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18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

gTLDFull Legal NameE-mail suffixDetail
.dotafricaDotConnectAfrica Trustyahoo.comView
i. The ICANN new gTLD programme will make it possible to have more Internet domain names beyond the current 22 generic Top-Level Domain names, and two-code country Top Level Domains (ccTLDs), thus providing users and registrants with a wider choice in the type of domain names they can register. The introduction of the DotAfrica gTLD will increase and widen the choice of domain names available to registrants since this will also make DotAfrica domain names available to users who wish to use it for different purposes such as creative marketing, innovation and branding of businesses, products, and services, thus consolidating the ‘African Brand’ on the global Internet platform. DotAfrica is expected to promote an African identity on the Internet by boosting Africa’s online presence and visibility on the Internet.
DotAfrica gTLD will therefore have the reputation as the domain name of choice for promoting African brands (brands.africa) and identity on a global scale, as Internet domain names creatively use the DotAfrica name extension for a wide range of local and global products, services, brands, companies, etc. It will be typified by high levels of quality service to users and registrants.
The geographic name ‘Africa’ will uniquely position the DotAfrica gTLD to specialize in all things that relate to Africa, in a way that presents vast opportunities for all those who are interested in Africa for any possible number of reasons.

ii: It is widely anticipated that the programme to introduce new top‐level domains has the potential to promote competition in the provision of registry services, to add to consumer choice, market differentiation and geographical and service‐provider diversity. (See for example http:⁄⁄www.icann.org⁄en⁄news⁄announcements⁄announcement-09nov10-en.htm) DotAfrica is expected to increase the level of competition in the domain name industry - both globally, and within the African continent - whilst improving customer choice, creating further market differentiation and geographical diversity in the ownership and operation of registry services. For instance, it is already envisioned that a successful delegation of the DotAfrica gTLD based on DCA’s new gTLD application will result in the first African-based gTLD registry operator.

Accordingly, DCA Registry believes that diversity and competition in the provision of registry services will result from the introduction of the new DotAfrica gTLD. This would be of immense benefit to registrants, registrars and domain name resellers in Africa and globally. The DotAfrica gTLD creates a unique opportunity for Africa to develop its own locally hosted gTLD registry, serving Africans from within Africa. DCA Registry Services intends to host the back-end registry system in a data centre in Nairobi, Kenya to support the technical functions of the DotAfrica gTLD Registry. The location of a world-class gTLD registry service in an African country would greatly contribute to technology transfer as registry operations and technical management skills are acquired by local staffs that participate in the project of establishing and running the registry. It is anticipated that adequate training shall be provided for the DCA local technical and operations staff in Kenya thereby aiding the process of technology transfer to African ICT professionals.

Apart from offering approved registry services, it is our intention to optionally provide Internationalized Domain Names (IDNs) support for Arabic and Latin at the second-level even though DotAfrica is not an IDN TLD. Therefore, DotAfrica will be considered as an ASCII TLD which offers IDNs (Arabic and Latin) optionally at the second level.

A) Improved Competition:
The potential users of DotAfrica domain names include commercial registrants, non-profits, governmental⁄inter-governmental organizations, and individual users. At the registry level, DCA DotAfrica Registry Services intends to adopt an open registration policy, thereby increasing the number of players competing to provide higher levels of service at affordable prices for Africans and other global users. DotAfrica gTLD will create improved competition in terms of choice, pricing, services and further opportunities for registrars and resellers.

1) Choice:
The DotAfrica gTLD will increase the range of choices for African Internet users who can now use the DotAfrica domain alongside their own ccTLDs and other gTLD names and by supporting the development of new African TLD initiatives such as: cities.africa for African cities; communities.africa to serve the diverse and rich cultural heritage of African communities; and brands.africa for Africa’s emerging brands; and IDNs support at the second-level particularly for the Arabic-speaking countries of North Africa within the framework of ICANN’s new gTLD policy.

Competition in the Domain Marketplace will come through employing an ICANN standard registry-registrar model where domain name registrants will be able to buy DotAfrica domains from multiple ICANN-Accredited Registrars with the advantage of lower prices and more Internet products.

