gTLD	Full Legal Name	E-mail suffix	Detail
.GAP	The Gap, Inc.	fairwindspartners.com	View

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Gap Inc. believes that a proposed .GAP gTLD has the potential to offer the following benefits to Internet users and consumers:

-Establish a trusted source of information and an online marketplace for the millions of consumers who purchase goods and services from Gap, for investors and third parties seeking information, and for the general Internet user population;

-Provide Gap Inc., its partners, and affiliates with short and memorable Internet addresses; provide increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;

-Minimize the cost and need for defensive registrations because domain names will only be allocated by Gap Inc. within the .GAP gTLD to Gap Inc. and verified partners⁄affiliates; and

-Develop a potential platform for the secure access to, and purchase and distribution of Gap brand products and information to consumers, in order to minimize the potential for counterfeit or infringing goods and services.

Also, through the adoption of new gTLDs by the wider Internet user community, consumers may benefit from a lower incidence of phishing and malware often associated with mistypes of domain names in the .COM space that are owned by cybersquatters, since consumers will be navigating to domain names in the .GAP gTLD.

Currently, Gap Inc. operates a number of company websites using a combination of second-level and top-level domain names. A representative sampling of Gap Inc. websites that incorporate geographical identifiers into the domain name include:

-GapNewYork.com
-GapNYC.com
-GapSanFrancisco.com
-GapBoston.com
-GapCanada.com
-GapStore.ca
-Gap.cn
-GapStore.eu
-Gap.eu

Gap Inc. believes that a .GAP gTLD can provide an online single-source identifying function for its current and future customers around the world, instead of the mix-and-match approach currently required for expansion into different global markets.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .GAP gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to deliver Gap brand retail content, information about business and focus, and other goods and services. As Gap Inc. continues to expand, the company will continue to pursue and develop opportunities to market and distribute its online content and products to consumers, in the U.S. and internationally, and on various platforms, including the Internet and mobile devices. Given that customers increasingly demand access to Gap Inc. brands through a variety of channels, which include domain names and the address bar, Gap Inc. believes that a .GAP gTLD has the potential to provide an innovative, virtual avenue to Gap brand products that will deepen and broaden its relationship with consumers.

Most importantly, Gap Inc. will be able to provide access to its products and online content in a namespace void of piracy, cybersquatting and other malicious activities. Providing consumers with a trusted experience is paramount to Gap Inc., and a .GAP gTLD will be used to further that goal.

While retail companies such as Gap Inc. must constantly fight to protect their valuable intellectual property from piracy on the Internet, a .GAP gTLD potentially offers consumers a safe and intuitive means of accessing authorized content from Gap Inc. and its affiliates.

Gap Inc. is supportive of existing anti-cybersquatting legislation and consumer protection measures, including the U.S. Anti-Cybersquatting Consumer Protection Act (ACPA) and others. As Gap Inc. invests in expanding the domain name space through the establishment of a .GAP gTLD, it will also actively prevent cybersquatting, fraud, phishing, and other malicious activities within the .GAP gTLD. Maintaining the highest standards within the .GAP gTLD will give Gap Inc. the opportunity to take a proactive approach to protecting intellectual property rights and fostering a safer online experience for all Internet users.

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

As a branded gTLD, the primary driving factors of a .GAP gTLD are differentiation and innovation. The success of the gTLD will be measured not by the number of domain names registered, but rather by the level of consumer recognition and trust that is placed in the .GAP gTLD. Using this benchmark, Gap Inc. will strive to build consumer recognition and trust through usage of the .GAP gTLD that rise to the level found in the .EDU and .GOV gTLDs.

As noted above, Gap Inc. is a leading global retail company that leverages numerous distribution channels and emerging technologies to deliver its online content and consumer goods to customers internationally. A .GAP gTLD has the potential to serve as a cornerstone of this online strategy.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

Gap Inc. believes that the .GAP gTLD will provide a single trusted ecosystem experience for the millions of consumers worldwide who purchase the company’s products, as well as those who seek information about Gap Inc., including investors and members of the press. Consumers will know that domains and content on .GAP are owned and controlled by Gap Inc. and are thus more likely to be protected from infringing, pirated, or harmful content.

The initial use of the .GAP gTLD will involve a limited number of second-level domain names. This initial use will provide Gap Inc. the ability to ensure seamless and secure access to the Gap website and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Gap Inc. expects to begin allocating domain names for internal corporate use and may redirect new .GAP domain names to pre-existing content. This phased rollout will likely take place over a multi-year period, subject to change depending upon a range of external factors.

