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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
.siteCharleston Road Registry Inc.google.comView
18.b. Benefits to Registrants, Internet Users, and Others

18.b.i.1. Specialty

Charleston Road Registry intends to apply for an exemption to ICANN’s Registry Operator Code of Conduct and operate the proposed gTLD with Google as the sole registrar and registrant. The proposed gTLD will specifically align with Googleʹs website publishing offerings, and will provide users with improved capabilities that meet their diverse needs.

The specialization goal of the proposed gTLD is to provide a dedicated second-level domain space for Googleʹs website publishing offerings. This specialization introduces a new domain name hierarchy that will generate new second-level namespace, and provide for streamlined, internal Google management of the introduction and phase out of Google products and⁄or services within the domain.

This specialization offers Internet users Google services that will enhance their current and future experience with Googleʹs website publishing offerings. Google will manage a process whereby users will be able to make use of unique vanity names in the gTLD; such second-level domains will only point to the Google offering. This provides users with a distinctive namespace as they develop and implement a unique, customized vision for their use of Googleʹs website publishing offerings. Google strives to offer its customers cutting edge tools that will not only enable them to better personalize their respective second-level domain content, but also spur further creativity and generate new options on the Internet.

As the Internet is ever changing, these services will evolve to meet users’ needs to the benefit of the Internet public. Google seeks to continuously provide tools that solve problems faced by Internet users, and, in partnership with Charleston Road Registry, the proposed gTLD will open the opportunity for Google to provide these customer-centric solutions.

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.

Charleston Road Registry’s service level goal for the proposed gTLD is to ensure that Google, as the proposed sole registrant, is supported in delivering the high level of quality, speed, and service to users for which it is known. Indeed, two of Google’s core principles in providing Internet search and related goods and services are “focus on the user and all else will follow” and “fast is better than slow.”

In focusing on the user, Google strives to provide the best user experience possible. Google will continue to operate under this principle when designing new offerings and providing goods and services within the proposed gTLD.

Google keeps speed in mind with each new product it releases, from faster mobile applications to improved Web browsers designed for rapid search and navigation. Google continues to devote its resources to improving speed and efficiency. In managing the proposed gTLD, Google expects to keep its service reliability and speed to this standard through direct management of all technical infrastructure related to DNS resolution other than the operation of the root servers.

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

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 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 so that Google registers and manages domain names in the site gTLD, that those domain names are used for only Googleʹs website publishing offerings-related purposes, and that the registry is responsive to legal rights owners (if applicable).

As noted, Charleston Road Registry intends to apply for an exemption to ICANN’s Registry Operator Code of Conduct and operate the proposed gTLD with Google as the sole registrar and registrant. This facilitates Google’s ability to further enhance the brand and reputation of the Google offering.

In addition, Charleston Road Registry’s operation of the new gTLD will provide the opportunity for users to build and⁄or bolster their unique brands or tailor unique user identities in association with the proposed gTLD and Googleʹs website publishing offerings.

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.

Google will have the opportunity to differentiate and innovate upon its website publishing offerings, products and services through its use of the gTLD.

The proposed gTLD, .site, will provide a new mechanism whereby Google plans to offer individuals, groups and enterprises, products and services related to website publishing. Charleston Road Registry anticipates the .site gTLD will help grow the volume of user accounts of web publishing services on the Internet, thereby increasing competition among all service providers.

The proposed gTLD will promote competition in the gTLD space by inciting competitors to respond with improved gTLD operations, greater range and higher quality products and services integrated with domain name offerings, and⁄or the creation of their own respective gTLDs, to the benefit of all Internet users. Launching the proposed gTLD will also generate increased competition in the online marketplace by adding incremental availability to the second-level domain pool.

Charleston Road Registry intends to apply for an exemption to the ICANN Registry Operator Code of Conduct and to act as the sole registrar for the proposed gTLD. Given that the proposed gTLD is exclusively intended for use in connection with Googleʹs services, Charleston Road Registry believes that there is a reasonable case for such an exemption. Should ICANN not approve this proposed exemption, Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines

18.b.ii.2. Differentiation

The proposed gTLD will clearly be differentiated from other gTLDs due to its purposefully limited scope. This differentiation includes: (1) uniqueness in terms of the users the proposed gTLD seeks to benefit; (2) a clear indicator that second-level domains within the gTLD offer a particular, targeted content; (3) and because the TLD will be associated with a Google offering, Internet users will immediately be able to rely on the quality of the product.

