreement provided by ICANN in the Applicant Guidebook. Dot-Irish LLC intends to fully comply with this list and any additions that may be made in the future.

Dot-Irish LLC will continue to take consultations in an effort to maintain this list and the .Irish domain in a sensitive and respectful manner to the global Irish community. Dot-Irish LLC will reserve the right to disqualify registrants or their agents from making or maintaining any registrations or reservations in the .Irish TLD if these registrants are found to have repeatedly engaged in abusive registrations, in its sole discretion.

Some premium names will also be put on a reserved list and will be reserved for auction. Some premium names may be awarded to individuals or companies through a transparent process in the interest of developing key services or initiatives under the .Irish domain. For example, Dot-Irish LLC may host a “Founders Program,” whereby people may apply for a premium name and demonstrate a valuable use. This will be done within reason and on a limited basis.

Dot-Irish LLC will not intentionally attempt to put trademarked names on the premium section of the reserved list, and will cooperate with any appropriate rights protection mechanisms. Premium domains will be established prior to launch.

Trademark “frontrunning,” the process of registering trademarks for valuable domain names that have not been released to the general public for the sole purpose of securing the domain at a lower price, is deemed to be abusive to the registry and will not be recognized.

Finally, certain geographic names will be reserved and handled in accordance with procedures delegated by ICANN. For more detail on this section, please refer to Question 22.

Data Collection and Use Policy

So that registrants can understand how their personal data might be used, Dot-Irish LLC will notify registrars of the purposes for which personally identifiable data is collected and used, and Dot-Irish LLC will not use that data in ways that are incompatible with the notice provided to registrars. (See Article 2.17.) Dot-Irish LLC will create a data collection and use policy that anticipates all the data that the registry can collect, and the ways it may want to use it.

Publication of Registrant Data; Measures for Protecting the Privacy or Confidential Information of Users

Dot-Irish LLC will have several measures for protecting the privacy of confidential information of registrants or users.

As per the New gTLD Registry Agreement, Dot-Irish LLC will make domain contact data (and other fields) freely and publicly available via a Web-based WHOIS and a port 43 server. (See Specification 4 for details.) This default set of fields includes the mandatory publication of registrant data. The Registry-Registrar Agreement will require that registrants consent to this publication.

As per the requirements of the new gTLD Registry Agreement (Article 2.17), Dot-Irish LLC shall notify registrars regarding the purposes for which data about any identified or identifiable natural person (“Personal Data”) submitted to the Registry Operator by such registrar is collected and used, and the intended recipients (or categories of recipients) of such Personal Data. (This data is basically the registrant and contact data required to be published in the WHOIS.) Dot-Irish LLC will require each registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. The policies will be posted publicly on the registry operator’s web site. As the registry operator, Dot-Irish LLC shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.

Specifically, those policies will include the following:
• As registry operator, Dot-Irish LLC does not plan on selling bulk WHOIS data. Dot-Irish LLC will not sell contact data in any way. Dot-Irish LLC will not allow, enable, or otherwise support the transmission by e-mail, telephone, or facsimile of mass unsolicited, commercial advertising or solicitations.
• Dot-Irish LLC may use registration data in the aggregate for marketing purposes.
• DNS query data will never be sold in a way that is personally identifiable.
• Dot-Irish LLC may from time to time use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use.
As the registry operator, Dot-Irish LLC shall take significant steps to protect Personal Data collected from registrars from loss, misuse, unauthorized disclosure, alteration, or destruction. Question 30 (“Security Policy”) and Question 38 (“Escrow”) contain further information regarding security policies and procedures used to protect the registry system and the data contained there from unauthorized access and loss.

Please see Question 26 (“WHOIS”) regarding “searchable WHOIS” and rate-limiting. That section contains details about how Dot-Irish LLC will limit the mining of WHOIS data by spammers and other parties who abuse access to the WHOIS.

Dot-Irish LLC plans to impose certain operational standards for registrars. In order to gain and maintain accreditation for .Irish, we will require registrars to adhere to certain information technology policies designed to help protect registrant data. These will include standards for access to the registry system, and password management protocols. Please see Question 30 (“Security Policy”) for details.

Dot-Irish LLC will allow the use of proxy and privacy services, which can protect the personal data of registrants from spammers and other parties that mine zone files and WHOIS data. Dot-Irish LLC is aware that there are parties who may use privacy services to protect their free speech rights, or to avoid religious or political persecution.

Similar gTLD applications: (5)