At the same time, Gap Inc. will evaluate potential strategies to migrate traffic away from the current network of second-level domains registered in various gTLDs, to the .GAP gTLD, which offers the potential to provide customers with a single, trusted online source for Gap brand products and services.

After consideration of the following factors: analysis of Gap Inc.’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Gap Inc. will have full control over the number of registrations in the .GAP gTLD namespace, Gap Inc. reasonably assumes that the number of domain name registrations will be less than 10,000 in the first five years of operation.

18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

Gap Inc. currently intends for the .GAP gTLD to be used exclusively by Gap Inc. and its partners⁄affiliates. Because of this condition, and because the Gap mark is a valuable brand, the protection of which is paramount to the company, Gap Inc. intends to address registration and use requirements in its partner⁄affiliate agreements, rather than in a domain name registration agreement.

Gap Inc. will, of course, incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each partner⁄affiliate will execute.

18.2.5 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.

As a global retail company, Gap Inc. respects the privacy of its customers and other consumers. The company employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information in its stores and on its websites. Gap Inc. will take similar precautions to protect registrant and user data associated with the .GAP gTLD. Furthermore, given that every domain name will be registered to Gap Inc. or a partner⁄affiliate, Gap Inc. has a vested interest in ensuring that accurate and current registrant information is readily available in connection with each .GAP domain name.

Gap Inc. will ensure that the operation of the .GAP will be consistent with Gap Inc.’s Privacy Policy, available on its website at http:⁄⁄www.gap.com⁄.

In addition, Gap Inc. intends to include contractual provisions to protect confidential and personal data in its registrar agreement, including provisions modeled after language in the template Registry Agreement that has been successfully utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states, “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (‘Personal Data’) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.ʺ

18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Gap Inc. sees the potential for the .GAP gTLD to play a large role in the company’s future online strategy. While the extent of likely benefits is currently uncertain due to questions of consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace, all of which will influence the communication and usage strategies for the gTLD, Gap Inc. anticipates a phased-in approach to using and promoting the .GAP gTLD.

As a first step, Gap Inc. plans to start using .GAP domains initially as redirects to existing .COM domains. Subsequently, Gap Inc. expects to initiate a targeted rollout using select gTLD domains as primary addresses and, after careful analysis and study of this rollout, Gap Inc. may engage in a broader initiative, should the results be satisfactory and in accordance with the company’s overall strategic goals. The actual usage of .GAP domain names will dictate what public communications and consumer outreach is conducted to encourage navigation to the .GAP gTLD, including advertising, media outreach, in-store communications, email campaigns, etc.

gTLD	Full Legal Name	E-mail suffix	Detail
.ESURANCE	Esurance Insurance Company	fairwindspartners.com	View

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

ESIC believes that the proposed .ESURANCE gTLD has the potential to offer numerous benefits to Internet users and consumers and to establish a trusted online marketplace for the millions of customers using ESIC’s online resources, the investors and third parties seeking information, and the general Internet user population.

In addition, .ESURANCE will provide ESIC and potentially its qualified subsidiaries, affiliates, and business partners having the Required License with short and memorable Internet addresses and an increased ability to navigate to information about ESIC products and services, while minimizing the cost and need for defensive registrations because domain names within the .ESURANCE gTLD will only be allocated internally to ESIC and potentially its subsidiaries, affiliates and business partners having the Required License.

ESIC intends to also use .ESURANCE to develop a potential platform for the secure access to, and research, purchase, and distribution of ESIC content, services, and information to consumers, in order to minimize the potential for phishing, pharming, or other harmful online activities.

ESIC believes that a .ESURANCE gTLD can provide a single, online source identifying function for its global customers, instead of the current mix-and-match approach that ESIC is currently forced to resort to as it expands into different markets around the world.


18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission of the .ESURANCE gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to aggregate content and other offers and services. As ESIC and its affiliates continue to expand, the company will want to pursue and develop new opportunities to market and distribute its information, products, and services to consumers in the U.S. and internationally, on a variety of platforms, including the Internet and mobile devices. Given that customers increasingly demand access to ESIC policy information through a variety of channels, which include domain names and the address bar, ESIC believes that a .ESURANCE gTLD has the potential to provide an innovative, virtual avenue by which to access content from ESIC and its qualified subsidiaries and affiliates, which will deepen and broaden the companyʹs relationship with consumers.

