18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
|gTLD||Full Legal Name||Detail|
i. What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
Currently, there is no top-level domain dedicated to banking and financial services, and no top-level domain dedicated to Citigroup Inc.ʹs (ʺApplicantʺ) brand. The goal of the TLD in terms of specialty, if displayed to the public, is for Applicant to securely and uniquely provide a top-level domain dedicated to providing banking and financial goods and services to Internet users and customers around the globe under its famous and trusted brand. Allowing Applicant to control its own Internet space for its famous 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 without having to incorporate a non-branded, non-industry-related term such as .com, .net, or .biz. This specialty will benefit Internet users seeking secure online banking and financial services.
This specialization simultaneously makes it easier for Internet users who are looking for Applicant-related information to locate this information more efficiently. The appendage of the TLD indicates to users what they can expect to find at that website under the TLD, namely, premier and secure financial and banking goods and services offered solely by the famous and reputable Applicant. It also has another added benefit in that web addresses will become shorter—one impact of a dearth of ‘good’ web addresses has been for them to get longer over time. Using the TLD not only means Applicant’s sites can benefit from having an important keyword in their web address, but it will also be much faster to type in the address. 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 global promotion purposes. This will increase traffic to these websites, promote competition and innovation, 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.
The goal of the TLD, if displayed to the public, will be to ensure the highest level of security, quality, and customer services levels are provided to Applicant’s customers and clients, for whom security is a high priority concern in connection with its banking and financial services. Primarily, this entails ensuring that only Applicant’s authorized employees and affiliates are able to register and control the second-level domain names in the TLD. Regarding security concerns, this entails contracting with and using proven industry experts to provide the highest possible quality in registry and registrar customer service so as not to compromise the security and stability of the highly confidential information that Applicant’s consumers will provide through the TLD.
Applicant will further endeavor, as it does with its current websites, to provide customer service available by phone 24 hours per day, 7 days per week to instantly help any customer attempting to learn about or utilize Applicant’s goods and services on any outwardly-facing domain name and website in the TLD. Similarly, Applicant will provide the highest level service to trademark and other legal rights owners by providing an easily accessible point-of-contact on any outwardly-facing domain names and websites.
By focusing on the end user, Applicant will ensure that it is providing the best specialized user experience possible. To do this, Applicant will employ customer focused testing to determine what their expectations are for an Applicant-branded TLD experience and then tailoring the TLD to its end users. For example, when designing its current websites or adding a new feature to its homepage, Applicant takes great care to ensure that they will ultimately serve the Internet user, rather than its own internal goals or bottom line. Applicant’s homepage interface is thus clear and simple. Information is provided through the most secure websites and networks. Applicant will continue to operate under this principle when designing websites and providing banking, finance, and related goods and services in the TLD.
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. Indeed, as discussed above, Applicant already has an awarded-winning online track record and, if displayed to the public, intends to enhance its Web services with the new TLD. As insurance and financial websites are among the most vulnerable to fraudulent online activity, Applicant seeks through the operation of the TLD to maintain a reputation for providing the most secure online environment in the industry for all Internet users to feel secure in providing highly sensitive personal information to Applicant. Applicant also has a reputation of having enhanced technical capabilities and to be an early adopter of technical advancements in the banking and financial industry. The goal of the TLD, if made public, is to continue to promote Applicant’s reputation for excellence and high levels of security and advanced and enhanced technical capabilities.
The TLD will further strive to be known for 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 world-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 use of the TLD.
ii. What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
The TLD, if displayed to the public, will enhance competition to the current Internet space by allowing Applicant to control its own Internet space and to have the flexibility to innovate and create new online goods and services, and to connect with new geographic areas in a new way. These innovations to how the Applicant will provide online banking and financial services will incentivize existing and new top-level domains and banking and financial service companies that operate on existing and new top-level domains to also improve the security and quality of the banking and financial goods and services they provide online and to accelerate the introduction of new goods and services in order to continue attracting new customers. Thus, the entry of the TLD will benefit consumers by increasing the likelihood of the successful introduction of new and innovative online goods and services.