2) Pricing:
Based on our research, African ccTLD Domains cost an average of $80 per annum, and this comparatively high cost has led to the low uptake of domain names. Most users cannot afford to purchase ccTLD domain names, forcing them to host content on free services like Wordpress and BlogSpot. This prevents the development of meaningful content in Africa’s Internet space. Our proposed pricing model aims to offer domain registrations at a cost commensurate with the income levels of Africans. The proposed selling price of US$10.00 per standard domain name will be price-competitive with the price offered by global registrars for a typical gTLD domain name.

3) Equality⁄Non-Preferential Treatment in Delivery of Service:
In adherence to the Registry Operator Code of Conduct obligations enshrined in Specification 9 of the new gTLD Registry Agreement, DCA will aim at ensuring equality and non-preferential treatment of registrars in the delivery of registry services. Since DCA Registry Services will not be providing registrar services, we will work to develop the DotAfrica namespace amongst African Internet users without conflict of interest, preferential treatment of registrars or preferential pricing; Our registry Web front-end and support for the latest registry protocols will make it simpler and easier for all registrars to deal with DCA DotAfrica Registry Services on an equal basis (non-discriminatory access to registry services) in keeping with ICANN mandatory guidelines and Consensus policies, thereby reducing the cost of entry into the market place and enhancing competition amongst ICANN-accredited registrars.

4) Marketing Opportunities for Domain Name Resellers in Africa:
African domain name resellers of existing gTLDs are at a great disadvantage relative to their competitors in the more advanced Internet markets since African resellers have to expend higher marketing budgets, are faced with higher broadband costs, low user awareness on the importance of domain names and other products like SSL certificates have made the reseller business in Africa very difficult. DCA Registry Services along with its back-end registry services partner – CentralNIC - plans to utilize a sizable marketing budget to promote different sales and marketing incentives for African resellers including but not limited to marketing grants, technical support and training; approving resellers to sell premium domains, price incentives, etc.

B) Differentiation
DCA Registry Services proposes to differentiate DotAfrica from existing TLDs and other new gTLDs through communication and marketing programs aimed at positioning DotAfrica as a vibrant domain namespace in which organizations and individuals within the continent can express their Pan African outlook and identity on the Internet. DCA will provide a world-class registry service based on technical excellence and customer service as the means of creating a unified Internet identity for Africa through DotAfrica gTLD.

Our approach for differentiation would entail attaching a brand value to DotAfrica both in Africa and globally as the gTLD for the African Region, by drawing on the African desire for unity and integration to express a consolidated Pan-African online identity. While there are no competing or confusingly similar domains to compel us to strictly differentiate DotAfrica we are confident that differentiating DotAfrica will help define DotAfrica in the minds of users as a TLD that offers continent-wide branding possibilities as opposed to country specific ccTLDs.

Differentiation will be further achieved based on the Whois service and strong marketing approach to be adopted by DCA DotAfrica Registry services:
• WHOIS Service: The implementation of a “Thick” Whois output service as part of the DotAfrica Registry system would allow interested third parties to look up the registrant, administrative, technical, billing and DNS delegation information for registered domain name(s) in such form as set forth in Specification 4 of the New gTLD Registry Agreement; coupled with a strict privacy policy will create a technical platform to support the development of a range of new and valuable DNS services for the Global and African Internet user.
• Marketing: Marketing would be vital in promoting the adoption of DotAfrica domain names. Several marketing initiatives will be undertaken by DCA based on a proper market assessment and estimation of demand, and a well-structured marketing plan that targets various language-speaking groups in different regions of Africa such as (a) Northern Africa – an Arabic-speaking region; (b) Francophone Africa which comprises of French-language speaking countries in West⁄Central Africa; Anglophone Africa aimed at the English-speaking countries in West, East and Southern Africa; and (d) Lusophone Campaign aimed at the Portuguese⁄Spanish-speaking African countries. Each region will be further segmented to reflect the various target user groups.

