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

gTLDFull Legal NameE-mail suffixDetail
.istanbulIstanbul Metropolitan Municipalitygmail.comView
We totally agree with ICANN: New gTLDs will change the way people find information on the Internet and how businesses plan and structure their online presence.

By the light of this vision, we believe that the proposed TLDs will provide numerous benefits to the registrants, internet users and others who want to become a part of the Istanbul. However, these we mentioned in this content are only limited by our imagination.

The Istanbul Metropolitan Municipality (the ʺIMMʺ) has a powerful budget and capabilities to support these TLDs in every aspect. We as the IMM, have a strong advertisement infrastructure, media vehicles and powerful market, and above all we truly believe the success of the TLDs.

At first glance, the proposed TLD offers benefits to City tourism, small-to mid businesses, entrepreneurs, and global corporations with a presence in the City. It will provide connections that facilitate innovation enabling people to create and sell their services and products to one another and the world. Most importantly, creative use of the Internetʹs naming and networking features will facilitate transparency, collaboration, and trust helping the City grow as a global economic force.

The IMM intends to market the proposed TLDs as a truly prestigious strings that can be embraced and utilized by an individual, entrepreneurs, enterprises, and organizations whether located in Istanbul, or not. By positioning the proposed TLD as a truly prestigious string and by providing an entirely new pool of domain names for registration, the proposed TLD will open the possibility of domain name registration to a far greater number of people.

New name space

Although this market is currently served by existing gTLDs and ccTLDs, as a practical matter many of the most popular commonly-known and utilized words and phrases have already been registered. Accordingly, new registrants must have the financial resources sufficient either to conduct a major marketing campaign for an uncommon phrase or to purchase a previously registered domain name at a substantial price. It created a aggressive competition between people, businesses and organizations with the same name. Number of domain name disputes are growing, and the name space for generic names is getting tight since a lot of companies register many gTLDs and ccTLDs when launching a business or product. This limits the ability of the Internet to continue to expand into a truly global medium. In this context, the proposed TLD will calm this competition down, since a nearly infinite number of new combinations will be available with it.

Through the introduction of a new TLD, the IMM will provide registrants with a fresh set of domain names eligible for registration. Although the IMM expects that some registrants of existing gTLDs domain names will quickly move to register an equivalent name in the new TLD, the IMM expects that the majority of registrants will not apply for duplicative registrations, leaving many domain names free for registration by entirely new registrants. The most important goal of proposed TLDs is to provide a new fresh name space for local brands to encourage them becoming a part of the virtual world.

The new Turkish Commerce Code, which will start a new era in the Turkish economy.

The New Turkish Commercial Code (the “NTCC”), which will be effective from 1 July 2012, is a change that will direct the course of commercial life in our country, a real “Regulation for the Future”. The TCC was adopted by the Turkish Parliament on 13 January 2011 and promulgated in the Official Gazette on 14 February 2011. In summary, The NTCC redefines the rules governing commercial life in Turkey, with a modern approach that will help take Turkey to the next level in terms of transparency, auditability and reliability. Additional notes regarding to NTCC is provided at the question #49c Contingency Planning - Volumes as Attachment 49c.

In accordance with the principle of transparency at the NTCC, all equity capital companies are obliged to found a web site, and if such a site is available, to allocate a section of the web site to the use of shareholders and society. The web site shall include all the reports and all the relevant data concerning creditors and investors; primarily all announcements that should be legally made by the company, annual reports, financial statements and audit reports. Penalties and sanctions shall apply if the company fail to fulfil these obligations.

In this context, we believe that proposed TLDs in parallel with the NTCCʹs goals will have a important role on creation of an information society by providing a new name space for businesses, marketing and introducing this new TLDs.

