18(c) What operating rules will you adopt to eliminate or minimize social costs?
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18(c) Minimizing Social Costs
The .MEMORIAL registry aims to provide a unique and beneficial service to registrants, Internet users, and the TLD space as a whole; therefore, it is imperative that consumers are protected at all times.
The first step we have taken to ensure that social costs are minimized is by partnering with Neustar to provide our back-end registry services. Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure. Our technical operator, Neustar, has secure and geographically dispersed facilities that include the global diversification of SRS, DNS, WHOIS and operational facilities. Neustar operates and maintains a world-class registry infrastructure, including fully redundant Shared Registration System (SRS) data centers, a third disaster recovery SRS site, two WHOIS sites, operations and customer support facilities in Sterling, Virginia and Louisville, Kentucky, and 16 nameserver hosting sites geographically dispersed for diversity and global reach. The facility locations provide diverse network connectivity and appropriate network capacity necessary to effectively operate the Registry with associated support and administrative functions, and also protect against natural and man-made disasters. Neustar has been operating a global DNS network for over 10 years and currently operates the DNS for several TLD customers, such as .CO, .US, .TEL, .BIZ and .TRAVEL. This makes them an optimal choice as a dependable, world-class back-end services provider.
In addition, .MEMORIAL understands that strong abuse prevention of a new gTLD is an important benefit to the Internet community. .MEMORIAL and its registry operator and back-end registry services provider, Neustar, agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help .MEMORIAL combat abusive and malicious domain activity within the new gTLD space.
One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from: Illegal or fraudulent actions, Spam, Phishing, Pharming, Distribution of malware, Fast flux hosting, Botnets, Distribution of child pornography, and Online sale or distribution of illegal pharmaceuticals. These steps to minimize social costs and negative consequences on consumers are outlined in greater detail in response to Question 28 – Abuse Prevention and Mitigation.
As discussed previously, it is also a top priority of the .MEMORIAL registry to work diligently to protect the rights of trademark owners through the use of Sunrise and Trademark periods before live launch to the public, implementation of the Uniform Domain Name Dispute Resolution Policy (UDRP), implementation of the Uniform Rapid Suspension (URS) system, and implementation of a Thick WHOIS to make it easier for rights holders to identify and locate infringing parties. These policies are described in greater detail in response to Question 29 – Rights Protection Mechanisms.
I. Resolution of Multiple Trademark Applications
In researching how to best resolve multiple trademark applications, it became clear that awarding a domain name on the basis of an auction would be the least fair. Auctioning trademarked names would favor those trademark holders that are financially well off enough to buy out everyone else. To make it as fair as possible to applicants, our policy will be to time-stamp all Sunrise submissions and allow the review process to proceed on a first-come, first-served basis. If multiple applicants with qualified trademarks (regardless of country) apply, the application that was submitted first will be evaluated first, and if their trademark is determined to be valid, then they will be awarded the string. Other valid trademark holders that want to challenge the award can do so under the UDRP or through a legal jurisdiction that arbitrates in trademark disputes.
II. Cost Benefits to Registrants and Registrars
Although .MEMORIAL does not plan to provide any immediate discounts for registrants, our aim is to keep our annual wholesale price as low as possible to enable anyone wishing to secure an online tribute for a special loved one to do so affordably. In addition, we aim to implement additional cost benefits as quickly as possible as the .MEMORIAL registry grows. For example, we would like to offer bulk registration discounts to our registrars based on monthly volume (e.g., 100 domains a month will receive a 3% discount, 250 domains will receive a 5% discount, 500 domains will receive a 7% discount, 1000 domains and above will receive a 10% discount). As the registry grows and our marketing budget allows, we aim to run various promotions with significant discounts with the goal of spreading the word about the benefits of owning a .MEMORIAL domain and increasing our number of domains under management. All discounts and promotions will be equally available and transparent to all registrars in accordance with ICANN’s Equal Access policy.
III. Price Escalation
Any future increases in our wholesale pricing to registrars will not exceed the Maximum Service Fee during the preceding calendar year multiplied by 1.10. The same Service Fee shall be charged to all ICANN-accredited registrars for new and renewal domain name registrations. Any price increases will be done in compliance with the ICANN escalation policy, including, but not limited to, providing no less than six months prior notice in advance of any price increase for domain name registrations and continuing to offer domain name registrations for periods of up to ten years.
Similar gTLD applications: (1)
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