18(c) What operating rules will you adopt to eliminate or minimize social costs?
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.Online considers both its Registrants and the end-users that access .Online websites as its users. Our goal is to create a highly reliable namespace and provide an outstanding user experience to both Registrants and end-users of .Online. To that extent it is our goal to –
* Reduce ⁄ minimize any incremental costs ⁄ negative consequences imposed upon our users
* Increase ⁄ maximize the value added to our Registrants and end-users
* Ensure that the net effect of .Online on its users is that of positive value creation
In this response we explore how .Online achieves a net benefit for Registrants and End-users.
1. MINIMIZING COSTS
It is our goal to provide Registrants of .Online incremental value and minimize any negative consequences and costs associated with .Online. We address this in the following manner
1.1.1 SUNRISE, TMCH, RPMs
Rights protection is a core goal of .Online. Our Right Protection mechanisms go significantly above and beyond the mandatory RPMs ensuring protection of trademark and IP rights of domain registrants and reducing the costs associated with rights protection for Registrants. Our elaborate RPMs are described in significant detail in our response to Q29. Some salient aspects of these are as follows -
* We offer a sunrise period to provide an opportunity for legitimate Registrants to block domain names in .Online before general availability begins, preventing unnecessary post-facto litigation
* We will integrate with the Trademark Clearing House in the manner prescribed to provide the Trademarks claims service, so as to alert potential Registrants of any trademark violations prior to registration, as well as notify mark holders of potential mark violations
* We will provide SDRP, URS, UDRP and PDDRP reducing litigation costs by providing legitimate Registrants the opportunity to resolve disputes through standardized arbitration proceedings.
* Additionally we have pioneering RPMs like Optional Trademark Declaration, Profiling and Blacklisting, Proactive Quality assurance, APWG review etc – all intended to reduce rights violations and hence reduce costs for Registrants
The above salient points barely scratch the surface in detailing the steps that .Online will take in order to reduce costs of Registrants with respect to rights violations. Significant details of all of the above and more are provided in our responses to Q26, Q27, Q28 and Q29.
1.1.2 MULTIPLE APPLICATIONS FOR A DOMAIN
All of the RPMs described in section 1.1.1 above ensure that applicants for domain names in .Online are legitimate right holders for the applied string.
During general availability domain names will be allocated on a first come first serve basis amongst applicants. During the initial registry launch periods of Sunrise and Landrush if multiple applications for the same domain name are received from applicants then the same will be distributed in the following manner –
* Incase of multiple sunrise applications for the same domain name, all applications will be validated against the TMCH for a valid trademark. Applications that do not qualify will be dropped.
* All remaining applications will be distributed through a fair auction.
1.1.3 COST BENEFITS FOR REGISTRANTS
The ICANN new gTLD program marks a historical event in the timeline of the Internet. It is an unprecedented event and one that will yield tremendous benefits for consumers. At this preliminary stage it is impossible to determine the true value consumers will derive from increase in competition and choice. However there is historical data to go by. Upon the launch of Domain Registrars and creation of competition amongst registrars, the Registrants benefited from reduced pricing.
With .Online our goal is to provide fair pricing for domains within .Online that reflect the value proposition derived by the Registrants of .Online. While we do not have any committed pricing plans as yet and the same will be determined during the launch process, we do anticipate providing promotional offers through the life of .Online for the purpose of customer acquisition. This is not too dissimilar from other gTLD registries currently in existence who offer ongoing promotional offers to their customer base.
1.1.4 PRICE ESCALATIONS
The ICANN new gTLD program is an unprecedented event and the actual nature of pricing pressures will only be determinable once several TLDs have successfully launched. At this preliminary stage it is impossible to commit to any pricing strategy on our part. We strongly believe that ultimately, the open market will determine the viability of pricing models and dictate pricing strategy for everyone. We intend to maintain the freedom to set pricing to accommodate for the existence of 100s of TLDs and business models and create a sustainable long term business model. Our goal is to provide fair pricing for domains within .Online that reflect the value proposition derived by the Registrants of .Online.
1.2 END USERS
It is our goal to provide end users of .Online incremental value and minimize any negative consequences and costs associated with .Online. We address this in the following manner
End-users bear a considerable amount of cost as a result of various forms of Internet abuse such as spam, malware, phishing, pharming, hacking, identity theft etc. Any TLD that implements policies and processes to create a clean namespace will result in a considerable reduction of these forms of abuse and hence a significant saving in terms of cost to consumers
.Online intends to set an example when it comes to abuse mitigation and preventing abuse within .Online. To this effect we have created unprecedented Abuse mitigation policies and Rights protection mechanisms that go significantly above and beyond mandatory requirements and common practice. These are detailed in our response to Q28. We strongly believe these practices will result in a significant reduction in online abuse and considerable savings for end users of .Online. We similarly hope to set an example for other TLDs and cooperate with the industry in creating a clean internet experience for internet users.
2. COST BENEFIT ANALYSIS
There has been considerable debate within the community concerning the cost benefit analysis of launching new gTLDs. We strongly believe that the launch of new gTLDs and our implementation of .Online will and add considerable value and result in a net positive effect on Registrants and end-users worldwide.
We recognize that there will be a post launch review of the New gTLD Program, from the perspective of assessing the relative costs and benefits achieved in the expanded gTLD space.
To this extent we would like to offer the following pointers concerning .Online as well as the general expansion of the new gTLD space in determining the net positive value generated for Registrants and end users –
* .Online will reduce overall cost for end-users in combating fraud and other forms of online abuse by implementing pioneering processes and anti-abuse policies as described in our response to Q28. Billions of dollars are spent worldwide combating various forms of fraud such as malware, phishing, spamming etc. Our abuse policies will result in overall reduction of these forms of abuses within .Online resulting in a considerable reduction in global costs spent towards combating these abuses. We also strongly believe that introduction of new gTLDs will result in increased competition which will drive significant innovation as well as competitive pressures for everyone in the industry to improve their abuse mitigation processes resulting in overall cost reduction for end-users
* The value of a Registrant getting the name they want is immeasurably larger than any costs resulting from expansion of the namespace. DotOnline Inc. is a subsidiary within the Directi Group which owns and operates several ICANN Accredited Registrars. Our stats show that 70% of the users who check for a .com domain name do not get their desired name. Until this launch of the new gTLD program there were very limited alternatives and none very viable⁄desirable for Registrants to choose from. .Online will expand the namespace thus providing a higher probability for new Registrants to obtain names they desire
* In general increased competition always results in pricing benefits for Registrants. .Online will provide additional options to new Registrants resulting in overall benefits to Registrants
This completes our answer to Q 18(c)
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