Benefits for the local business and trademarks

Primarily, we believe that this TLD will assist local merchants based in Istanbul to be able to brand their businesses as located in the Istanbul. The small business community is a vital part of the Istanbul economy and any opportunity to increase their exposure while facilitating easy searching online is a step forward. The following list summarizes benefits for the businesses:
- Short, descriptive, and memorable domain names will be available for the Cityʹs businesses. Many local businesses will have the opportunity to reclaim their traditional and familiar names within the proposed TLD.
- The new set of domain names will reduce the current time consuming task of locating a good domain name, provide identity, and promote ʺfindabilityʺ through the intuitive names and Search Engine Optimization, helping city businesses rise to the top of search engines results.
- The proposed TLDs will provide local identity for companies using the same name used in other cities.
- Global companies with a city presence will choose a local TLD for more focused communication such as to let residents know of their local jobs, distributors, concerts, and community events they sponsor.

By encouraging domain name registration by a large audience both national and international, the proposed TLD will foster to improve service levels of both local and global businesses and government institutes. The TLD will able to enable government institutes to launch new e-government initiatives by a modern communication infrastructure and thereby it will ease the interaction of the city government and institutions with residents, organizations and businesses. Self-explaining URLs with content users expect will make the Cityʹs resources readily available and easier to locate by the regional, national and international audience. In addition, global and local businesses will be able to market and promote their events, new products and services for a targeted audience under a City brand.

By increasing navigation, the proposed TLD will obviously provide localization for areas of specialty such as hospitality, culture and education. Therefore accessibility of trusted-information will become easier than ever. In addition, the TLD will enable the IMM to generate new income streams which will enable a considerable resource for the IMM to support its services for the public and City development as well as to support its unique initiatives for tourism and economic development.

Our proposed TLDs goals are to foster businesses and government institutes to develop new methods to reach and communicate their targeted audience.

Reputation

We believe that proposed TLDs will support to increase brand awareness, recognition, and reputation of the Istanbul around the world. In this sense, it will support to promote and market tourism and culture in the Istanbul globally.

The TLD will ease the marketing of the city brand and city image to residents, tourists, businesses and investors from all over the globe with every domain name, e-mail, and web site. All of them will be associated with the City, and people will be reminded of our great city, and dream of their next visit. The TLD will create a unique local identity for citizens, companies, organizations and institutions and also provide a opportunity for local business to market their brands under a world City brand.

Our proposed TLD, which will boost importance and richness of Istanbul, goals is to support economic growth of the City by providing a new vehicle for City tourism. Once the ʺ.istanbulʺ and ʺ.istʺ TLDs are launched, individuals and local business owners will be able to uniquely associate themselves and their business with their home, and the Istanbul brand. They will be able to choose their online presence, how they want to represent themselves, with IST brand short-form of Istanbul or Istanbul brand.

The both proposed TLDs will be a source of prestige for Istanbul. Istanbul will be honored to recognize with its own TLD in the country and in the worldwide.

Competition

One of the central goals of the introduction of new TLDs is to create competition between existing ccTLDs and gTLDs and registry operators, as such competition will inevitably benefit the public. By definition, the more competitors there are in any given market, the greater the opportunities for competition in that market.

The introduction of a new TLD managed by the IMM and its experienced back-end registry operator will also create competition for the existing gTLDs, ccTLDs and their registry operators. This competition will drive each registry operator to improve its services and pricing and thereby benefit the entire Internet community.

New gTLDs will also create additional choices for consumers, and thus foster competition between the proposed TLDs and the existing unrestricted and restricted gTLDs and ccTLDs. Such competition will benefit consumers as it will encourage all registries to offer better services and prices. Domain name registrants will for the first time have an opportunity to choose the registry or registries with which they would like to do business.

The proposed TLDs consequently will increase choice and competition for the regional city community in an environment of national and international competition on investments.

Accordingly, we expect from ICANN to examine the degree to which the introduction of a new gTLD encourages competition between TLD registry operators, and the effects of such competition. Although the impact of competition in a marketplace may be difficult to measure over a short time period, The IMM will make its best effort to have the desired effect.