Registrars and reseller will also be engaged as part of the DotAfrica gTLD marketing programme with various incentives schemes provided for registrars. We intend to allocate part of registrar’s expenditure up to a cap of gross registrations to support such planned incentives.

DotAfrica gTLD will offer a Pan-African identity appeal and outlook, a trusted and secure namespace, and brand⁄trademark protection that would make it possible to market to brands and commercial organizations in Africa and global companies doing business in Africa.

III: A snap survey and analysis conducted by DCA reveals that current user experience with the ccTLDs has been largely typified by poor levels of customer satisfaction, since users have to cope with an under-developed reseller system. This is mainly attributed to the fact that the ccTLDs registries do not have the latest technologies thereby making users to show preference for the services offered by other gTLD registries. Therefore, we intend to offer an improved user experience based on better quality customer services to be achieved as follows:

1. Physical – DCA DotAfrica Registry will implement an all new registry system that will be user-friendly and based on world-class technologies, using an up-to-date registry services management system platform. It is anticipated that this will provide an entirely new experience for users and registrants of the DotAfrica gTLD typified by high levels of customer satisfaction.
2. Social - Availability of DotAfrica domain names will affect the way people perceive and ascribe value to domains names in Africa. This is expected to trigger a positive effect that will change how domains are utilized creatively and innovatively, thereby creating a new form of Internet user experience as DotAfrica gTLD names are widely and rapidly adopted.
3. Infrastructural - Availability of a good registry system that will ease the current user problems and provide a registry services management platform that is built according to an acceptable global standard will encourage rapid uptake, multiple registrations and lower cost of domain names.

iv. As already explained, DotAfrica gTLD is not a community-based TLD, and as such will not be subjected to any community-based restrictions in its registration policies. Rather, as a standard geographic gTLD serving diverse needs and purposes, it will have open registration policies that would enable it attract a very large population of users and registrants from the global Internet community.
Therefore, in keeping with the spirit of global access, innovation, and competition promoted by the TLD and by the applicant, DCA DotAfrica Registry believes that the registration of domains should be open to all parties for legitimate purposes. Due to the specific and descriptive nature of the string, it is expected that registrations will be relevant to the nature of the TLD; however, Applicant does not wish to impose validation criteria as it believes it would only increase cost and restrict innovation – which goes against ICANN’s and Applicant’s goals for the TLD.

DCA DotAfrica Registry does, however, intend to enforce an Acceptable Use Policy to ensure that the zone remains stringently protected from illegal content or activity, and the UDRP, URS, and all other ICANN-required rights protection mechanisms will form an integral part of the domain registration policy compliance process. Applicant will also provide additional rights protection mechanisms beyond ICANNʹs requirements as set forth in written answers to questions 26, 28, and 29. To minimize abusive registrations, DCA DotAfrica Registry Services will adopt an Acceptable Use Policy that will allow it to cancel the registration of a domain name if the name is in violation of the Policy. Additionally, Applicant will undertake communications efforts to encourage reporting and execute rapid takedown of domains in violation of the Acceptable Use policy.

As further detailed in the responses to questions 28 and 29, DCA DotAfrica Registry will implement all rights protection mechanisms required by ICANN (including but not limited to the URS and the UDRP) and will additionally operate a Sunrise period for Trademark holders prior to General Availability (again, in accordance with all ICANN rules). Additional rights protection mechanisms, beyond ICANN requirements, are described in response to questions 26, 28, and 29.

Note that the Registration Policies also references the Acceptable Use Policy, ICANN Consensus Policies (in effect), and any other policies that may be adopted by DCA DotAfrica Registry or ICANN that would become applicable to DotAfrica gTLD.
A complete copy of the intended Eligibility and Acceptable Use Policy can be found in response to Question 29 (in Section 29.9).

V: There will be various measures implemented in the TLD for protecting the privacy or confidential information of registrants and users. In various jurisdictions, Data Protection and Privacy laws exist to keep citizen and consumer private information confidential and not publicly accessible, and protected from abuse or being stolen or illegally distributed for marketing purposes. Moreover, unauthorized disclosure of citizen’s private information exposes such victims to various social, economic and legal vulnerabilities.

