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18(c) What operating rules will you adopt to eliminate or minimize social costs?

gTLDFull Legal NameE-mail suffixDetail
.chatdot Chat Limitedfamousfourmedia.comView
Q18C
What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

The Applicant fully appreciates the concerns of ICANN, the GAC and other consumer protection authorities about the need to operate new gTLDs in ways that minimize social costs, consumer vulnerabilities as well as other time and financial resource costs. To achieve these goals this gTLD will not only employ the ICANN mandated minimum protections, but will also deploy the following innovative protection measures that will put the gTLD at the forefront of addressing these critical issues:

1) Abuse Prevention and Mitigation Policies and Procedures

The Applicant’s core mission and purpose is to create an environment where individuals and companies can interact and express themselves in ways never before seen on the Internet, in a more targeted, secure and stable environment. To achieve this goal the Applicant will be implementing a range of Abuse Prevention and Mitigation (ʺAPMʺ) policies and procedures.

These Policies and Procedures will include: 1) gTLD APM Plan, 2) Policies and Procedures to Minimize Abusive Registrations ,3) Abuse Point of Contact, 4) Policies for Handling Complaints Regarding the Abuse Policies, 5) Acceptable Use Policy (“AUP”), 6) Proposed Measures for Removal of Orphan Glue Records, 7) Resourcing plans for the initial implementation of, and ongoing maintenance of, the APM initiatives, 8) Registry semi-annual WHOIS verification, 9) Regular monitoring of WHOIS registration data for accuracy and completeness, 10) Registrar WHOIS self-certification, 11) WHOIS data reminder process, 12) Establishing policies and procedures to ensure Registrar compliance, which may include audits, financial incentives, penalties, or other means, 13) Registrar verification of WHOIS, 14) Abuse Response Process, 15) Policies and procedures that define malicious or abusive behaviour, 16) Service Level Requirements for resolution regarding APM issues, 17) Service Level Requirements for Law enforcement requests regarding APM issues, 18) Coordination of APM efforts with sector Groups and Law Enforcement, 19) Rapid takedown and suspension, 20) Controls to Ensure Proper Access to Domain Functions, 21) Enabling two-factor authentication from Registrants to process update, transfers, and deletion requests, 22) Enabling multiple, unique points of contact to request and⁄or approve update, transfer, and deletion requests, 23) Enabling the notification of multiple, unique points of contact when a domain has been updated, transferred, or deleted, 24) Additional Mechanism for Protection of Capital City Names, 25) Additional Mechanisms to Protect and Reserve IGO Names, 26) Governance Council Structure, 27) Efforts to increase Registrant Security Awareness, 28) Registrant Disqualification, 29) Restrictions on Proxy Registration Services, 30) Registry Lock. (Q28 for detail)

2) Rights Protection Mechanisms

The Applicant is firmly committed to the protection of Intellectual Property rights and to implementing all the mandatory Rights Protection Mechanisms (“RPMs”) contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Use of domain names that infringe upon the legal rights of others in the gTLD will not be tolerated and preventing abusive registrations is a core objective of the Applicant. The nature of such uses creates security and stability issues for the Registry, Registrars, and Registrants, as well as for users of the Internet in general. The Applicant will minimize time or financial resources costs by preventing abusive registrations and reduce opportunities for behaviours such as phishing or pharming. This will be achieved by implementing comprehensive registration, anti-abuse, and rights protection guidelines as defined in its AUP, as well as innovative additional RPMs such as the Mechanism to Protect IGO Names by blocking second level labels currently present in the .int zone file and the Mechanism for Further Protection of Capital City Names, as described below. In order to identify and address the abusive use of registered names on an ongoing basis, the Applicant will also incorporate and abide by the following RPMs and all other RPMs as specified in Specification 7 of the Registry Agreement and as adopted by the ICANN Board of Directors as ICANN Consensus Policies.