Finally, we expect that ICANN should study the degree to which effective marketing on the part of a new entrant is necessary to ensure real competition for registration services. If such competition requires an extensive marketing campaign, then only those that have the financial resources to conduct such a campaign should be selected to operate new TLDs. The IMM has already funded necessary contribution for marketing campaign and has a powerful marketing vehicles with large audience to support proposed TLDs advertisement.

Innovation

One of the important goals of the proposed TLD is to leverage innovation and create differentiation globally. The TLDs will offer the opportunity to create projects, ideas and new initiatives to individuals, enterprises and organization on a green field.

We believe that proposed TLDs will become an engine of innovation that will enable citizens and Istanbul to grow and thrive.

User Experience

As an unrestricted TLD, the proposed TLDs will serve businesses and individuals of all countries and classes.

The proposed TLDs will allow registrants the opportunity to establish an international-regional web presence, and reduce the need to register multiple domain names in other TLD spaces. Domain name registrants may then focus their resources on expanding the reach of their offerings and content, as well as their brand identity. Finally, the proposed TLDs will enable new registrants to enter the market and register domain names.

In addition, the TLDs will also unite people across the world under a city brand. People who lives, or formerly lived, visited or wants to visit, and do business or looking for business opportunities in Istanbul will be able to associate themselves as they are somehow connected to the Istanbul. Other locations worldwide with the same name, even if small villages or towns, shall also be part of the community. They will profit from the increased visibility of the city name and will have equal rights to register domain names under the TLD.

Through .istanbul and .ist TLDs, we hope to make the search for Istanbul City-related content easier than ever by providing individuals, entrepreneurs, organizations, non-profits and others a chance to own a virtual piece of the greatest city in the world.

The IMM Mission

The IMM Department of Information Technologiesʹ mission is to transform the way Istanbul City interacts with its residents, businesses, visitors and employees by leveraging technology to improve services and increase transparency, accountability and accessibility across all agencies.

In addition to IMMʹs mission, 2010-2012 Strategic Plan by Information and Communication Technologies Authority (ICTA) has three main goals that support the macro scale objective “creation of an information society”, (1) e-transform of public authorities⁄institutions, (2) Widespread use of electronic communication over broadband and (3) Efficient information security.

Within this context, goals of proposed TLDs are also to support ICTA strategic goals, launch new e-government initiatives, and increase Istanbul reputation globally.

By marketing and promoting the TLDs successfully, the IMM hopes to increase electronic communication, internet usage, and awareness of virtual worldʹs opportunities around the country.

We believe that the proposed TLDs will establish a focal point for bringing the benefits of the information society to the city community.
In recent years, the IMM has developed many projects promoting sustainable development in areas of urban transformation, social services for deprived citizens. Particularly, ongoing Istanbul Financial Center (ʺIFCʺ) project to support economic growth, and other innovative systems, will have also significant contribution to support proposed TLDs. These major projects will clench the position of Istanbul as a global-scale city. Istanbul will become the exemplary center of culture and arts, environment, humane living environments and health, sports and technology.

Within this context, strategies towards raising Istanbul’s rank among global cities will contribute to the proposed TLDs process and basic goal is that Istanbul should have its own TLD by its diversity of benefits community and quality of brand.

Privacy

The IMM is committed to being a responsible participant in the efforts of the Internet community to balance the need for data privacy with the need to provide access to records that allow the public to identity and contact domain name holders. To that end, the IMM will strive to maintain open access to registrant information to the extent compatible with applicable privacy laws and the its policy of treating all registrants equitably.
In addition, via the Registry Registrar Agreement (RRA), we will require registrars to post privacy policies that provide clear and complete notice to registrants of the type of data that will be collected and maintained by the IMM, the use of such data in operating the registry service, (including display through the Whois service), and the registrantʹs rights to access and correct data maintained by the IMM. Clear consent to such data practices will be a prerequisite to the submission of a domain name registration request.

In addition, for each type of Whois access (general queries, bulk access and enhanced searches), the IMM, via the registrars, will require customers to enter into an agreement prohibiting the customer from using the Whois database to send unsolicited e-mail to registrants, solicit them by telephone or use the database for other such commercial purposes.

