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18(a) Describe the mission/purpose of your proposed gTLD

gTLDFull Legal NameE-mail suffixDetail
.yellowpagesTelstra Corporation Limitedsensis.com.auView
THE MISSION AND PURPOSE OF THE NEW RESTRICTED .YELLOWPAGES gTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST, CONVENIENCE AND UTILITY.

The .yellowpages gTLD will create a new generation gTLD serving the interests of end users by providing an authoritative Internet space where information, services and resources of the Yellow Pages brand and its affiliates and partners that are associated with the brand will be closely controlled by Telstra Corporation Limited (Telstra) and its wholly-owned subsidiary Sensis Pty Ltd (Sensis). The majority of the anticipated domain name registrations in the .yellowpages gTLD will be used in the promotion and communication of the Yellow Pages brand and its advertising and directory services. A subset of domain names has the potential to be created and used for communication and marketing purposes, with internet users assured of brand authenticity.

The first Yellow Pages directory using yellow paper was launched in 1975. The Yellow Pages directory was initially published and distributed by Telstra and is currently under the management of Sensis. Telstra is Australia’s leading telecommunications and information services company, with some of the best known brands in the country including the Yellow™ and Yellow Pages® brand. Telstra offers a full range of services and competes in all telecommunications markets throughout Australia, providing over 8 million Australian fixed line and 12 million mobile services. Telstra is also listed on the Australian Securities Exchange and generated a sales revenue of AUD25 billion for FY2011. Telstra and its international businesses employ over 39,000 people across Asia Pacific, North America and Europe. Its main activities include the provision of:

- basic access services to most homes and businesses in Australia;

- management of business customers’ IT and telecommunications services; and

- advertising, search and information services (through Sensis).


Arguably Australia’s leading information resource, Sensis helps Australians find, buy and sell by providing an integrated network of local search and digital marketing solutions such as the Yellow Pages®, White Pages® and CitySearch services. Over 12 million Australians use a Sensis service every month. Sensis currently manages the Yellow Pages® print, online and mobile directories and applications and voice services. Sensis seeks to maintain and build its position as Australia’s top provider of directories and local search services through the Yellow Pages® directory by focusing on building on its range of digital marketing services and its growth in new markets.

Every year, Yellow Pages® print directories are delivered to millions of homes and businesses across 6 metropolitan areas in Adelaide, Brisbane, Hobart, Melbourne, Perth and Sydney in Australia. With an extensive suite of digital products, about 4.5 million searches were made across Australia each week with yellowpages.com.au in 2010. When people need to find a business, they turn to the Yellow Pages® brand. The Yellow Pages® brand offers great opportunities to connect with people who are ready to buy and helps its users choose an advertising solution appropriate for their business. The Yellow Pages® products are all about connecting businesses with customers. In this regard, brand promotion and customer engagement are paramount considerations in Telstra’s application for .yellowpages.

These days, business activities are increasingly conducted over the internet, allowing for greater levels of interaction between businesses and customers. As a result, both businesses and end users benefit from ease of interaction and a wider range of choices with lower transaction costs. However, the development in this arena in the current domain name system has exposed both businesses and consumers to increased criminal activities over the internet, including data breaches, hacking and phishing. These sophisticated criminal activities cause reputational damage to businesses as internet users lose consumer confidence and trust with the businesses targeted by such criminal activities. The .yellowpages gTLD will facilitate greater trust and assurance from internet users connecting with Telstra and Sensis online, whilst still allowing convenient and efficient interaction.