According to ICANN, the use of personal data must be limited to the purpose for which it is collected; and as per the new gTLD Registry Agreement, we shall do our utmost to ensure that this requirement is satisfied, and that the personal data of users and registrants will be protected, not publicized, and used only for the purpose for which it has been collected.

For registrations under DotAfrica, only non-sensitive information of registrants and users will be made public. Reasonable steps will be taken to protect any personal data collected as specified under Article 2.17 of the new gTLD Registry Agreement.

Furthermore, DCA DotAfrica Registry shall:
1. Notify Registrar of the purposes for which registrant Personal Data submitted by Registrar is collected, the intended recipients of such Personal Data, and the mechanism for access to and correction of such Personal Data;
2. Take reasonable steps to protect them from loss, misuse, unauthorized disclosure, alteration or destruction; shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars;
3. May from time to time use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars;
4. Not use the information stored regarding the domain name holders in the DotAfrica Registry system for any spamming or marketing purposes.

VI: DCA’s promotional campaign for sensitization and awareness creation of ICANN’s new gTLD programme has helped to mainstream DotAfrica as the principal Internet discourse within Africa in recent years. This has been aided by regular email campaigns to circulate analyses and commentaries on topical Internet DNS issues, press releases, dissemination of quarterly newsletters, published blog articles; coupled with video productions, television interviews, sponsored exhibitions and advertisement on popular Internet governance platforms and conferences such as ICANN and IGF. All these have been employed to effectively communicate the message of the DotAfrica gTLD.

DCA has used these communication tools to explain the potential benefits of DotAfrica gTLD, and inform people on the positive impact this will have on the innovative use of domain names when the DotAfrica domains become generally available. When the gTLD is delegated, these forms of outreach will be further strengthened with a strong sales and marketing effort, and initiatives such as Yes2DotAfrica campaign (http:⁄⁄www.dotconnectafrica.org⁄yes-campaign⁄join-campaign⁄), generation.africa (http:⁄⁄www.prlog.org⁄11681274-generationafrica-on-their-high-at-the-6th-igf-held-in-nairobi-kenya.html), and miss.africa (http:⁄⁄www.dotconnectafrica.org⁄yes-campaign⁄miss-africa⁄). These initiatives shall be further powered by an active social media presence on micro-blogging sites such as Twitter and ‘friendship⁄conviviality’ sites such as Facebook which attract a younger Internet user demographic.

As a result of concerted promotional and campaign activities undertaken by DCA during the past couple of years, DotAfrica received a lot of press coverage in different local, regional and global news media. Such press coverage has been organized into a media briefing kit, which may be found at: http:⁄⁄www.dotconnectafrica.org⁄press-room⁄press-kit⁄ and http:⁄⁄www.dotconnectafrica.org⁄press-room⁄global-media-coverage⁄

As part of its outreach and communications efforts, DCA has made over 56 press releases and Executive Briefings, and received over 79 global press coverage in print and electronic media, in addition to press coverage in over 21 foreign language news media; reaching a potential audience of nearly 100 million people globally. Such archived press releases and other media campaign iinfo are available at:
http:⁄⁄www.dotconnectafrica.org⁄yes-campaign⁄accomplishments⁄ and http:⁄⁄archive.constantcontact.com⁄fs053⁄1102516344150⁄archive⁄1103885604203.html

DCA already employed a combination of useful communication tools and strategies to achieve significant successes in the course of promoting DotAfrica during the last few years (See http:⁄⁄www.dotconnectafrica.org⁄major-milestones⁄).

It is envisaged that when the DotAfrica gTLD is delegated such efforts shall be re-doubled to enable DCA achieve its projected benefits.
gTLDFull Legal NameE-mail suffixDetail
.srlCharleston Road Registry Inc.google.comView
18.b. Benefits to Registrants, Internet Users, and Others

18.b.i.1. Specialty

The goal of the proposed gTLD is to create a new Internet environment that provides registrants with the opportunity to associate with a meaningful term.