The IMM and its back-end registry service provider itself will not use the Whois service to send unsolicited e-mail to registrants, to solicit registrants by telephone, or to otherwise engage in unauthorized uses of their data.

The IMMʹs goal is to improve the reliability and responsiveness of the TLD registry system at all levels through technological, business and policy advancements.

Registration Policies

The IMM will implement a global registration policies to achieve its goals. These are grouped under the following headings:
1. Registry Services through experienced, powerful, centralized registry service provider.
2. Start-up period Policies (Grandfathering, Sunrise A, Sunrise B, Landrush)
3. Registry Registrar Agreement (RRA)

The IMM expects a significant rush for domain name registrations during the period immediately following the initial opening of the TLD (the ʺStart-Up Periodʺ), after the close of the Landrush Period. In order to roll out the registry in a responsible fashion, and ensure proper and accurate processing of the registrations in a fair manner across all registrars, we will implement the following variations in its registry policies in coordinated with back-end registry service provider during the Start-Up Period which is expected to last for more than four months.

At least four months (120 days) prior to the proposed TLDs being opened to the general public, the IMM, in coordination with the intellectual property community, will make a general public announcement with the estimated date that it will open the proposed TLD to the general Internet community.

The IMM will implement a series of special policies with a detailed Launch Plan during a ʺStart-up Periodʺ. The Launch Plan will be intended to deter abusive and bad faith registrations of proposed TLDs Domain Names and to create a stable and effective launch of proposed TLD Domain Names for the benefit of the Internet community on a local and global level.

Schedule for Start-up

The IMM will introduce a detailed .TLD Launch Plan which intends to provide for the allocation of Domain Names in the proposed gTLD in a fair, orderly and equitable manner, and described in detailed at question #29 Rights Protection Mechanisms.

The following list provides a summary of the four phases of the Launch Plan:
- Phase 1: Grandfathering (one month). The IMM intend to provide one month timeframe for grandfathering for existing Registrants of Third Level Name(s) of .TR ccTLD.
- Phase 2: Sunrise (two months). Sunrise “Local (A)” for local trademarks, and Sunrise “Global (B)” for global trademarks.
- Phase 3: Landrush (one month): Period during which interested parties can seek to register Domain Names not previously registered through the Grandfather Process or Sunrise Process, or otherwise reserved by the Registry or Restricted by theses Launch Rules, but where the allocation of Domain Names is not done on a first-come, first-served basis.
- Phase 4: General Availability: As from the start of this phase, Domain Names that have not been previously registered can be registered on a first-come, first-served basis.

Length of Sunrise Registrations

The IMM believes that parties seeking domain name registrations during the Sunrise Periods will select as long a registration term as is available to them, in order to protect their valuable asset as a domain name for as long as possible. Therefore, domain name registrations that issue during the Sunrise Periods will have a minimum term of five years.

Registration

The Registry Registrar Agreement (RRA) will prohibit the purchase of domain names by registrars for any purpose except instances where the registrar has a bona fide intent to use that domain name on its own behalf.
gTLDFull Legal NameE-mail suffixDetail
.flyCharleston Road Registry Inc.google.comView
18.b. Benefits to Registrants, Internet Users, and Others

18.b.i.1. Specialty

The goal of the proposed gTLD is to create a new Internet environment that provides registrants with the opportunity to associate with a meaningful term.

Charleston Road Registry, as the registry operator, will define the specialized meaning of the term and, based on this definition, will identify criteria for registrants to operate in the proposed gTLD. Only entities that meet these criteria will be entitled to register for a domain in the gTLD. Specialization, therefore, arises from the Charleston Road Registry definition of a term, as well as through market dynamics as entities align their offering(s) with the term. This specialization will be maintained through intermittent audits to ensure the relevancy of content in the proposed gTLD to the defined meaning of the gTLD.

