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

Prototypical answer:

The proposed .CASINO gTLD will benefit registrants, Internet users and others by, among other reasons, providing a legally-compliant name space wherein users can come to find legally-allowed on-line gaming, recognizing that on-line gaming laws vary from jurisdiction to jurisdiction; as such, .CASINO websites will not be available in all geographic areas, and any on-line gaming available at a .CASINO website may vary from jurisdiction to jurisdiction as required by applicable jurisdictional law. The proposed .CASINO gTLD will further benefit registrants, Internet users and others by promoting consumer trust by providing a gTLD operated in a professional and commercially reasonable manner by an experienced management team, powered by an experienced back end registry provider (Minds + Machines) and under the stewardship of Rock Gaming LLC and its affiliates (“Rock Gaming”).

Awareness of the existence of the .CASINO gTLD will also benefit Internet users -- such awareness will create new choice within the DNS for how to access and locate on-line gaming and on-line gaming related information and services. Users will also benefit from the limited, legally-compliant nature of the .CASINO space. Users can be confident that a domain in the .CASINO gTLD has Rock Gaming as its registrant, and any content is consistent with the stated mission⁄purpose of the gTLD.

1. The goals of the .CASINO gTLD in terms of areas of specialty, service levels and reputation.

A goal of the .CASINO gTLD is to provide legally-compliant on-line gaming, providing people a greater choice for accessing on-line gaming. In its partnership with Caesars Entertainment in developing and operating full-service casinos in downtown Cleveland and Cincinnati, Ohio, Rock Gaming has, and continues to build, its specialty in casino⁄gaming operations. It is Rock Gaming’s goal to extend this area of specialty to operation and use of .CASINO websites. In this regard, Rock Gaming anticipates that the same level of casino⁄gaming specialty associated with Rock Gaming’s licensed and regulated operation of physical casinos in Ohio will cross over to on-line casinos and on-line gaming offered via the .CASINO gTLD.

In terms of service level goals, it is DotCasino’s goal for users to experience robust DNS industry standards for technical back-end operations, including but not limited to near 100% uptime; timely zone file dissemination; searchable WHOIS capabilities; and additional security measures such as for DNS Security Extensions (DNSSEC).

In terms of reputation, it is Rock Gaming’s goal to provide a gTLD that upholds Rock Gaming’s regulatory compliance and further provides jurisdictionally-specific and legal on-ling gaming, and it is DotCasino’s goal to provide a gTLD operated (and recognized as being operated by users) in a professional and commercially reasonable manner by an experienced management team and powered by an experienced back end registry provider.

2. What the .CASINO gTLD will add to the current space in terms of competition, differentiation and innovation.

Creation of .CASINO will provide competition to existing TLD’s in the form of new name space for provision of on-line gaming.

Limiting registrations to Rock Gaming, with Rock Gaming’s commitment regarding the legality of on-line gaming at .CASINO websites, inherently brings differentiation and innovation to the .CASINO gTLD. Rock Gaming, in its capacity as a regulated casino operator, is appropriately situated to ensure that on-line content at .CASINO will be limited to .CASINO’s mission and purpose; namely, provision of legal on-line gaming, and the consistency of such websites will provide further differentiation. Rock Gaming has the depth, reach, and expertise to provide a consistently legally-compliant on-line gaming experience, which will both differentiate .CASINO from its gTLD brethren and, it is anticipated, foster innovation in the .CASINO namespace. The .CASINO gTLD will evolve to become known as the legally-compliant destination for on-line gaming.

Over time, the Rock Gaming anticipates a single dedicated name space under the .CASINO gTLD, in combination with the reputation and regulated legality users associate with Rock Gaming, will resonate with users to create differentiation that otherwise could not exist in current gTLD’s. Further, provision of the .CASINO gTLD as a single-source registrant TLD (Rock Gaming) will differentiate .CASINO from other, multi-source registrant TLD’s which also allow on-line gaming.

While it is difficult to predict in exact terms what future innovation may occur as a result of the existence of the .CASINO gTLD, we expect the Rock Gaming to demonstrate the same capacity to innovate and adapt as they have shown with their various business ventures. One possible example of this innovation which the Rock Gaming intends to explore is the option of providing a hierarchical and intuitive framework for the .CASINO namespace by using geographical identifiers as second-level domain names, as described further in the answer to Question 22.

3. User experience goals of the .CASINO gTLD.

A goal of .CASINO is for users to experience robust DNS industry standards for technical back-end operations, including but not limited to near 100% uptime; timely zone file dissemination; searchable WHOIS capabilities; and additional security measures such as for DNS Security Extensions (DNSSEC).

Over time, an additional goal is for users to experience .CASINO websites as a single source for legal on-line gaming and on-line gaming related information and services. One goal Rock Gaming intends to explore is to provide on-line gaming at domains which are associated with geographic and⁄or subject matter terms and which are legally appropriate in light of applicable jurisdictional rules of law. Over time, users desiring to locate legal on-line gaming in a specific area, or on-line gaming of a particular type, will be conditioned to navigate to “geographic.CASINO” or “gametype.CASINO”. Consistent with Rock Gaming’s mission⁄purpose for the .CASINO gTLD, Rock Gaming will determine the legally-appropriate amount and type of on-line gaming allowed in any given jurisdiction, if any at all.

4. Intended registration policies in the .CASINO gTLD in support of the goals listed above.

Consistent with the stated mission⁄purpose for the .CASINO gTLD, the sole registrant of .CASINO domains will be Rock Gaming LLC and Rock Gaming LLC’s affiliates (“Rock Gaming”), as determined by Rock Gaming LLC. Rock Gaming will set forth policies and practices relating to registration and use of domains in .CASINO which are reasonably necessary for the management, operations and purpose of the gTLD in light of its stated mission⁄purpose, and which are consistent with such mission⁄purpose. Particularly, Rock Gaming will ensure that any on-line gaming at a .CASINO website will be in full compliance with all applicable jurisdictional rules of law.

Additional restrictions, policies or practices may be set forth by Rock Gaming during initial operations of the .CASINO gTLD so that the .CASINO gTLD can be launched and initially operated in a controlled manner, granting the gTLD the opportunity to fulfill its stated mission(s)⁄purpose(s), and allowing Rock Gaming the opportunity to study use of the gTLD and user adoption of the gTLD. Any such restrictions, policies or practices will also allow Rock Gaming the ability to explore and implement user experience goals noted above and to find additional ways of achieving the missions⁄purposes identified above.

Rock Gaming will periodically review progress and adoption of the .CASINO gTLD with an eye towards maintaining consistency with the gTLD’s stated mission⁄purpose and achieving the goals set forth above. Rock Gaming – in its sole discretion – may add, delete, amend or otherwise modify registration restrictions, policies and practices in support of the goals listed above, so long as the stated mission⁄purpose relating to compliance with applicable jurisdictional rules of law is maintained. Rock Gaming may also adopt use policies consistent with the principles set forth herein.

5. Measures for protecting the privacy and confidentiality of registrants and users.

Applicant does not at this time propose any measures for protecting the privacy of confidential information of registrants or users of .CASINO domain names, outside of what is required under applicable statute, contract or law.

6. Outreach and communications which will help achieve projected benefits.

The primary outreach and communications that will occur for .CASINO will be through Rock Gaming and its related entities through existing channels of communication. Over time, DotCasino expects these existing channels of communication to produce widespread awareness for .CASINO.

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