Charleston Road Registry, as the registry operator, will define the specialized meaning of the term and, based on this definition, will identify criteria for registrants to operate in the proposed gTLD. Only entities that meet these criteria will be entitled to register for a domain in the gTLD. Specialization, therefore, arises from the Charleston Road Registry definition of a term, as well as through market dynamics as entities align their offering(s) with the term. This specialization will be maintained through intermittent audits to ensure the relevancy of content in the proposed gTLD to the defined meaning of the gTLD.

The specialization goal of the proposed gTLD is to create a new Internet environment that provides registrants with the opportunity to associate with the term ʺsrl,ʺ a commonly used international acronym signifying a business. This specialization introduces a new domain name hierarchy with the express purpose of creating increased competition in the gTLD space through providing businesses with an alternative to .com.

18.b.i.2. Service Levels

Through its association with Google, Charleston Road Registry is uniquely positioned to enable and support the proposed gTLD by providing its service reliability and speed of delivery as a part of its services. Google brings unique expertise and a proven record of excellence in infrastructure operations: Google now runs the largest DNS system in the world, has industry-leading uptime on its services, such as web search, and offers enterprise services on which governments and businesses depend.

Google is known for its high level of quality and speed, and Charleston Road Registry’s service level goal for the proposed gTLD is to extend that high level of quality, speed, and service to registrars. Indeed, two of Google’s core principles are “focus on the user and all else will follow” and “fast is better than slow.”

Charleston Road Registry is committed to using the most technologically advanced, secure, and reliable registry services for all of the domain names in the gTLD so as to not compromise the service levels, security, and stability of the gTLD to users across the globe.

Charleston Road Registry will provide both Engineering and Customer Service support to registrars. All registrars will also have the same level of access to Charleston Road Registry resources to resolve disputes and technical and⁄or administrative customer service issues.

Charleston Road Registry will provide all registrars with 24-hours-a-day, 7-days-a-week Customer Support in the form of telephone, email, and⁄or web chat for technical and non-technical issues relating to the operation of the gTLD system. Charleston Road Registry will provide all registrars with the same level of access to customer support via telephone, email, and Charleston Road Registryʹs website; email and web-based interactions will be the primary method of provisioning customer service support to registrars.

18.b.i.3. Reputation

Google has a proven record of providing high-quality, secure online services. Charleston Road Registry seeks to enhance Google’s reputation for excellence, superior quality, and high level of security and become known as an exemplary domain name services provider. When registrants assess opportunities in the marketplace to obtain a name, they will have confidence in Charleston Road Registry’s ability to meet ongoing needs as the registry operator for the proposed gTLD. When Internet users visit a domain name in the proposed gTLD environment, they will be able to reliably expect and experience the high level of security and quality on which Google’s reputation has been built.

The registry will be structured in such a way that Charleston Road Registry will enable registrars to register and oversee second-level domain names in the proposed gTLD; that registrars develop and deploy a reasonable process for ensuring that those domain names are used for gTLD-relevant purposes as specified in the registry-registrar agreement; that the WHOIS is thick and reliable; and that the registry is responsive to legal rights owners (if applicable) who may have complaints about potentially abusive registrations.

Charleston Road Registry plans to develop and publish eligibility criteria for all registrants in the proposed gTLD and will work with its registrars to execute the eligibility verification process. This process will imbue additional meaning to all second-level domains in the gTLD and enhance the gTLD’s reputation by establishing an authoritative community of content providers. When Internet users visit a website in the proposed gTLD environment, they will be able to reliably expect content relevant to the proposed gTLD.

In addition, Charleston Road Registry’s operation of the new gTLD will provide the opportunity for registrars and registrants to build and⁄or bolster their unique brands and brand reputation in association with the proposed gTLD.

18.b.ii.1. Competition

Charleston Road Registry supports the advancement of registry operators as a whole and the diffusion of gTLDs amongst diverse stakeholders to generate increased competition for the benefit of the Internet public. Increased competition will result in more competitive prices for consumers, generate efficiencies and increase productivity in enterprises, and spur innovation in the gTLD space.