These Rights Protection Mechanisms will among other things include: 1) Trademark Clearinghouse, 2) Applicant’s Sunrise Period, 3) Trademark Claims Service , 4) Uniform Domain Name Dispute Resolution Policy, 5) Uniform Rapid Suspension System, 6) Trademark Post-Delegation Dispute Resolution Procedure, 7) Mechanism to protect IGO Names, 8) Mechanism for Further Protection of Capital City Names, 9) Efforts to promote WHOIS Accuracy, 10) Thick Searchable WHOIS, 11) Semi Annual Audits to Ensure Accurate WHOIS, 12) Policies Handling Complaints Regarding Abuse and Rights Issues, 13) Registry Acceptable Use Policy (“AUP”), 14) Monitoring for Malicious Activity. (Q29 for detail)

3) Governance Council Structure

The Applicant believes that sector stakeholders should be afforded the opportunity to influence the manner in which the gTLD is governed. Accordingly, the Applicant will establish a Governance Council (the “GC”) comprised of key sector stakeholders that will serve as an advisory body tasked with defining best practice recommendations for the gTLD space. The Applicant believes that the success of the gTLD will be determined largely by the sector’s key stakeholders. Not only will these stakeholders have the primary interest in registering domains in the gTLD, but they will also be motivated to protect the sector from practices that would negatively impact the sector overall. The GC exists to provide guidance on matters related to best practices, intellectual property, authentication, certification, and other matters of importance to the sector and it will elect its own Board of Directors, which will be responsible for self-governance, the recommendation of sector-specific policies, and other best practices related to the gTLD.

4) BITS and Coalition for Online Accountability (“COA”) Recommendations

The Applicant will further structure its policies around the BITS and COA Recommendations where relevant to this gTLD. The Applicant’s goal is to provide a safe and secure experience for consumers. A domain within this gTLD that is owned, operated by or compromised by a malicious party could cause harm to consumers, to the gTLDʹs reputation and to the reputation of the Internet itself. As such, additional controls are in place relating to the validity of registrations, as well as measures to ensure the correct identity of both Registrants and Registrars relating to changes made within the SRS, and to protecting the integrity of the DNS service as a whole.

The Security Standards Working Group (SSWG) formed by BITS drafted a set of policy recommendations that should be applied to financial TLDs. The policy comprises of a set of 31 recommendations that should be adopted by ICANN in evaluating any applicant of a financial gTLD. The recommendations were posted by BITS in the form of a letter to ICANN at [http:⁄⁄www.icann.org⁄en⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf].

The Coalition for Online Accountability have drafted a set of policy recommendations, also endorsed by many other international organizations representing the creative industries, that should be applied to entertainment gTLDs - especially those dependent on copyright protection. The policy comprises of a set of 7 recommendations that should be adopted by ICANN in evaluating any applicant for an entertainment-based gTLD. The recommendations were posted by COA in the form of a letter to ICANN at http:⁄⁄bit.ly⁄HuHtmq.

We welcome the recommendations from BITS and the COA and will strongly consider the recommendations relating to the implementation of this gTLD where considered relevant.

5) Registry Operators Startup Plan

The Applicant proposes to implement the following start-up plan so that the new gTLD is introduced in an orderly, transparent and stable manner. This will safeguard competition, fairness, trust and reliability for Registrants, the User Community, ICANN Accredited Registrars, and other Stakeholders.
The Applicant’s startup plan is designed to minimize social costs (e.g., time or financial resources costs, as well as various types of consumer vulnerabilities) by instilling a number of RPMs as well as APMs.
The plan consists of the following multi-phase process that will be executed by the Registry Operator. The timeline for the gTLDs start-up process and associated RPMs in the Applicants gTLD is as follows:

Phase 1 – Sunrise Process:

- Day 1: Sunrise round opens
- Day 60: Sunrise round Closes
- Day 61: Sunrise Allocation Including contention resolution mechanisms opens
- Day 71: Sunrise Allocation contention resolution mechanisms closes

• The following Rights Protection Mechanisms apply:
a. Trademark Clearinghouse (“TMCH”)
b. Sunrise Eligibility Requirements (“SER”)
c. Sunrise Dispute Resolution Policy (“SDRP”)
d. Uniform Domain Name Dispute Resolution Policy (“UDRP”)
e. Uniform Rapid Suspension System (ʺURSʺ)
f. Mechanism for the Protection of IGO Names (“PIN”)
g. Trademark Claims Service (“TCS”) *

Phase 2 – Landrush process:

- Day 72: Landrush opens
- Day 102: Landrush closes
- Day 103: Landrush contention resolution mechanisms opens
- Day 113: Landrush contention resolution mechanisms closes

- The following Rights Protection Mechanisms apply:

a. UDRP
b. URS
c. PIN
d. Mechanism for Further Protection of Capital City Names (“CCC”)
e. TCS *

Phase 3 – General Availability⁄Registrations:

- Day 114: General availability begins

- The following Rights Protection Mechanisms apply:

a. UDRP
b. URS
c. PIN
d. Trademark Post-Delegation Dispute Resolution Procedure (“PDDRP”)
e. TCS for the 90 days after day 114 *

* To ease the concerns of trademark owners and mitigate the impact of infringing registrations, the Applicant will be implementing the TCS in all three phases of launch. It is important to note that during the General Availability Phase, the TCS will be used for 90 days, 30 days longer than the ICANN mandated minimum.

18(C)(i) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?

Sunrise and Landrush periods:

During the gTLDs launch period, multiple applications for a particular domain name will be resolved through a Contention Resolution Mechanism (“CRM”) involving auctions. These CRMs will apply to the Sunrise and Landrush application phases. The CRMs will be conducted by Sedo GMBH, an experienced provider of domain auction services. The mechanisms offered will involve closed auctions where only specific bidders can participate.

During the Applicants Sunrise process, if there are two or more eligible applicants for one domain name string, then the contention will be resolved by auction. Auctions held during the Sunrise phase (“Sunrise Auctions”) will be closed and the only bidders will be eligible applicants according to the gTLDs Sunrise eligibility requirements including the TMCH.

During the Applicants Landrush process, if there are two or more eligible applicants for one domain name string, then the contention will be resolved by auction. Auctions held during the Landrush phase (“Landrush Auctions”) will be closed and the only bidders will be eligible applicants according to the gTLDs Landrush eligibility requirements.

General Availability:

After the two initial startup phases of the Registry the allocation of domain names will occur on a first-come first-serve basis, taking into account the registries APM and RPM mechanisms.

18(c)(ii) Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

Incentive, Marketing and Outreach Programs

The Applicant will implement a number of incentive, marketing assistance, awareness and PR programs to assist the Registrar channel in providing a sector leading experience to end-users and to provide cost benefits for registrants. The Applicant will work with the global Registrar channel to ensure that the new gTLD offer is clearly visible on registrar sites resulting in an increase in the awareness and in the number of new gTLD registrations. Achieving this visibility requires (1) a clear business case and incentives for registrars to motivate them and (2) mechanisms and assets to make it easy for them to do so.

The Applicant will at the time of launch depending upon market conditions consider incentive programs that will deliver cost benefits to registrants through either the use of advantageous pricing, introductory discounts, bulk registration discounts or other similar methods. The Applicant is aware of Specification 9 – Registry Operator Code of Conduct, and will not directly or indirectly show any preference or provide any special consideration to any Registrar in its marketing efforts.

Example incentive mechanisms the Applicant will provide to the registrars may include:

Marketing Incentives

The Applicant intends to provide expertise, tools and creative assets to the registrars as part of general marketing and co-marketing programs. There is a significant cost saving if the expertise, tools and assets are developed centrally and the costs amortized across the registrar base. Significant cost savings can occur relating to Market Research, Social Customer Relationship Management (“SCRM”), Content Management Systems (“CMS”), Direct Marketing Tools, Marketing Collateral and Analytics Solutions.

The Applicant will employ some or all of the following marketing techniques jointly with registrars globally: (1) Direct Response Print, (2) General Web Marketing, (3) Email campaigns without Incentive, (4) Email with Incentive, (5) Email Marketing - Prospect List, (6) Email Marketing - Sponsored Newsletter, (7) Direct Marketing with Incentive, (8) Web Marketing with Incentive, (9) Viral Marketing (Social, Video, Micro-sites), (10) Develop User Interface Improvement best practices, (11) Develop Search Engine Optimization best practices, (12) Email Marketing - Registrar List
As an example of a marketing initiative, the Applicant will forward leads to the Registrars “buy” pages as an incentive via the means of Pay-Per-Click (“PPC”) search marketing. The Applicant will run multiple PPC campaigns targeting gTLD Registrants and point these to landing pages on the Registrar’s websites. Conversions are directly trackable from all PPC campaigns and keywords with a high Click-Through-Rate (“CTR”) or conversions will also be leveraged for SEO best practice purposes.

