18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
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The key goals of the proposed new .netflix gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice, all of which are in the global public interest. Netflix also seeks to foster its online reputation and provide an authoritative internet space through which Netflix is able to engage its customers more directly and more effectively. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and effective functionality will provide a trusted and positive user experience.
18(b)ii. WHAT DO YOU ANTICIPATE YOUR PROPOSED GTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?
It is anticipated that the proposed .netflix gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .netflix gTLD will simplify how internet users interact with Netflix by providing a distinctive domain space. Internet users will be able to directly navigate to .netflix gTLD site, saving time and resources searching for an official site pertinent to the local market. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names that seek to exploit consumer confusion. Netflix can address some of these limitations by maintaining complete control over the domain names registered under the .netflix domain space, assuring customers of the authenticity of the Netflix domain and providing uniformity of the Netflix brand. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under .netflix domain space, which will differentiate interaction between internet users and Netflix.
The use of the .netflix gTLD together with the NETFLIX brand will differentiate the Netflix service as a trusted and preferred site for a globally known entity like Netflix. This will enable Netflix to compete more effectively in an extremely fast-paced and innovative industry by providing a more authoritative and secure site for its members and the internet community globally.
With the expansion of the internet-connected population, the existing TLD structure presents limitations. One great limitation is the ability of unaffiliated third parties to hold the NETFLIX mark, or confusingly similar names in the second level domains. The use of .netflix gTLD will be innovative by removing security risk and alleviating consumer confusion caused by such domain squatting. Another existing limitation is the unavailability (or prohibitive expense in the secondary market) of desired second level names. .netflix gTLD will open the ability to create , on demand, desired relevant second or third level domain names, including the use of geographic names and IDNs. These names will only be dictated by their relevancy to services⁄products, and not by constraints in availability or pricing. This will promote and contribute to more clear internet navigation for internet users in general.
The proposed .netflix gTLD will provide a positive user experience, which meets the changing and growing needs of the global internet community. Netflix will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorized by Netflix. Therefore, .netflix gTLD will:
- represent authenticity thus promoting user confidence;
- enhance security and minimize security risks by implementing necessary technical and policy measures;
- provide an easy and intuitive reference and access point for internet users;
- direct internet users to relevant information in a timely manner by creating domain names on demand;
- use IDNs to enable customer to interact directly in their native language;
- use geographic names to localize its websites to connect with internet users in the relevant regions and to comply with local laws, subject to relevant GAC advice and ICANN’s implementation of an approved program to allow registration of national names;
- strengthen brand reputation and user confidence by reducing user confusion caused by infringing second level registrations; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.
.netflix will address the broadly existing concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing processes, the .netflix gTLD will reduce potential abuses in the registration processes and overall costs to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the global public interest.
18(b)iv. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.
The proposed registration policy is attached in response to Question 28.
Only wholly-owned affiliate entities of Netflix or select business partners having the Required License will be eligible to register domain names in .netflix. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures.
18(b)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.
Netflix is committed to protection of privacy and confidential information in accordance with applicable laws, regulations and industry standards relating to internet security, and the protection of privacy and personal information. These include, but are not limited to: Section 5 of the Federal Trade Commission (FTC) Act, as interpreted by the FTC in its enforcement actions and written guidelines, interpretations, or self-regulatory principles, including, without limitation, its Self-Regulatory Principles for Online Behavioral Advertising and its privacy framework for protecting consumers (preliminary report entitled “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Business and Policymakers”), the Children’s Online Privacy Protection Act (“COPPA”) and the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CANSPAM”) in the US; the European Directives 95⁄46⁄EC and 2002⁄58⁄EC (as implemented by Luxembourg) in Europe; PIPEDA in Canada; the Federal Law for the Protection of Personal Data in Possession of Private Persons (Personal Data Protection Law) in Mexico, and applicable constitutional protections established in Brazil.
As the .netflix gTLD will only be available to wholly-owned affiliate entities of Netflix and select business partners having the Required License, only limited personal data will be collected for the purposes of operating the gTLD. Such limited personal data will be of the sort commonly available in WHOIS records.
Netflix will deploy DNSSEC and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy. Netflix already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorized access. Such measures include several layers of directive, preventative, detective, and reactive controls protect Netflix sensitive information from a process and technology perspective:
- Business Continuity and Disaster Response plans provide overall guidance to the operations of Netflix infrastructure, including operations resiliency and data backups.
- An Information Security Policy provides guidance regarding IT controls such as mandatory password complexity and expiration periods, anti-virus requirements, log and event monitoring, and the use of VPNs, VLANs, firewalls, and network segmentation based on risk of asset.
- An Incident Response Plan coordinates overall efforts to respond to incidents that may affect the operation of Netflix services or Netflix information.
- A Netflix-managed Network Operations Center is staffed 7x24 to monitor Netflix services and coordinate and respond to incidents or outages.
- Separate policies outline additional controls and processes to protect SOX or PCI significant information. Representative controls include additional physical security; more stringent audit, logging, and monitoring requirements; mandatory encryption for sensitive customer information; and stronger authentication and authorization requirements.
- Sensitive information such as customer payment information and customer email addresses are stored in encrypted databases. Specific controls govern the use and storage of cryptographic key material.
18(b)vi. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
The .netflix gTLD will be introduced in the ordinary course of Netflix’s public relations efforts and marketing communications. During the initial stage of the operation of the .netflix gTLD, it is anticipated that internet users will be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilize the trusted site will contribute toward minimizing malicious abuses and protecting internet users.
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