The specialization goal of the proposed gTLD is to create a new Internet environment that provides registrants with the opportunity to associate with the term ʺflyʺ and to provide air travel-related offerings within that dedicated domain space. This specialization introduces a single domain name hierarchy with the express purpose of offering air travel-related content.

18.b.i.2. Service Levels

Through its association with Google, Charleston Road Registry is uniquely positioned to enable and support the proposed gTLD by providing its service reliability and speed of delivery as a part of its services. Google brings unique expertise and a proven record of excellence in infrastructure operations: Google now runs the largest DNS system in the world, has industry-leading uptime on its services, such as web search, and offers enterprise services on which governments and businesses depend.

Google is known for its high level of quality and speed, and Charleston Road Registry’s service level goal for the proposed gTLD is to extend that high level of quality, speed, and service to registrars. Indeed, two of Google’s core principles are “focus on the user and all else will follow” and “fast is better than slow.”

Charleston Road Registry is committed to using the most technologically advanced, secure, and reliable registry services for all of the domain names in the gTLD so as to not compromise the service levels, security, and stability of the gTLD to users across the globe.

Charleston Road Registry will provide both Engineering and Customer Service support to registrars. All registrars will also have the same level of access to Charleston Road Registry resources to resolve disputes and technical and⁄or administrative customer service issues.

Charleston Road Registry will provide all registrars with 24-hours-a-day, 7-days-a-week Customer Support in the form of telephone, email, and⁄or web chat for technical and non-technical issues relating to the operation of the gTLD system. Charleston Road Registry will provide all registrars with the same level of access to customer support via telephone, email, and Charleston Road Registryʹs website; email and web-based interactions will be the primary method of provisioning customer service support to registrars.

18.b.i.3. Reputation

Google has a proven record of providing high-quality, secure online services. Charleston Road Registry seeks to enhance Google’s reputation for excellence, superior quality, and high level of security and become known as an exemplary domain name services provider. When registrants assess opportunities in the marketplace to obtain a name, they will have confidence in Charleston Road Registry’s ability to meet ongoing needs as the registry operator for the proposed gTLD. When Internet users visit a domain name in the proposed gTLD environment, they will be able to reliably expect and experience the high level of security and quality on which Google’s reputation has been built.

The registry will be structured in such a way that Charleston Road Registry will enable registrars to register and oversee second-level domain names in the proposed gTLD; that registrars develop and deploy a reasonable process for ensuring that those domain names are used for gTLD-relevant purposes as specified in the registry-registrar agreement; that the WHOIS is thick and reliable; and that the registry is responsive to legal rights owners (if applicable) who may have complaints about potentially abusive registrations.

Charleston Road Registry plans to develop and publish eligibility criteria for all registrants in the proposed gTLD and will work with its registrars to execute the eligibility verification process. This process will imbue additional meaning to all second-level domains in the gTLD and enhance the gTLD’s reputation by establishing an authoritative community of content providers. When Internet users visit a website in the proposed gTLD environment, they will be able to reliably expect content relevant to the proposed gTLD.

In addition, Charleston Road Registry’s operation of the new gTLD will provide the opportunity for registrars and registrants to build and⁄or bolster their unique brands and brand reputation in association with the proposed gTLD.

18.b.ii.1. Competition

Charleston Road Registry supports the advancement of registry operators as a whole and the diffusion of gTLDs amongst diverse stakeholders to generate increased competition for the benefit of the Internet public. Increased competition will result in more competitive prices for consumers, generate efficiencies and increase productivity in enterprises, and spur innovation in the gTLD space.

The proposed gTLD, .fly, will provide a new online structure for the aggregation of air travel-related content. As an alternative to existing second-level domains, Charleston Road Registry anticipates that the .fly gTLD will increase competition among registrars by allowing for further product and pricing differentiation opportunities when offering second-level domains in the gTLD. Charleston Road Registry expects that the aggregation of air travel related content in the .fly gTLD will foster increased competition among all air travel providers by facilitating user comparison of options and prices. Charleston Road Registry also anticipates the .fly gTLD may contribute to an increase in online advertising given the specific nature and purpose of the domain. Entities will compete to advertise their goods and services and reach a targeted audience of air travelers.