The proposed gTLD, .srl, will provide a new online structure for the aggregation of business-specific content. As an alternative to existing second-level domains, in particular .com, Charleston Road Registry anticipates that the .srl gTLD will increase competition among registrars by allowing for further product and pricing differentiation. Charleston Road Registry also anticipates the .srl gTLD will grow the volume of businesses offering content online, thereby increasing competition among businesses.

Managing this namespace will allow Charleston Road Registry to provide to registrars and registrants the high level of technical operations quality and service for which Google is known, which in turn will incent other existing and new gTLDs to improve the quality of their offerings.

Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines and fully complying with the Registry Operator Code of Conduct. Charleston Road Registry is committed to treating all registrars equitably and will not offer preferential treatment to Google in its capacity as registrar.

18.b.ii.2. Differentiation

Charleston Road Registry believes in the commercial viability of alternatives to existing gTLDs such as .com and .net.

The proposed gTLD will provide the marketplace with an authoritative space for registrants to deliver content, imparting brand differentiation not currently available in the current gTLD space. It also delivers value to the Internet public by defining the meaning of the gTLD term, providing for the verification of registrants who will offer content in the proposed gTLD environment, and encouraging a specific use. These activities differentiate the proposed gTLD space in a new and meaningful way.

The .srl gTLD will provide a new mechanism whereby businesses and individuals can differentiate their content by signifying that their offerings are relevant to a second-level domain name-specific business. This signification is currently available in the gTLD space; however, the new gTLDʹs provision will exert competitive market influence on the provision of .com, likely inducing service-oriented differentiation among registrars.

In addition, given its association with Google, Charleston Road Registry offers a unique value proposition to registrars and registrants resulting from the strength of Google’s trusted brand, technical leadership, and support for free speech on the Internet. Registrars will have the opportunity to leverage this brand in devising their own market positions.

18.b.ii.3. Innovation

The proposed gTLD will foster innovation by creating a new space for the categorization and classification of online content. It will therein provide a mechanism by which registrars and registrants can better brand and manage their online presence by associating it with the .srl namespace. This namespace delivers value to the public through the provision of new and differentiated content, goods, and services to Internet users.

The proposed gTLD, .srl, will promote innovation among registrars by providing for the sale of a second-level domain in a gTLD that will attract a specific segment of registrants for which there is currently a limited number of options. This provides registrars with the opportunity to create and offer tailored new products and services that benefit registrants and⁄or improve user experience in association with the registration of a second-level domain in the .srl gTLD. In addition, the concentration of both application creators and users in the .srl gTLD space will likely invite user comparison among second-level domain sites, incentivizing second-level domain registrant feature and service innovation as a point of differentiation.

Charleston Road Registry considers the proposed gTLD to be a platform for innovation with existing and future Google products and services. Charleston Road Registry, therefore, may incorporate these new offerings into future registry service options (subject to the ICANN approval process), infusing new ideas into the gTLD for the betterment of the public.

Google consistently aims to improve upon technologies that connect people with information, as demonstrated by a proven record of innovation and iteration. Charleston Road Registry strives to offer its constituents this same level of continuous development in advancing its management and operation of the gTLD, engendering benefits to registrars, registrants, and end users.

18.b.iii. User Experience

Charleston Road Registry will strive to provide the highest level of user experience through operational stability, security, and performance to serve the interest of registrants in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

The proposed gTLD will provide registrants with the opportunity to differentiate their dedicated domain space such that the end users are able to discern the type of content intended to be found within the proposed gTLD. This will enable increased user visibility of registrants’ offerings, as well as provide registrants with the opportunity to enhance their respective content offerings and innovate in new ways.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the .srl gTLD can flourish. Charleston Road Registry seeks to have users deem the gTLD trustworthy and reliable and recognize it as an aggregated source of targeted goods, services, and information.

The proposed gTLD, furthermore, facilitates an improved online user experience through greater structure and categorization on the Internet.

18.b.iv. Registration Policies

Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars. Domain names within the proposed gTLD will be available to the public for registration and use.