PR and Awareness Incentives:

In addition to the core outreach to the Registrar Channel, the Applicant will engage in a wider outreach to build awareness of the new gTLD with customers, end-users and other stakeholders. The Applicant will engage with a number of high profile individuals associated with the gTLD and will seek to reach end consumers through webcasts, podcasts, traditional broadcast TV as well as radio.

Provision of customer retention toolkits to Registrars:

The Applicant will use propensity modelling to build retention marketing programs to minimize churn whilst building renewal sustainability. The Applicant will develop econometric models designed to measure the likelihood of a customer segment to purchase a product or offer bundle, at a certain point in the relationship lifecycle. They are used to predict the best time, and the best combination of products, to offer to customers who match a certain profile. They are especially effective where there are large numbers of customers and reliable data can be gathered. The Applicant expects that registration volume in the gTLD will provide sufficient data for this modelling.

Measure, benchmark and improve the customer experience:

The Applicant will engage in a program to develop best practice policies related to the customer experience at differing levels of the channel. This will include the entire ecosystem from Registry through Registrar to Resellers and finally end-users. One key metric might be, for example, to reduce the number of clicks to make a purchase equivalent to the most customer friendly e-commerce sites in the world.
The Applicant might, for example, provide website performance tracking tools to registrars, which would benchmark current performance and provide insights into customers’ needs and behaviour at the point of purchase.
The Applicant will engage in a Social Customer Relationship Management Program to monitor social media feedback to questions, concerns or other issues. The Applicant will further seek to measure marketing communication expenditure and activity.

Other initiatives that will be considered by the Applicant in its outreach efforts:

(a) Customized Vertical Search App for major mobile platforms.
(b) Designated Twitter channel for the stakeholder community.
(c) Social Media outreach through Facebook and other social media solutions.

Translation into other languages:

At present, the Applicant plans to translate marketing collateral and other content that it considers to have geographically diverse appeal in to the 6 official UN languages, namely Arabic, Chinese (Mandarin), English, French, Russian and Spanish.

18(c)(iii) Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

The Applicant will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator has in excess of ten years of experience managing numerous gTLDs that utilize standard and unique business rules and lifecycles.

Initial registrations of registered names may be made in the registry in one (1) year increments for up to a maximum of ten (10) years. For the avoidance of doubt, the registration term for registered names may not exceed ten (10) years. Further the renewal of registered names may be made in one (1) year increments for up to a maximum of ten (10) years. For the avoidance of doubt, renewal of registered names may not extend their registration period beyond ten (10) years from the time of the renewal.

The Applicant plans to review domain name registration rates on an annual basis and will make a determination at that time regarding adjustments, depending upon market factors. Thus, at this time, the Applicant does not plan to make specific guarantees regarding pricing increases.

The Applicant will provide ICANN and each ICANN accredited registrar that has executed the registry-registrar agreement for the gTLD advance written notice of any price increase (including as a result of the elimination of any refunds, rebates, discounts, product tying or other programs which had the effect of reducing the price charged to registrars, unless such refunds, rebates, discounts, product tying or other programs are of a limited duration that is clearly and conspicuously disclosed to the registrar when offered) that complies with the requirements as outlined in the New gTLD Registry Agreement.
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gTLDFull Legal NameE-mail suffixDetail
.gaydotgay llcspimarketing.comView
18(c)i

Creating .gay as a vibrant community-based TLD requires an innovative approach to registration that ensures names are distributed in a fair and orderly manner during launch, and redistribution after expiration, in order to create the maximized benefits for the intended registrants and Internet users. This includes rights protection offered during Sunrise A and B, as well as a level of protection based on domain names that community members have built their organizations and businesses around on other IANA-recognized TLDs. In all cases described below each .gay domain name registration requires community authentication, which is manifested through a unique Community Identifier Code (CIC) per registrant and domain. The exception is the Sunrise B period, which does not require community authentication.

dotgay LLC will create an extensive reserved names list consisting of potential index directory domain names, sensitive names and a wide array of common generic names in several languages. The Registry and the Internet users will later determine which words may be released as premium auction names. The Registry reserved names noted above will be excluded from all registration periods prior to General Availability.