Managing this namespace will allow Charleston Road Registry to provide to registrars and registrants the high level of technical operations quality and service for which Google is known, which in turn will incent other existing and new gTLDs to improve the quality of their offerings.

Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines and fully complying with the Registry Operator Code of Conduct. Charleston Road Registry is committed to treating all registrars equitably and will not offer preferential treatment to Google in its capacity as registrar.

18.b.ii.2. Differentiation

Charleston Road Registry believes in the commercial viability of alternatives to existing gTLDs such as .com and .net.

The proposed gTLD will provide the marketplace with an authoritative space for registrants to deliver content, imparting brand differentiation not currently available in the current gTLD space. It also delivers value to the Internet public by defining the meaning of the gTLD term, providing for the verification of registrants who will offer content in the proposed gTLD environment, and encouraging a specific use. These activities differentiate the proposed gTLD space in a new and meaningful way.

The .fly gTLD will provide a new mechanism whereby verified airlines, travel agencies, and travel re-sellers can enact second-level domains that offer air travel-related products and services. This signification is not currently available in the gTLD space.

In addition, given its association with Google, Charleston Road Registry offers a unique value proposition to registrars and registrants resulting from the strength of Google’s trusted brand, technical leadership, and support for free speech on the Internet. Registrars will have the opportunity to leverage this brand in devising their own market positions.

18.b.ii.3. Innovation

The proposed gTLD will foster innovation by creating a new space for the categorization and classification of online content. It will therein provide a mechanism by which registrars and registrants can better brand and manage their online presence by associating it with the .fly namespace. This namespace delivers value to the public through the provision of new and differentiated content, goods, and services to Internet users.

The proposed gTLD, .fly, will promote innovation among registrars by opening the possibility for verified airlines, travel agencies and travel resellers to own second-level domains in which they can deliver content related to air travel to the Internet public. This provides registrars with the opportunity to create and offer tailored new products and services that benefit registrants and⁄or improve user experience in association with the registration of a second-level domain in the .fly gTLD. The proposed gTLD aspires to become an authoritative online resource for air travel. In addition, broad adoption of the .fly gTLD will likely invite user comparison among second-level domain sites. This will encourage second-level domain registrants to innovate and improve upon their offerings as a point of differentiation.

Charleston Road Registry considers the proposed gTLD to be a platform for innovation with existing and future Google products and services. Charleston Road Registry, therefore, may incorporate these new offerings into future registry service options (subject to the ICANN approval process), infusing new ideas into the gTLD for the betterment of the public.

Google consistently aims to improve upon technologies that connect people with information, as demonstrated by a proven record of innovation and iteration. Charleston Road Registry strives to offer its constituents this same level of continuous development in advancing its management and operation of the gTLD, engendering benefits to registrars, registrants, and end users.

18.b.iii. User Experience

Charleston Road Registry will strive to provide the highest level of user experience through operational stability, security, and performance to serve the interest of registrants in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

The proposed gTLD will provide registrants with the opportunity to differentiate their dedicated domain space such that the end users are able to discern the type of content intended to be found within the proposed gTLD. This will enable increased user visibility of registrants’ offerings, as well as provide registrants with the opportunity to enhance their respective content offerings and innovate in new ways.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the .fly gTLD can flourish. Charleston Road Registry seeks to have users deem the gTLD trustworthy and reliable and recognize it as an aggregated source of targeted goods, services, and information.

The proposed gTLD, furthermore, facilitates an improved online user experience through greater structure and categorization on the Internet.

18.b.iv. Registration Policies

Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars. Domain names within the proposed gTLD will be available to the public for registration and use.

Charleston Road Registry is committed to implementing strong and integrated intellectual property rights protection mechanisms. Doing so is critical to Google’s goals of model Internet citizenship and fostering Internet development, especially in emerging regions. Accordingly, Charleston Road Registry intends to offer a suite of rights protection measures which builds upon ICANNʹs required policies while fulfilling our commitment to encouraging innovation, competition, and choice on the Internet.

