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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
.EVERBANKEverBanksteptoe.comView
(i)Specialty-
Improved security is arguably the most attractive benefit of the registry for Internet users. Presently, there is no top-level domain dedicated to banking and financial services, and no top-level domain dedicated to Applicant’s brand. The goal of the TLD, in terms of specialty, is for Applicant to securely and uniquely provide a top-level domain dedicated to providing banking and financial products and services to customers and Internet users across the country under its highly recognized and trusted brand. Allowing Applicant to control its own Internet space for its highly recognized brand gives it the ability to customize its domain and website names and signal to the general population of Internet users that websites within the TLD will indeed be securely controlled by Applicant. This specialty will benefit Internet users seeking secure online banking and financial services who will be able to bank with greater confidence as we greatly reduce the possibility that our customers will become the next phishing victim or subject to the numerous other malevolent schemes currently perpetrated from and through domains bought on the open market.
Navigation to Applicant and affiliate sites will be more efficient. Users will know that .EVERBANK sites are operated by Applicant and are a reliable source of information about all EverBank Financial Corp companies. Applicant’s exclusive access to keyword domain names will be mutually beneficial for Internet users and affiliates, as users may tie the keyword service to affiliate providers. Searches for the TLD will quickly yield Applicant sites. Shorter domain names, which would be feasible with the new TLD, will also increase navigational efficiency for users. Built into a wider process of web optimization and marketing, the inclusion of the TLD as a keyword in every domain name will likely have positive implications for specialty, security, and national promotion purposes. This will increase traffic to these websites, promote competition, and facilitate use and trust by banking and financial service consumers who prefer shorter domain names and want a trusted source of the specific services they seek.
Service Levels-
The goal of the TLD will be to ensure that the highest level of security, quality, and customer service levels are provided to Applicant and its affiliates’ financial services customers, for whom security is a high priority. Applicant will exercise tight control over domain ownership and limit distribution of the domains to related entities and agents. Applicant is contracting with proven industry experts to provide the highest possible quality in registry and registrar services for maximum security and stability to protect the highly confidential information that Applicant’s customers will provide through use of the sites associated with the TLD.
Applicant will further endeavor, as is currently done on Applicant and affiliate websites, to provide for any outwardly-facing domain name and website in the TLD, Customer service that will be available by email and phone 24 hours per day, 7 days per week to instantly help any customer attempting to learn about or utilize Applicant’s services. Similarly, Applicant will provide the highest level service to trademark, copyright, and other legal rights owners by providing an easily accessible point-of-contact on any outwardly-facing domain names and websites.
In addition, despite the fact that Applicant will operate a tightly controlled, closed registry, in which only it and its corporate affiliates will be permitted to register second level domains, Applicant is keenly aware of its responsibility as a financial institution to enact policies and procedures designed to minimize the possibility of abusive registrations and other activities that have a negative impact on Internet users in the TLD, and which maximize the security and stability of the TLD. Applicant’s strong commitment to this goal is demonstrated, among other things, by its adoption of several of the requirements proposed in the 2011 Proposed Security, Stability and Resiliency Requirements for Financial TLDs (i.e., the BITS Requirements, available at http:⁄⁄www.icann.org⁄en⁄news⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf). These standards were developed by the financial services sector for financial TLDs, and Applicant believes that adhering to these standards will result in a more robust approach to combating abuse. The specifics of this approach are set forth in response to Question 28.
Reputation-
Applicant already has a reputation for excellence, superior quality, and the highest level of security in the banking and finance industry, including online through its current websites and domain names. As noted above, Applicant already has an award-winning online track record. It intends to enhance Web services through use of the new TLD. As financial websites are among those with the highest exposure in connection with fraudulent online activity, Applicant seeks through the operation of the TLD to provide the most secure online environment in the industry, to enable Internet users to feel secure in providing highly sensitive personal information to Applicant and its affiliates. The goal of the TLD is to further enhance Applicant’s reputation for excellence and high levels of security and to advance and enhance technical capabilities.