Telstra’s mission and purpose of the proposed new gTLD share ICANN’s initiatives to promote public interest. Telstra is committed to contribute towards achieving such initiatives in line with ICANN’s Affirmation of Commitments, which includes:

- consumer trust: the .yellowpages gTLD registry will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to Telstra and Sensis, at this stage, which will provide added consumer trust that .yellowpages domain names are trustworthy. As .yellowpages domain names are subject to registration standards, policies and procedures under Telstra’s control, this eliminates the possibility of malicious conduct within the .yellowpages domain space;

- competition: the proposed new gTLD is anticipated to contribute to ICANN’s initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in the .yellowpages gTLD will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and

- consumer choice: the proposed new gTLD will enable user-driven improvements and innovations assisting Sensis and Telstra’s marketing efforts through its ability to create new second and third level domain names on demand. These names will provide consumers with more choices for interacting with Sensis and Telstra. As Telstra has effective control over the registration and use of domain names under the .yellowpages domain space, this will also contribute towards general service innovations on the internet.


Given the restricted nature of the .yellowpages gTLD, the projected number of registrations is likely to be limited. It is anticipated that approximately 500 domain names will be registered in the first year. However, over the next few years, the number of registrations is likely to increase to about 1000 domain names as Telstra and⁄or Sensis on its behalf develop and implement domain names in the second or third level of the .yellowpages gTLD into its suite of products and services and marketing campaigns.


Telstra believes that the .yellowpages gTLD is unlikely to cause confusion with either a generic term or any existing TLDs. Telstra is a leading global brand with a significant reputation in Australia as its leading telecommunications and information services company. Telstra has an extensive portfolio of Australian Yellow™ and Yellow Pages® trademarks including registrations for “Yellow Pages” and images including “Yellow Pages” in Australia for classes such as Computer software, publications in electronic form including those supplied online (9); Paper goods and printed matter (16); Advertising and business including over the internet (35); Telecommunications (38); Electronic publication of information (41); Website design and computer software design services and directory goods in electronic and non-electronic form (42) and Registration of domain names (45).

Further, Telstra has 3 domain names with an exact match to the applied-for .yellowpages string and its “Yellow Pages” trademark in yellowpages.com.au, yellowpages.asia and yellowpages.net.au and 25 domain names containing .yellowpages in spaces such as yellowpages-victoria.com.au, yellowpagesdeals.com and yellowpagesaustralia.com.au.
gTLDFull Legal NameE-mail suffixDetail
.limitedBig Fest, LLCdonuts.coView
Q18A SVC CHAR: 7572

ABOUT DONUTS
Donuts Inc. is the parent applicant for this and multiple other TLDs. The company intends to increase competition and consumer choice at the top level. It will operate these carefully selected TLDs safely and securely in a shared resources business model. To achieve its objectives, Donuts has recruited seasoned executive management with proven track records of excellence in the industry. In addition to this business and operational experience, the Donuts team also has contributed broadly to industry policymaking and regulation, successfully launched TLDs, built industry-leading companies from the ground up, and brought innovation, value and choice to the domain name marketplace.

ABOUT DONUTS’ RESOURCES
Donuts’ has raised more than US$100 million from a number of capital sources for TLDs. Our well-resourced, capable and skilled organization will operate these TLDs and benefit Internet users by:

1. Providing the operational and financial stability necessary for TLDs of all sizes, but particularly for those with smaller volume (which are more likely to succeed within a shared resources model);
2. Competing more powerfully against incumbent gTLDs; and
3. More thoroughly and uniformly executing consumer and rights holder protections.

THE .LIMITED TLD
This TLD is attractive and useful to end-users as it better facilitates search, self-expression, information sharing and the provision of legitimate goods and services. Along with the other TLDs in the Donuts family, this TLD will provide Internet users with opportunities for online identities and expression that do not currently exist. In doing so, the TLD will introduce significant consumer choice and competition to the Internet namespace – the very purpose of ICANN’s new TLD program.

This TLD is a generic term and its second level names will be attractive to a variety of Internet users. Making this TLD available to a broad audience of registrants is consistent with the competition goals of the New TLD expansion program, and consistent with ICANN’s objective of maximizing Internet participation. Donuts believes in an open Internet and, accordingly, we will encourage inclusiveness in the registration policies for this TLD. In order to avoid harm to legitimate registrants, Donuts will not artificially deny access, on the basis of identity alone (without legal cause), to a TLD that represents a generic form of activity and expression.