Charleston Road Registry is committed to implementing strong and integrated intellectual property rights protection mechanisms. Doing so is critical to Google’s goals of model Internet citizenship and fostering Internet development, especially in emerging regions. Accordingly, Charleston Road Registry intends to offer a suite of rights protection measures which builds upon ICANNʹs required policies while fulfilling our commitment to encouraging innovation, competition, and choice on the Internet.

Charleston Road Registry reserves the right to impose registrant verification enforcement policies on registrars.

Charleston Road Registry believes that the .srl gTLD will best add value to the gTLD space by limiting registration to only verified srl entities. Charleston Road Registry plans to require registrars to confirm that a domain applicant is a legally recognized srl in the country in which it operates via an established process. If the domain applicant passes the eligibility verification process, only then will the applicant be eligible to apply for a second-level domain in the .srl gTLD. Second-level domain names in the .srl gTLD must be related to the registered srl entity name. To preserve the integrity of the gTLD, Charleston Road Registry reserves the right to adopt certain monitoring measures, including periodic audits. Charleston Road Registry also reserves the right to adopt enforcement measures, including a request that registrars facilitate a user reporting method to log complaints and⁄or potential instances of misuse within the gTLD. If a registrant is found to be in violation of the terms of the registry-registrar agreement or the registrar-registrant agreement, Charleston Road Registry may request that the appropriate registrar enforce such agreements through penalties, including but not limited to suspension of the domain name.

18.b.v. Protection of Privacy and Confidential Information

Charleston Road Registry will strive to ensure the appropriate level of privacy and security will be met for its users. Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection; additional specifics regarding the practices for the registry include but are not limited to the following:

-All data transmitted from registrars to the registry will be encrypted using TLS or other similar data protection schemes to ensure that third parties cannot access personally identifying information or other sensitive data as it crosses the Internet.

- Charleston Road Registry will attempt to prevent the misuse of WHOIS data for improper purposes such as spam, intellectual property theft or phishing. Charleston Road Registry will attempt to identify patterns of abusive usage of WHOIS and will appropriately use CAPTCHA, query throttling or other techniques to prevent information scraping.

- Google will restrict access to data and information systems maintained by the registry to a specific list of individuals involved with supporting the Google Registry system in production. Google will review this list on a periodic basis to ensure that the level of access granted to individuals is appropriate. Google uses two-factor authentication and other mechanisms to ensure that staff with access to user information are properly identified prior to using registry systems.

- Google data backups stored offsite are encrypted with passwords that are securely managed on Google’s internal systems. Google can effectively remove the ability to access this data by destroying the relevant encryption password.

- Supplying Google account information will be optional for registrants unless the domain registration is directly associated with another Google product offering. Google will not disclose Google account information except for any contact information provided by the user that is required by ICANN to be displayed in response to a WHOIS query.

- Registrar billing and payment information will not be stored alongside domain name registration information. All registrar billing and payment information will be stored in a PCI-compliant billing system similar to that used by Google Ads.

- Data will not be shared with third parties without permission of registrants, except as required for registry operations or as required under the law, such as in response to a subpoena, other such court order, or demonstrated official need by law enforcement.

Beyond these specific mechanisms, both Charleston Road Registry and Google will govern its approach to privacy by the Google Privacy Policy. This policy applies to registrars, registrants and end users of registry services such as DNS zone publication and WHOIS data publication. The Privacy Policy is located at http:⁄⁄www.google.com⁄policies⁄privacy⁄.

18.b.vi. Outreach and Communications Efforts

Once Charleston Road Registry begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity to obtain domain space there through investments in marketing and public relations.

Charleston Road Registry intends to promote gTLDs in its portfolio collectively, such that the public gains an awareness and understanding of new gTLDs and the availability of new second-level domain space on the Internet. Charleston Road Registry believes that this approach will make the strongest impact in modifying consumer behavior and is the best path to achieving success for all new gTLDs collectively.

Charleston Road Registry will reach out to the Internet community via a number of different outreach and communications methods and venues to deliver its mission and message to the public, including but not limited to: press briefings, videos posted on various Internet sites, blogs and other social media, and paid advertising. In addition, when developing resources for localized Internet registrars in different global regions, Charleston Road Registry will use local marketing and communications platforms as needed.