Applicant will strive to ensure that the TLD is known for being tightly controlled, by ensuring only Applicant’s employees, agents, subsidiaries, affiliates, or related companies register domain names in the TLD, that those domain names are used for Applicant-related purposes, that the WHOIS is thick and reliable, and that the Registry is responsive to legal rights owners. Indeed, when Internet users visit a website within the TLD, they should know that Applicant will be the entity providing its nationally-renowned services, and that they can expect the highest level of online service and security. In all, Applicant will strive to be known as an exemplary and model domain name services citizen through the controlled use of the TLD.
(ii)Competition-
The TLD will enhance competition in the current Internet space. Through Applicant’s control of its own Internet space, and the flexibility to innovate and create new ways of accessing its ever-evolving online products and services, Applicant’s customers will experience a new level of service. These innovations will motivate competitors’ with existing and new top-level domains to improve the security and quality of the banking and financial products and services they provide online and to accelerate the introduction of new products and services in order to continue attracting new customers. Thus, the TLD will benefit consumers by increasing the likelihood of new and innovative online products and services in a more secure environment.
Differentiation-
The most obvious differentiation will be the TLD itself: it will be solely composed of Applicant’s unique service mark. Internet users will immediately know the source of the sites featuring the TLD. Indeed, no other top-level domain is similar in appearance to the TLD, none is used exclusively for banking and financial goods and services, and none exclusively serve Applicant’s users and customers. In terms of differentiated uses, Applicant will have the flexibility to customize the second-level domains within the TLD so as to signify the service offered as well as the source of the service. Finally, unlike in existing top-level domains, only Applicant’s employees and affiliated companies and agents will be allowed to register and⁄or operate domain names within the TLD, thus enabling the TLD to become unique in that customers do not have to fear corruption, weak security, malicious code, malware, spam, phishing or false or inaccurate information, and thereby allowing Applicant to become a more trusted provider of online banking and financial products or services.
Innovation-
Applicant is already a recognized leader in online banking and financial innovation. Of paramount importance to financial services customers is security. Ownership of the TLD will allow Applicant to impose higher security standards, to provide information, products and services to customers in a more secure and technologically advanced way and allow Applicant to implement technological advances with greater flexibility.
Indeed, Applicant believes that the TLD will open up new opportunities not yet imagined, and permit Applicant to innovate new services in a truly secure environment.
(iii) Applicant will strive to test, develop, and implement the TLD and associated websites to anticipate its customers’ Web needs and expectations in the most secure manner. Applicant will take great care to ensure that domain names in the TLD will primarily serve the Internet user by being intuitive and practical. Applicant will rely on its consumer and security-driven testing to provide a targeted user experience for those seeking robust, reliable, and secure online banking and financial products and services across the country and eventually perhaps even around the world. Because users will know that all domain names in the TLD will be owned and operated by Applicant, Applicant anticipates that the TLD will eventually provide an enhanced and secure online technological experience for those interested in obtaining more information about conducting online banking and financial transactions and purchasing Applicant’s products and services. Finally, the TLD will serve to differentiate Applicant from other banking and financial institutions and serve to create a more stable, competitive, and active marketplace.
(iv)To support the goals for the TLD, only Applicant, its affiliates, and its authorized and designated employees or agents, will be allowed to register domain names within the TLD. Accordingly, the general public will never be allowed to register, buy, or sell domain names in the TLD. Applicant, does however, reserve the right to sell, distribute, or transfer control or use of any registrations in the TLD to any third party that is an Affiliate of Applicant or is an agent of Applicant or of its Affiliates, for uses as specified by Applicant or its Affiliates. For the purposes of this application “Affiliate” is defined as (i) a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, Applicant, and (ii) “control” (including the terms “controlled by” and “under common control with”) means the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of a person or entity regarding the use of a domain name within the TLD, whether through the ownership of securities, as trustee or executor, by serving as an employee or a member of a board of directors or equivalent governing body, by contract, by credit arrangement or otherwise.
Further, as stated above, Applicant intends to operate a closed registry in order to continue to offer the high-quality secure online financial products and services it currently offers on its branded websites in existing top-level domains. Accordingly, policies and decisions regarding the registration and use of domain names within the TLD will continue to be provided through an internal team consisting of Applicant’s existing business and marketing decision-making channels.