Charleston Road Registry reserves the right to impose registrant verification enforcement policies on registrars.

Charleston Road Registry believes that the .fly gTLD will best add value to the gTLD space by limiting registration to only verified airlines, travel agencies and travel resellers. Charleston Road Registry plans to require registrars to confirm that a domain applicant is an authorized seller of airline travel via an established process. If the domain applicant passes the eligibility verification process, only then will the applicant be eligible to apply for a second-level domain in the .fly gTLD. To preserve the integrity of the gTLD, Charleston Road Registry reserves the right to adopt certain monitoring measures, including periodic audits. Charleston Road Registry also reserves the right to adopt enforcement measures, including a request that registrars facilitate a user reporting method to log complaints and⁄or potential instances of misuse within the gTLD. If a registrant is found to be in violation of the terms of the registry-registrar agreement or the registrar-registrant agreement, Charleston Road Registry may request that the appropriate registrar enforce such agreements through penalties, including but not limited to suspension of the domain name.

18.b.v. Protection of Privacy and Confidential Information

Charleston Road Registry will strive to ensure the appropriate level of privacy and security will be met for its users. Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection; additional specifics regarding the practices for the registry include but are not limited to the following:

-All data transmitted from registrars to the registry will be encrypted using TLS or other similar data protection schemes to ensure that third parties cannot access personally identifying information or other sensitive data as it crosses the Internet.

- Charleston Road Registry will attempt to prevent the misuse of WHOIS data for improper purposes such as spam, intellectual property theft or phishing. Charleston Road Registry will attempt to identify patterns of abusive usage of WHOIS and will appropriately use CAPTCHA, query throttling or other techniques to prevent information scraping.

- Google will restrict access to data and information systems maintained by the registry to a specific list of individuals involved with supporting the Google Registry system in production. Google will review this list on a periodic basis to ensure that the level of access granted to individuals is appropriate. Google uses two-factor authentication and other mechanisms to ensure that staff with access to user information are properly identified prior to using registry systems.

- Google data backups stored offsite are encrypted with passwords that are securely managed on Google’s internal systems. Google can effectively remove the ability to access this data by destroying the relevant encryption password.

- Supplying Google account information will be optional for registrants unless the domain registration is directly associated with another Google product offering. Google will not disclose Google account information except for any contact information provided by the user that is required by ICANN to be displayed in response to a WHOIS query.

- Registrar billing and payment information will not be stored alongside domain name registration information. All registrar billing and payment information will be stored in a PCI-compliant billing system similar to that used by Google Ads.

- Data will not be shared with third parties without permission of registrants, except as required for registry operations or as required under the law, such as in response to a subpoena, other such court order, or demonstrated official need by law enforcement.

Beyond these specific mechanisms, both Charleston Road Registry and Google will govern its approach to privacy by the Google Privacy Policy. This policy applies to registrars, registrants and end users of registry services such as DNS zone publication and WHOIS data publication. The Privacy Policy is located at http:⁄⁄www.google.com⁄policies⁄privacy⁄.

18.b.vi. Outreach and Communications Efforts

Once Charleston Road Registry begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity to obtain domain space there through investments in marketing and public relations.

Charleston Road Registry intends to promote gTLDs in its portfolio collectively, such that the public gains an awareness and understanding of new gTLDs and the availability of new second-level domain space on the Internet. Charleston Road Registry believes that this approach will make the strongest impact in modifying consumer behavior and is the best path to achieving success for all new gTLDs collectively.

Charleston Road Registry will reach out to the Internet community via a number of different outreach and communications methods and venues to deliver its mission and message to the public, including but not limited to: press briefings, videos posted on various Internet sites, blogs and other social media, and paid advertising. In addition, when developing resources for localized Internet registrars in different global regions, Charleston Road Registry will use local marketing and communications platforms as needed.