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

Prototypical answer:

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

The .PING registry will begin with one registrant only: KMC. This will quickly expand to include a limited allocation of .PING domains to allow for testing, followed by a second allocation designed to enhance our commercial and strategic goals. Following the testing phase, we expect to allow registrations by trusted third parties, such as our distributors, who have the Required License. We believe that application for the .PING registry is in the global public interest because a .PING domain will signpost authenticity to our customers, and will be used to promote custom fitting of PING golf clubs, including unique “passive” fitting tools that PING has developed and continues to improve for internet purchasers. We want our registry to be a trusted location for genuine, accessible information about PING which will in turn support the delivery of authentic products and services valued by our customers across the world. According to U.S. Customs and Border Protection, PING is among the 100 most counterfeited brands in the world. We expect more of our customers to use the internet to interact with us and our distributors over the next decade and as a result a single, globally effective domain name for PING is beneficial to us because it will provide a more safe and reliable informational and⁄or shopping experience for our customers.

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

Our business continues its global brand expansion. It is our intention to enhance our reputation for innovation in the design and manufacture of golf clubs and accessories by utilizing the full potential of the internet. We aim to deploy new technologies that will promote our goal of having the best internet custom fitting tools that will in turn help PING grow from being one of the most recognized golf brands in the world to the most recognized golf brand in the world.

PING golf clubs were traditionally sold through “green grass” golf shops located on golf courses where club professionals could provide customized fittings. Over the past decade, KMC has expanded from this base to sell PING equipment through several carefully selected national sports or golf speciality retailers. As a result, there are now approximately 9500 PING authorized retailers in the United States alone, and hundreds more throughout the rest of the world.

PING is recognized as the global leader in custom fitting, with thousands of fitting systems at golf shops and courses around the world, a fleet of fitting vehicles that travel to scores of “Demo Days” held at golf courses and driving ranges across the nation, and a PGA-certified training program that instructs golf professionals precisely how to fit PING equipment to match the swing of each golfer.

KMC has expanded from the production of clubs into the production of PING accessories including bags, golfing apparel, mobile phone applications and a number of other premium products. KMC now has global operations including North America, Europe and the Far East.

In keeping with the age of the internet and the computer technologies that drive global innovation, KMC Affiliates have launched a range of PING nFlight Fitting Centers utilizing virtual software to provide a state-of-the-art fitting experience for golfers wishing to purchase PING equipment. Every aspect of a shot can be captured and analyzed in both indoor and outdoor testing environments so that the customer is presented with a recommendation for a full set of golf clubs including metal woods, irons, wedges, hybrids, and putters that best meets each individual golfers needs.

Through its affiliates, KMC has also introduced an iPing app for iOS devices, including the iPhone and the iPod Touch, which works in conjunction with a PING cradle. The cradle clips onto the shaft of a putter just below the grip and allows golfers to analyze their putting game by measuring stroke type, impact angle and tempo. This analysis is also used to identify which of hundreds of PING putter models and specifications best suits that individuals putting stroke.

While KMC does not sell directly to customers on-line, we have an approved network of thousands of authorized retailers, including a number of authorized internet retailers, who have demonstrated customer service skills, including superior product knowledge and a passion for custom fitting of PING equipment. We want to support each of them and help each reach new customers using our latest digital products such as our nFlight fitting service or iPing app. The retailers will benefit from presentation of these innovations under a .PING domain and consumers will benefit from having a trusted TLD through which to make their purchases and gather information about PING products and services.

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

From the launch pad of our traditional home in Phoenix, Arizona, we continue to spread our network of distributors and retailers as we expand our client base across the globe. In doing so, we continue to differentiate ourselves from our competitors through custom fitting and through innovation in the design and manufacture of golf equipment. We also aim to pull away further from the pack by applying these same industry leading tools to customers using the globally accessible internet, all of which is consistent with ICANN’s guidance that new GTLDs should “diversify the namespace, with different registry business models and target audiences.”

We want our .PING registry to provide us with a secure and stable foundation for our online expansion while enabling us to protect our consumers and intellectual property in traditional and new markets. With the phenomenal growth of the internet showing no sign of abating, we envision a future where hundreds of thousands of PING customers benefit from using .PING domains as we expand the registry from its “Single Entity” beginnings to a selectively licensed community of retailers who share our passion for the PING brand, and for providing PING customers outstanding service and custom fitting experiences.

