18(a) Describe the mission/purpose of your proposed gTLD

Prototypical answer:

Applicant’s parent company, ICM Registry LLC (“ICM”), brought into existence the Internet’s only existing adult-targeted top level domain (“.XXX”). .XXX is a sponsored top level domain (“sTLD”), whose sponsoring organization is the International Foundation for Online Responsibility (“IFFOR”). ICM was entrusted to certify that each of its registrants adopt responsible business practices designed to combat child abuse images, facilitate user choice and parental control regarding access to online adult entertainment, as well as protect privacy, security and consumer rights.

Applicant, a wholly owned subsidiary of ICM, will leverage ICM’s experience and consumer trust by providing the proposed gTLD at a more competitively priced offering.
Applicant will utilize the best practices, expertise, relationships, resources, and goodwill the parent company has generated throughout the decade it has been focusing on the sensitivities, opportunities, and responsibilities inherent in operating an adult-targeted TLD. In doing so, Applicant strives to empower entities around the globe, spur innovation, facilitate trade and commerce, and enable the free and unfettered flow of information while ensuring the protection of minors, respecting the free speech rights of the adult industry, increasing brand protection for non-adult brands and facilitating user choice for Internet users who are not interested in accessing adult content on the new gTLD.

In light of .XXX’s unparalleled exposure through its multi million dollar marketing campaigns and significant first mover advantage as the adult domain extension of choice for the global adult entertainment industry (“AEI”), Applicant believes that the .XXX TLD is and will likely continue to be universally recognized as the pre-eminent TLD for the AEI. Applicant believes that .XXX will maintain its status as the first choice adult-targeted TLD because the protections offered on each .XXX website, such as daily malware scanning and automated family safety tagging, as well as the other benefits that accrue to .XXX registrants and consumers as a result of IFFOR’s polices, are impossible to replicate in a lower cost TLD.

That said, throughout ICM’s successful pursuit and launch of .XXX, Applicant learned that there are members of the AEI who chose not to, or were unable to, participate in .XXX, whether on the basis of price, inability to satisfy the sTLD membership criteria, or a general unwillingness to adopt or implement the policies promulgated by IFFOR. ICM learned that these constituencies within the AEI maintain a philosophical skepticism about, or an outright rejection of, granting a third party organization, i.e. IFFOR, the authority to create TLD policies that they perceive as potentially interfering with their own business policies and practices.

Applicant notes that while some constituents within the AEI have expressed the above -mentioned concerns regarding IFFOR’s policy making authority with respect to .XXX, Applicant itself believes that the multi-stakeholder approach embodied in the IFFOR policy making process, which includes a formal and transparent Policy Development Process (“PDP”) resulting from community-based participation, is ultimately a safer and more trustworthy process for policy making than the proposed lack of process available to all registry operators under the new gTLD Registry Services Agreement. Under the new gTLD Registry Services Agreement, registry operators are authorized to establish policies and TLD registration criteria without any of the oversight required under the Sponsoring Organization model. Applicant believes there is a potential risk under the new gTLD Registry Services Agreement that registry operators, especially unscrupulous registry operators who are not held accountable to a PDP-like process, may have more flexibility and less restraint required when making and imposing policies that impact their TLDs. These potentially unscrupulous registry operators, with unfettered limitations, may elect to impose new policies over their registrants that impact not only registrants, but also end-users and Internet stakeholders-at-large, without the benefit of the commentary, representation, or transparency that inherently exists in a sponsored TLD model, like .XXX. Applicant is, however, not currently aware of any existing AEI commentary regarding registry operators unrestricted policy making freedom available under the new gTLD program (as contrasted with the concerns Applicant is aware of by some constituents regarding the IFFOR policy making process).

In light of these concerns, certain AEI constituents have elected not to register .XXX names and thus Applicant believes that this new, competitively priced gTLD will provide these AEI constituents an opportunity to obtain adult-related TLD names without the IFFOR-related opportunities for policy making authority that they have expressed concerns regarding. Essentially, Applicant has listened to the concerns expressed to ICM by these constituencies and wishes to offer a new, alternative, adult targeted TLD that operates at a lower price point and does not have the same qualifying and operational requirements as those that exist in a sTLD like .XXX. Applicant’s mission and purpose is to expand the pool of adult-targeted TLDs and to provide the AEI an adult-targeted gTLD that clearly identifies their products and services to end-users, without certain perceived barriers to entry expressed by certain constituents within the global adult entertainment industry.

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