Founders
The Founders period is tied to the Founders Program created by dotgay LLC, a pre-launch opportunity for members of the Gay Community to contribute financially, while reinforcing their commitment to building the .gay TLD. As is common practice in the Gay Community with new emerging organizations, Founders become stewards because of their commitment, setting the tone to build trust for future membership. Founders with and without trademarks will have the opportunity to submit requests for .gay names prior to the Sunrise Period. Requests during the Founders period are submitted directly to dotgay LLC.

Resolution: Applications for domain names during the Founders Period will be distributed on a first-come⁄first serve basis and placed on the Registry reserved list of Founders Names.

Sunrise
The Sunrise period will consist of Sunrise A (Community Trademark) and Sunrise B (Non-Community Trademark), as described below. Both periods run simultaneously and last for a minimum of 30 days. Sunrise A applications will be submitted to approved Registrars and Sunrise B requests will be submitted directly to dotgay LLC through the provided online process, or another process outlined at a later date when details about how the Trademark Clearinghouse will operate are revealed.
• Sunrise A – Community Trademark – The opportunity for authenticated community members (who have obtained a CIC) registered in the Trademark Clearinghouse to submit Registration Requests for .gay names corresponding to their registered trademarks.
• Sunrise B – Non-Community Trademark – The opportunity for those who are not members of the Gay Community to submit requests for names corresponding to their trademarks, as registered in the Trademark Clearinghouse, to be added to the Registry Sunrise B Reserved names list. A nominal fee will be charged for successful Sunrise B requests, to cover the cost of the Trademark Clearinghouse inquiry (amount TBD) and Registry administration fee (TBD). Registry will publish a complete list of names from Sunrise B that have been reserved. Reserved names will not result in a Registration in the .gay TLD, and will convey no other rights to successful Sunrise B applicants. Community authentication is not required for Sunrise B.

Resolution: Multiple applications for a particular domain name during Sunrise A will be resolved with an auction in the Sunrise Auction period. Sunrise A applications will trump all Sunrise B applications, meaning that if there is a viable Sunrise A and B applicant then the Sunrise A applicant will be awarded the name. Multiple Sunrise B applications do not require any prioritization.

NOTE: dotgay LLC reserves the right to release Sunrise B reserved domain names for registration if an authenticated community member with a trademark (corresponding to the name) included in the Trademark Clearinghouse requests so in writing to dotgay LLC.

Sunshine
The Sunshine period is designed to give community members with registrations obtained before May 1, 2012 on other IANA-recognized TLDs, an opportunity to become part of the .gay domain prior to General Availability. This period follows the conclusion of the Sunrise period and is designed to provide a protection for existing community domain names. Applications received during Sunshine require a CIC and are treated as received at the same time.

Resolution: Multiple applications for the same name during Sunshine will be resolved by an auction in the Sunshine Auction period.

Premium Name Auction
Premium Name Auction periods will take place periodically as scheduled by dotgay LLC, as early as the conclusion of the Sunshine Period. Premium Name auctions include domains reserved by dotgay LLC specifically for sale during Premium Name Auctions to those who have obtained a CIC.

Resolution: All premium name auctions will be awarded to the highest bidder.

Land Rush
The Land Rush period opens following the conclusion of the Sunshine period and will serve as an opportunity for community members who have obtained a CIC to apply for any available name they are entitled to apply for. Applications received during Land Rush are treated as received at the same time.

Resolution: Multiple applications received during Land Rush for a particular domain will be resolved by an auction in the Land Rush Auction period.

General Availability
The General Availability Period will follow the conclusion of the Land Rush Period and will serve as an opportunity for community members who have obtained a CIC to apply for any available name.

Resolution: Applications for domain names during the General Availability will be distributed on a first-come⁄first serve basis.