The .LIMITED TLD will be attractive to a very broad and diverse group of registrants that may include companies and non-profits in multiple international and intra-country jurisdictions that use the “limited” term as a corporate or organizational identifier. It would be further available to companies in jurisdictions that may later adopt this moniker. The “limited” term is widely utilitarian, as evidenced by various international applications—for example, separate from their context as incorporated entities, organizations have used the “limited” term to refer to various products and services (in the case of the known clothing retailer, we would work to reserve certain names that arguably could interfere with the rights of that entity). Commensurate with its applicability as a dictionary term, its potential user set is wide, and the TLD would be appropriately inclusive. We would operate this TLD in the best interests of entities in all jurisdictions and in a secure and legitimate manner.

DONUTS’ APPROACH TO PROTECTIONS
No entity, or group of entities, has exclusive rights to own or register second level names in this TLD. There are superior ways to minimize the potential abuse of second level names, and in this application Donuts will describe and commit to an extensive array of protections against abuse, including protections against the abuse of trademark rights.

We recognize some applicants seek to address harms by constraining access to the registration of second level names. However, we believe attempts to limit abuse by limiting registrant eligibility is unnecessarily restrictive and harms users by denying access to many legitimate registrants. Restrictions on second level domain eligibility would prevent law-abiding individuals and organizations from participating in a space to which they are legitimately connected, and would inhibit the sort of positive innovation we intend to see in this TLD. As detailed throughout this application, we have struck the correct balance between consumer and business safety, and open access to second level names.

By applying our array of protection mechanisms, Donuts will make this TLD a place for Internet users that is far safer than existing TLDs. Donuts will strive to operate this TLD with fewer incidences of fraud and abuse than occur in incumbent TLDs. In addition, Donuts commits to work toward a downward trend in such incidents.

OUR PROTECTIONS
Donuts has consulted with and evaluated the ideas of international law enforcement, consumer privacy advocacy organizations, intellectual property interests and other Internet industry groups to create a set of protections that far exceed those in existing TLDs, and bring to the Internet namespace nearly two dozen new rights and protection mechanisms to raise user safety and protection to a new level.

These include eight, innovative and forceful mechanisms and resources that far exceed the already powerful protections in the applicant guidebook. These are:

1. Periodic audit of WhoIs data for accuracy;
2. Remediation of inaccurate Whois data, including takedown, if warranted;
3. A new Domain Protected Marks List (DPML) product for trademark protection;
4. A new Claims Plus product for trademark protection;
5. Terms of use that prohibit illegal or abusive activity;
6. Limitations on domain proxy and privacy service;
7. Published policies and procedures that define abusive activity; and
8. Proper resourcing for all of the functions above.

They also include fourteen new measures that were developed specifically by ICANN for the new TLD process. These are:

1. Controls to ensure proper access to domain management functions;
2. 24⁄7⁄365 abuse point of contact at registry;
3. Procedures for handling complaints of illegal or abusive activity, including remediation and takedown processes;
4. Thick WhoIs;
5. Use of the Trademark Clearinghouse;
6. A Sunrise process;
7. A Trademark Claims process;
8. Adherence to the Uniform Rapid Suspension system;
9. Adherence to the Uniform Domain Name Dispute Resolution Policy;
10. Adherence to the Post Delegation Dispute Resolution Policy;
11. Detailed security policies and procedures;
12. Strong security controls for access, threat analysis and audit;
13. Implementation DNSSEC; and
14. Measures for the prevention of orphan glue records.

Further, due to the multi-jurisdictional aspect of this string, Donuts will provide appropriate authorities with the capability to make designations in the Whois record relevant to the registrant’s organizational establishment in that jurisdiction.

DONUTS’ INTENTION FOR THIS TLD
As a senior government authority has recently said, “a successful applicant is entrusted with operating a critical piece of global Internet infrastructure.” Donuts’ plan and intent is for this TLD to serve the international community by bringing new users online through opportunities for economic growth, increased productivity, the exchange of ideas and information and greater self-expression.