The TLD’s domain name policies will be shaped by its abuse prevention and rights protection policies, and Applicant will strive to avoid registering domain names that are confusingly similar to third-party trademarks and related rights. Obscene, explicit, and offensive domain names will not be permitted to register in the TLD.
(v)Keeping information secure and private is of crucial importance to banking and financial institutions, whose websites are particularly vulnerable to attempts at online fraud. Initially, Applicant intends to operate a closed registry with limited domain ownership access, to ensure the security and privacy of the information available. As Applicant’s use may expand, Applicant will take all available steps to maintain the security and privacy of the information collected, and will remain in compliance with all applicable confidentiality and security regulations in relevant jurisdictions.
For example, Applicant and its Affiliates already haves Privacy Policies in place to safeguard the financial information of their respective customers. For online banking, for example, these include:
-Encryption software that ʺscramblesʺ messages in its secure web-based email system to allow account holders to communicate over a secured channel with EverBank Representatives.
-Customer authentication procedures to protect personal and account information against fraud and other Internet risks.
-Restricted access to nonpublic personal information to only those persons with a business need to know the information to process or service a customer’s account(s).
-Multiple channels of contact to allow users to discuss privacy issues or report anything unusual or inappropriate to Everbank.
For Applicant and its Affiliates’ policies in their entirety, see Privacy Policies for EverBank and its Subsidiaries, found at https:⁄⁄www.abouteverbank.com⁄privacy.aspx. When the TLD becomes public-facing such that external users are interacting with domains registered in the TLD, Applicant will, at a minimum, continue to provide similar security measures.
(vi)Applicant will create and implement marketing and outreach efforts in a variety of media to inform the public about the TLD and the information and services available there.
Applicant already uses a variety of outreach and communications methods and venues to communicate its mission and message to the public, including but not limited to, electronic mail, press releases, featured videos posted on its website, social media, including but not limited to Twitter, LinkedIn, and Facebook, various news feeds around the country, and paid advertising, which includes television and radio commercials, magazine and newspaper print, billboards and posters in major markets, and a variety of digital media. Applicant is able to incorporate the outreach and communication regarding the TLD into its current branding and marketing efforts to ensure that as many customers and users as possible understand the new resources available and how to interact with them to improve their consumer experience.
gTLDFull Legal NameE-mail suffixDetail
.esqCharleston 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 ʺesqʺ and to provide content and offerings related to law and⁄or targeted at users seeking lawyers.

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, .esq, will provide a new online structure for the aggregation of legally-related content. As an alternative to existing second-level domains, Charleston Road Registry anticipates that the .esq 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 .esq gTLD will lower barriers to entry for registrants and foster growth in the number of entities offering law-related content on the Internet, thereby increasing competition among lawyers. Charleston Road Registry also anticipates the .esq gTLD may contribute to an increase in online advertising given the law-related nature of the domain. Entities will compete to advertise their goods and services and reach a targeted audience of lawyers and⁄or users interested in content related to lawyers.

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 .esq gTLD will provide a new mechanism whereby verified lawyers and law practices can enact second-level domains that offer content related to their profession. 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 .esq 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, .esq, will promote innovation among registrars by opening the possibility for individuals and law practices to own second-level domains in which they can deliver content related to their profession 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 .esq gTLD. The proposed gTLD aspires to become an authoritative online resource for dentists. In addition, broad use of the .esq gTLD will likely invite user comparison among second-level domain sites. This will encourage second-level domain registrants to innovate and improve upon their content and⁄or 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 .esq 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 .esq gTLD will best add value to the gTLD space by limiting registration to only verified lawyers and attorneys. Charleston Road Registry plans to require registrars to confirm that a domain applicant has a law degree, has successfully completed the appropriate steps as required by their country of practice or body governing certification of lawyers and has taken and passed a bar exam or equivalent exam if required by their country of practice or body governing certification of lawyers 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 .esq gTLD. Second-level domain names in the .esq gTLD must be related to the registered individualʹs legal name or practice. 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.