18(c) What operating rules will you adopt to eliminate or minimize social costs?
|gTLD||Full Legal Name||Detail|
18C - Operating Rules To Reduce Social Costs
18.C.1 Assignment of Domain Names
New TLDs ought to serve all registrants equally on a first-come, first-served basis, while reserving the opportunity for incumbents to optionally enhance the existing goodwill of their established identities or, alternatively avoid dilution of their Internet identity, without having that choice forced upon them.
Uniregistry believes introduction of new TLDs should not be an opportunity for registries to engage in what is viewed by some as extortion of payment for brand protection. Our financial projections do not include, expect, nor rely upon an assumed profit from defensive registrations. Prior to general registration availability, Uniregistry will conduct a Sunrise period during which names may be reserved or registered on the basis of trade or service marks validated by the Trademark Clearinghouse.
Brand owners who are not interested in using the TLD should not be charged a premium nor risk implicitly threatened consequences of non-registration. Hence, we will offer the opportunity to block trade or service marks in the .BLACKFRIDAY TLD strictly on a cost-recovery basis. While the Trademark Clearinghouse provides an economy of scale for Sunrise programs across registries, Uniregistry will provide further burden reduction with a ʺonce and for allʺ unified multi-TLD Sunrise registration application process. A single Sunrise application can be designated to cover all future TLDs which Uniregistry is entrusted to manage, such that delegation of other TLDs to Uniregistry decreases the net cost, time and inconvenience to any parties engaged in intellectual property protection.
Domain names not allocated during the trademark sunrise process or registry reserved in accordance with ICANN policies and GAC advice, will be made available to all registrants equally on a first-come, first-served basis. At launch, Uniregistry intends to implement randomized and equitable rate-limited registration queues to both handle the load at the registry and also ensure that registrants and their registrars have equal opportunities to register their preferred domain names. Uniregistryʹs business model also does not assume or rely upon reservation and sale of ʺpremium namesʺ or other forms of domain speculation.
18.C.2 Cost Structure and Increases
Uniregistry will offer flat-rate, affordable pricing. It intends to offer certain co-marketing rebates and incentives to all registrars, some of which may be returned to registrants as introductory or bulk registration discounts at the discretion of the registrar.
While not a ʺcommunityʺ application, Uniregistry views its prospective domain registrants as a community to be served, and not exploited. Uniregistry intends to make a contractual commitment to registrants and their registrars not to increase registry prices above cost of inflation for the first five years after launch of the registry. Our initial pricing model allows registry prices to find a market value that may be substantially below our projections, which are based on conservative assumptions of registration volume, rather than locking in a captive market with a deceptively low initial registration cost.
Uniregistry does not believe that registry fees should rise when the costs of other technology services have uniformly trended downward, simply because a registry operator believes it can extract higher profit from its base of registrants. While competition in registrar services by ICANN caused an initial and substantial drop in retail domain registration prices, the fees for registry services have increased over the same span of time. Those increases have not been justified by increased Internet traffic, and thus zone server operational cost, since the cost the underlying technology has trended down while performance has increased. We do not believe registry fees should follow a different trend than comparable technological services. Uniregistryʹs management includes individuals who participated in anti-trust litigation which was brought to combat increases in existing TLD registry charges they believed to be unjustified, and we have no intention of following that path. We believe our best opportunity for prosperity is to offer a reliable, differentiated TLD which will attract increasing numbers of registrants.
18.C.3 Mitigating Externalities
18.C.3.1 Pro-Active Abuse Prevention, Monitoring, and Mitigation
Historically, domain name registries have viewed their companies as purely technical service providers and seen socially undesirable Internet behavior, such as abuse, criminality and fraud, as someone elseʹs problem. The Internet increasingly permeates human interactions and processes, whether those interactions are social, commercial, financial, industrial, or governmental. Uniregistry believes that a registry should possess sophisticated technical tools to identify and redress behavior, wielded by experienced and knowledgeable management committed to rapid response to clearly abusive behavior. While what may be a criminal act in one jurisdiction might be a lawful expression in another, we believe it is possible, and necessary, to define and respond to behaviors which constitute, in their motivations and consequences, attacks on the Internet itself as a reliable medium for the free expression of ideas, information and commerce. Fraud, cybervandalism, identity theft and other universally recognized forms of cybercrime can adversely impact utilization of the Internet to advance the human condition in ways that are as insidious as the injudicious application of policies designed to combat them.