The gTLD will provide an authoritative environment for the provision of Googleʹs website publishing offerings. New, higher quality products offered in the gTLD will also attract new users to the Google offering.

The .site gTLD will provide Google with the opportunity to differentiate its services from other service providers by virtue of its suite of offerings and branded gTLD. This signification is not currently available in the gTLD space.

The proposed gTLD will also encourage differentiation among users. Google’s services, including tools to improve and customize users’ unique Googleʹs website publishing offering experiences, will provide users with new ways of distinguishing themselves from others.

18.b.ii.3. Innovation

The proposed gTLD is in itself innovative, as it seamlessly combines DNS services with other Google products and services. The proposed gTLD will promote further innovation by creating a new space for the categorization and classification of online content. It will also provide services to users that will enable them to improve their interaction with Googleʹs website publishing offerings on the Internet. This environment delivers value to the public by introducing new and differentiated content, goods and services.

The proposed gTLD, .site, will promote innovation by encouraging competitors of Google to provide linkages to their products that fulfill the same need as Google plans to deliver to its users. Google may choose to innovate within its portfolio of web spaces and introduce distinguishing feature(s) that will further crystallize the relationship between content offered in the gTLD and the Google brand and reputation. This will likely invite user comparison among domains, encouraging other web publishing service providers to innovate new features and services 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 users this same level of continuous development in advancing its management and operation of the gTLD, engendering an improved user experience.

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 users in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; per its SEC filings, Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

Google keeps user experience in mind with each new service it releases, from allowing users to personalize their Gmail accounts to providing small to medium businesses with tools customized for their specific needs. The proposed gTLD provides Google with a formal mechanism whereby it can continue to improve its services to address the ever-changing needs of all Internet users.

The proposed gTLD, furthermore, facilitates an improved online user experience by provisioning the DNS on users’ behalf and streamlining the process by which users are able to link to and make use of the Google offering.

The proposed gTLD, .site, will provide users with an improved user experience by allowing for direct management of their respective content within the .site gTLD.

In focusing on the user, Google strives to provide the best user experience possible. Google will continue to operate under this principle when designing and providing new service offerings in the proposed gTLD. The proposed gTLD will provide users with improved customization services and facilitate additional opportunities to enhance their current and future experience with Googleʹs website publishing offerings.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the site 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.

Lastly, the proposed gTLD improves the Internet user experience by creating greater structure and categorization on the Internet.

18.b.iv. Registration Policies

Because the sole purpose of the proposed gTLD is to associate domain names with the Googleʹs website publishing offerings, Charleston Road Registry intends to apply for an exemption to the ICANN Registry Operator Code of Conduct and operate the gTLD with Google as the sole registrar and registrant. As the sole registrant, Google will have the opportunity to differentiate and innovate upon its website publishing offerings, products and services through its use of the gTLD.

Given the proposed limited scope and use of the gTLD, Charleston Road Registry believes that there is a reasonable case for such an exemption. Should ICANN not condone this proposed exemption, Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars.

Google will manage a process whereby users will be able to make use of unique vanity names in the gTLD; such second-level domains will only point to the Googleʹs website publishing offerings.

Charleston Road Registry believes that given its specific use, the .site gTLD will best add value to the gTLD space by limiting all second-level domains to the sole use of pointing to Googleʹs web publishing suite of offerings. In addition, only entities and individuals with a Google log-in or who register for a new account will be eligible for a second-level domain within the gTLD.

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.

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. Although Google will be the only registrant (and is intended to serve as the only registrar for the gTLD as well), Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection for their users; additional specifics regarding the practices for the registry include but are not limited to the following:

- Since Google will be the only registrant, personally identifying information regarding individual users will not be sent to or stored by the registry. Such data will remain on Google’s infrastructure used to provide the individual service, and is subject to Google’s existing privacy policy.

- 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 the WHOIS service 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.

- In the event that other registrars are involved, 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.

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 Google begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity for users to obtain domain space there through marketing and public relation investments.

Charleston Road Registry, in conjunction with Google, intends to promote gTLDs under its purview 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 and Google believe 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 and Google 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, Google will use local marketing and communications platforms as needed.