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

Regardless of the geographic location of our customers and the PING products or services they are interested in, we hope that once they find content under a new .PING domain, they will know they have arrived at a safe and reliable destination. It is a regrettable fact that anyone, including infringers selling counterfeit goods or knock-off products, can register any variation or multiple variations of our brand PING under a .com domain and⁄or any other existing generic or country code top-level domains. While ICANN’s innovative UDRP policy has proved to be a helpful tool, it is not able to prevent infringing activity, nor can it be deployed in time to prevent consumers from being duped, since the UDRP process can take up to 90 days and cyber squatters are free to associate infringing content shortly after registration. It is believed that consumers will come to know and trust the .PING domain space, as they do PING products today, and therefore will, over time, become the target of fewer online counterfeiters who use other gTLD spaces.

With mobile devices overtaking personal computers as the most common web access device in recent years, we also want our customers to gain access to our products and services from any type of device, and with fewer clicks. This means the opportunity to learn more about genuine PING products and services from us or to order equipment or accessories from our distributors or retailers.

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

While PRP will be the operator of the .PING registry, it will do so under a support agreement with KMC which will provide technical, employee, legal, and other support. The KMC domain name management team will be responsible for the development, maintenance and enforcement of the .PING Domain Management Policy. This policy will define the rules associated with eligibility and domain name allocation and will describe the dispute resolution policies for the .PING gTLD. This policy is intended to be updated and revised regularly to reflect KMC’s commercial, strategic, and philanthropic interests and, whenever appropriate, ICANN consensus policies.

Registration of a .PING domain name will be undertaken in four steps: Eligibility Confirmation, Naming Convention Check, Acceptable Use Review, and finally Registration.

Each applied for character string must conform to the .PING registry rules of eligibility. Each .PING name must:

• Be at least 3 characters and no more than 63 characters long
• Not contain a hyphen on the 3rd and 4th position (tagged domains)
• Contain only letters (a-z), numbers (0-9) and hyphens or a combination of these
• Start and end with an alphanumeric character, not a hyphen
• Not match any character strings reserved by ICANN
• Not match any protected country names or geographical terms

Internationalized domain names (IDN) may be supported in the .PING registry at the second level.

.PING domains must be used solely for purposes that enhance KMC’s strategic, commercial, or philanthropic interests. .PING domains may not be used in a way which knowingly infringes any third-party intellectual property rights or gives rise to moral or public order questions.

All .PING domains will carry accurate and up to date registration records.

The KMC domain name management team may revoke a .PING domain name at any time in line with KMC’s strategic, commercial, or philanthropic interests.

The .PING registry will be ICANN compliant: the registry will interface with the Trademark Clearinghouse, operate a Sunrise and IP Claims service and all registrants must comply with the UDRP and the URS.

Will your proposed gTLD impose any measures for protecting the privacy of confidential information of registrants or users?

We know that PING customers care how their information are used and shared, and we will make great efforts to ensure that such information is handled carefully and sensibly. The .PING registry plans to implement appropriate privacy and security standards to protect any personal information held in the .PING registry, though we have no current plans to allocate second level domains to anyone outside of KMC, its affiliates, or its subsidiaries.

As the .PING registry will be maintained in the United States, all data will be processed in conformity with relevant State and federal laws and regulations.

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

PING products are frequently requested by movie and television show producers who desire an authentic, recognizable golf brand to add credibility to golf scenes in their productions. Product placements of PING® clubs have occurred in movies and television shows such as the Bill Murray movie ʺCaddyshack,ʺ the Jennifer Aniston movie ʺBounty Hunter,ʺ and the Michael J. Fox television series ʺSpin City.ʺ PING clubs are, prominently featured in the most popular golf video game in America, EA Sports ʺTiger Woodsʺ PGA Tour game.

Numerous other manufacturers have sought out the PING® brand for the purpose of co-branding their products, including Microsoft, NCR, Dell, and Cray Computers. Even Under Armour, Inc. (another famous brand) recently ran a clothing advertisement during the Super Bowl for Under Armour® golf clothing in which the PING® brand was also worn by the clothing model, Hunter Mahan. The PING® brand was recited along with BMW® and Rolex® as being associated with recognizable trademarks for high quality goods in an advertisement by Junckers appearing in HOME magazine.

There is no commercial imperative driving KMC to undertake public outreach or mass communication about its new gTLD registry under the name .PING because (1) it will be a standard, restricted, private dot brand registry: second level domains will initially be provisioned in line with KMC’s strategic goals to KMC; and (2) the registry reflects the famous PING mark which, as described above, is the subject of intense media attention and global recognition.

We intend to explore how metrics can help to measure the success of the .PING registry. We are interested in the perceptions of our global partners who distribute PING equipment and accessories towards the new gTLDs in general and .PING registry in particular.

To the extent that consumers accept “dot brand” registries, our usual communication with our consumers will naturally begin to work in the existence of the .PING domain name space in furtherance of the mission and Purpose set forth in this response to Question 18.

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