This Application proposes a suite of abuse prevention, investigation and response tools, including active monitoring of WHOIS accuracy; participation in ISCʹs Security Information Exchange; detection of anomalous network traffic consistent with abuse profiles; agents for service of legal process, warrants and subpoenas in the United States; a single point of contact for abuse reporting and response with 24x7 availability; a directory of abuse response resources for third party responders; zone file access; searchable WHOIS; anti-terrorism measures; and graduated tiers of registrar incentives and disincentives based on policy compliance and responsiveness. As undesirable Internet behavior continues to evolve in sophistication and creative unpredictability Uniregistryʹs commitment to be an active participant in the relevant cooperative law enforcement and industry and anti-abuse communities, and the demonstrated record of Uniregistryʹs contractor Internet Systems Consortium in that regard, is perhaps of greater importance than the rules, policies and services which Uniregistry will provide and enforce.
18.C.3.2 Civil Disputes
Uniregistry will require and enforce registrar compliance with the Uniform Domain-Name Dispute Resolution Policy, Uniform Rapid Suspension (URS), and all requirements of the RAA relevant to civil disputes. The URS is not currently offered by any dispute resolution provider which has committed to ICANNʹs target estimate of $300 for URS disputes. Uniregistry believes that cases of clearly unambiguous, facially apparent cybersquatting against established brands can be resolved fairly, promptly and economically, because the type of cases qualifying for the URS are precisely the sort of cases which do not require analysis at length. Uniregistry will seek to implement a URS equivalent to be administered by recognized experts in the field of domain name disputes in the absence of URS availability at the cost target established by ICANN. In conjunction with Sunrise registrations, Uniregisty will implement Sunrise challenges to address abuse of the Sunrise registration system; a trademark claim notification service for pre-empting a defense of ignorance as an excuse for cybersquatting; designated resolution of suspended or blocked domains to prevent ISP re-direction of non-resolving names; and a registration string watch service to permit policing of domain registrations containing strings of interest to users.
18.C.3.3 Technical Security and Stability
Uniregistryʹs technical services provider, ISC is well known in the domain name services community as the operator of the F-Root, and its personnel include highly respected and experienced participants in the Internet Engineering Task Force, and numerous ICANN working groups, task forces and committees. ISC brings decades of experience in operating high reliability and high security systems to the operation of the .BLACKFRIDAY TLD. The application proposes a modular, scalable, and geographically diverse registry platform which can accommodate registration volume and name resolution second to none, independent of whether the actual volume fails to meet or overwhelming exceeds expectations, and can accommodate addition or replacement of capacity without service interruption. The WHOIS system described in the application is further designed to accommodate selective publication of WHOIS data on a jurisdictional basis, as various standards for the handling of personal data continue to evolve.
18.C.3.5 Financial Stability
Experience gained since the launch of new TLDs and general marketing of certain ccTLDs since 2000 has demonstrated that treatment of a TLD delegation as a privately-owned balance sheet asset or private fiefdom does not inspire user confidence. Uniregistry believes that delegation of a TLD is an appointment of a private steward of a public trust. Accordingly, a registry should be prepared to execute a plan of operation which does not rely on rosy scenarios, unrealistic projections and revenue gimmicks.
Uniregistryʹs business plan is based on providing registry services to end users, and not on ʺpremium nameʺ sales, extorting trademark owners, or returning gains to passive outside investors. Uniregistry is not seeking to obtain any necessary capital based on the prospect of selling a stake in Uniregistry ownership contingent upon approval of this application. Uniregistry is well-capitalized, fully funded and ready to commence operation rapidly upon approval of this application. Uniregistryʹs financial reserve is held in gold, and thus immune to currency fluctuations from global economic uncertainty.
Similar gTLD applications: (53)
|gTLD||Full Legal Name||Detail|