The TLD, if displayed to the public, will be differentiated from all other top-level domains currently available in the marketplace because its famous brand will be automatically affixed to all second-level domains as the TLD and immediately indicate to Internet users the source of the TLD. Indeed, no other top-level domain is similar in appearance to the TLD, and none is used exclusively for banking and financial goods and services, and⁄or none exclusively serve Applicant’s users and customers. In terms of differentiated uses it 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 will be ever be allowed to register and⁄or operate domain names within the TLD, allowing the TLD to become unique in that its customers can reduce their concerns regarding corruption, security, spam, phishing or false or inaccurate information, and allowing Applicant to become an even more trusted provider of online banking and financial goods or services.
Applicant is already a recognized leader in online banking and financial innovation as demonstrated above. Indeed, technology is at the forefront of Applicant’s online banking and financial presence. One of the most crucial issues of importance to banking and finance customers and clients is security. The TLD, if displayed to the public, will allow Applicant to provide information, goods and services to its clients and customers in a more secure and technologically advanced way and allow Applicant to implement technical advances that may not have been capable before in a less secure environment.
Indeed, the TLD will allow Applicant to innovate and to continue to be a market leader in providing truly secure banking and financial websites. With the TLD, Applicant can test the use of the TLD with consumers to facilitate their desired Web experience, and can test the use of the TLD to ensure it meet the highest possible security standard. This innovation will promote competition in the Internet space and more likely provide higher levels of service to its users and customers. Moreover, the TLD will be innovative in that it will allow more people to have greater access to a dedicated and secure banking and financial services top-level domain. The TLD will also allow Applicant to expand its secure work in communities where access to financial services is limited by making it easier for these communities to access its banking and financial services in a trustworthy way.
Similarly to how it operates its award-winning domain names and websites in third-party top-level domains, Applicant will strive to test, develop, and implement the TLD and its websites to target its customer’s Web expectations in the most secure manner. In doing so, Applicant will take great care to ensure that domain names in the TLD will ultimately serve the Internet user, rather than its own internal goal or bottom line. Accordingly, 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 goods and services around the globe. 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 and conducting online banking and finance transactions. The TLD, if displayed to the public, will serve to differentiate Applicant from other banking and financial institutions and serve to create a more stable, competitive, and active marketplace.
iv. Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
In order to support the goals listed above, only Applicant through its authorized employees will be allowed to register domain names within the TLD for its own exclusive use. Accordingly, it is Applicant’s intention that the general public will never be allowed to register, buy, or sell domain names in the TLD. Applicant, however, reserves 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 for the exclusive use of Applicant. Affiliate will be defined for the purposes of this application 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.
As stated above, Applicant intends to operate a closed registry in order to continue to offer the high-quality online banking and financial goods 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 of course be subject to its abuse prevention and rights protection policies discussed further herein, and Applicant will strive to avoid registering domain names that are confusingly similar to third-party’s trademarks and related rights. Obscene, explicit, and offensive domain names will not be entitled to registration.
v. Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.
Keeping information secure and private is of crucial importance to banking and financial institutions, whose websites are targets of online fraudsters. Initially, Applicant intends to operate a registry with limited access so as 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 therein, and will remain in compliance with all confidentiality and security regulations in relevant jurisdictions.
For example, Applicant already takes the following steps to safeguard the financial information of its current online banking services customers and clients:
• 128-Bit Encryption;
• Additional Authentication — asking users additional questions to verify identity;
• Date⁄Time Stamp to notify Applicant of unauthorized account access;
• Extended Validation (EV) SSL Certificate — allows users to visually validate that the website being transacting with has undergone an extensive outside security audit; and
• Secure Firewalls — The computer servers which run Applicant’s websites are protected by numerous firewalls to help prevent unauthorized access to Applicant’s network, and Applicant constantly monitors these firewalls to prevent security breaches.
If the TLD becomes public-facing such that external users are interacting with domains registered in the TLD, Applicant will, at a minimum, provide similar security measures.
vi. Describe whether and in what ways outreach and communications will help to achieve your projected benefits.
Outreach and communication are among Applicant’s important goals in connection with the TLD. For example, if the TLD is displayed to the public, it will provide better and more secure access to banking and financial information to consumers, institutions, and governments throughout the globe. Applicant intends to institute marketing and outreach efforts to inform the public about the TLD and the information available there.
Applicant already uses a number of different outreach and communications methods and venues to get its mission and message out to the public, including but not limited to, press releases, featured videos posted on various Internet sites, social media, including but not limited to blogs, YouTube, Twitter, and Facebook, various mobile applications for iPads, iPhones, Android, and Kindle devices, various news feeds around the globe, 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.
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|gTLD||Full Legal Name||Detail|
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