18(c)ii

dotgay LLC does not intend to implement any cost benefits for registrants, such as discounts or bulk rates. All pricing will stem from standardized wholesale rates. As a community-based initiative, the .gay TLD is designed to address the needs of the Gay Community by using a ‘pay it back to the community’ strategy around achieving cost benefits for its registrants. Registrations in the .gay TLD contribute to a community resource from which registrants can ultimately benefit in ways that extend beyond a financial saving on the domain name itself, including progress in the areas of social services and social change. The benefits for registrants will also be realized over the long-term.

dotgay LLC views a certain monetary “entry barrier” into the second level as a healthy instrument to prevent unnecessary drain of the available namespace and in order to preserve availability for future years to come. Registrants in financial strain will be able to obtain less expensive third level registrations on index domain names.

An indirect cost benefit for registrants will be realized through the incentive program designed as a commission for the essential community support organizations serving as dotgay LLC’s Authentication Partners. This is an exclusive offering to Authentication Partners as described below and based on the uniqueness of the Gay Community, and their needs.

Uniqueness of the .gay TLD

Unique to the .gay TLD is the challenge of identifying eligible community members and garnering their trust to participate. Because the Gay Community is not always visible and because the Gay Community is still healing (and in some cases still suffering) from prejudice and injustice, the task of outreach and engagement remains difficult, except when initiated from within the community. Understanding the landscape of the Gay Community and approaching registrants from a trusted source is mandatory to the registration process. dotgay LLC does not believe that standard practice used in marketing existing TLDs can be applied to the .gay TLD. Establishing entry points that are linked into the Gay Community and seen as trusted sources remains critical to the .gay community-based model.

Through the use of established membership organizations in the Gay Community as Authentication Partners, dotgay LLC not only complies with the most restrictive community registration requirements, but also provides the best solution for connecting with potential registrants. Authentication Partners are the community membership organizations used by dotgay LLC to confirm eligibility. Authentication Partners become advocates for the .gay TLD and provide a trusted entry point for members of the community. Authentication Partners are also the advocates for their registrants within the .gay community-model.

Eligibility is required of all registrants of the .gay TLD, so the first step of registration begins with the acquisition of a Community Identifier Code (CIC) through one of the Authentication Partners. As dotgay LLC will utilize a uniquely innovative and targeted marketing plan via the Authentication Partners, it will create a more strategic and cost effective approach to seeking out registrants. The majority of potential registrants will ultimately be driven by dotgay LLC and the Authentication Partners to the registrars.

No pricing discounts for registrars will be offered initially. The registrars that meet dotgay LLC requirement for handling name registrations for .gay will not need to put the same necessary efforts into marketing .gay as with other TLDs, but will benefit from the Authentication Partner network created by dotgay LLC to drive registrations. Registrars will also benefit greatly from the level of trust that dotgay LLC bestows upon them as an approved registrar for the .gay TLD.

Because Authentication Partners offer the direct link to eligible registrants through their membership base, dotgay LLC will focus on incentive programs that reward the Authentication Partners for each confirmed registration. Committed to an overall community-based approach to the .gay TLD, dotgay LLC feels it is essential to integrate and channel financial support back into the Gay Community wherever possible.

Authentication Partner Incentive Program

dotgay LLC’s Authentication Partner Incentive Program is intended to catapult growth in the early years of operation and fulfill the intended mission. Authentication Partners will be compensated for engaging their membership base with registrations in the .gay TLD while assisting in building out the index directory that will become a vital resource for the Gay Community globally.

By providing an opportunity to strengthen and financially support the Authentication Partners who have served as the foundation of the Gay Community in their regions, dotgay LLC will provide a separate and distinct way of funding the Gay Community beyond the dotgay Foundation discussed in the mission outlined in 18(a) above. Registrants who are members of multiple Authentication Partners will also have the option to choose which Authentication Partner receives credit for their registration by using them to acquire their CIC, giving registrants a choice of which organizations receive the credit.

18(c)iii

With the understanding that names on the .gay TLD will be sold at an initial premium wholesale price, it will be the goal of dotgay LLC to avoid any price escalation in the foreseeable future.

It is dotgay LLC’s commitment that the wholesale cost of second and third level names will not increase during the five years that follow the beginning of the Sunrise period. At the conclusion of the initial five year period, dotgay LLC reserves the right to, but is not required to, introduce a wholesale price increase at both second and third level on an annual basis with prior written notice as required by ICANN. The price escalation –if ever required- will not exceed 5% per year.