Most importantly, ESIC will be able to provide access to information about its products and services in a namespace less affected by piracy, cybersquatting, and other malicious activities. Providing consumers with a trusted experience is a paramount goal to ESIC, and the .ESURANCE gTLD will be used to further that goal. Given the high saturation of insurance-related sites, including many that offer misleading or incorrect information to users, the .ESURANCE gTLD offers assurance that current and prospective ESIC policyholders are receiving authorized, up-to-date information, all in the global public interest.

While insurance providers, such as ESIC, fight never-ending battles to protect their valuable intellectual property from fraud and piracy on the Internet, a .ESURANCE gTLD potentially offers legitimate consumers a safer and more intuitive means of accessing authorized content from ESIC.

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

As a branded gTLD, the primary driving factors of applying for the .ESURANCE gTLD are differentiation and innovation. The success of the gTLD will not be measured by the number of domain names registered. Instead, it will be measured by the level of consumer recognition and trust that is placed in the .ESURANCE gTLD.

Using this benchmark, ESIC strives to build consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.

As noted above, ESIC, together with its affiliates, forms a leading insurance services company that leverages emerging technologies to deliver information, products, and services to its consumers on a national scale. The .ESURANCE gTLD has the potential to serve as a cornerstone of this online strategy, if the potential consumer benefits that ICANN experts have forecasted become a reality.

A .ESURANCE gTLD also ties in closely with ESIC’s commitment to the environment. In addition to a claim vehicle fleet that is 100% hybrid, by offering a paperless customer experience, ESIC estimates that it has helped save over 3,520 trees since 2000. By providing increased opportunities for consumers to use the Internet to engage in commerce in a safe and trusted environment, ESIC minimizes the potential negative impact on the environment.


18.2.3 What goals does your proposed gTLD have in terms of user experience?

ESIC believes that the .ESURANCE gTLD will provide a single, trusted ecosystem experience for the millions of current and prospective policyholders in North America seeking information about its and its affiliates’ services. ESIC currently offers the following services online 24⁄7 through its flexible technology platform: delivering fast and accurate car insurance quotes; the ability of customers to manage their policy in real time; and filing a claim and checking its status online.

As one of the pioneers in the online insurance sector, ESIC will look to integrate these existing services into the new gTLD hierarchy and infrastructure, while evaluating other potential opportunities for innovation.

At minimum, the proposed .ESURANCE gTLD will provide consumers with short, memorable, and intuitive domain names to navigate the ESIC website. The general availability of these shorter domain names is a critical aspect for the growing number of consumers that navigate the Internet and use ESIC’s services through mobile devices. In addition to providing consumers with short, memorable, and intuitive domain names, ESIC hopes to have robust safeguards to minimize any fraudulent activity within the .ESURANCE gTLD.

The initial use of the .ESURANCE gTLD will involve ESIC registering a conservative number of second-level domain names. This initial use will provide ESIC’s IT and security personnel the ability to run a number of assessments for seamless and secure access to the ESIC website, and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, ESIC plans to begin allocating domain names for internal corporate use and may redirect new .ESURANCE domain names to pre-existing content.

This phased rollout will likely take place over a multi-year period, but is subject to change depending upon a range of external factors, and will be in line with ESIC’s marketing strategy and technology needs.


18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

The .ESURANCE gTLD is initially intended to be exclusively used by ESIC and potentially its qualified subsidiaries and affiliates. Should business partners eventually be allowed to register second level domain names, each will have the Required License which will terminate in the event of a misuse. The termination of the Required License will result in the deletion of any second level domain name(s) registered to any such business partner. Because of this intended use, any registration and use requirements are more appropriately vested in these corporate⁄affiliate agreements and in the Required License (if any), not in a domain name registration agreement itself.
While ESIC is fully supportive of, and committed to, ICANN’s bottom-up, consensus-driven model, the ESIC mark ESURANCE is a valuable brand whose protection is of paramount importance; therefore, any registration and use requirements (e.g., trademark quality control provisions) must, necessarily, vest in these other agreements.
Notwithstanding these concerns, ESIC will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each registrant will execute.

18.2.5 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.

As an online business, ESIC recognizes first hand that this is an evolving area of law in which there is not a single international standard. ESIC respects the privacy of its customers and other consumers. As an insurance provider, ESIC is regulated by federal and state laws protecting the confidentiality and security of customer information, as well as ESIC’s use and disclosure of such information.

ESIC will ensure that the operation of the .ESURANCE gTLD will be consistent with relevant local and national laws governing privacy rights protection, as they are interpreted and applied, and has obtained a similar warranty from its backend services provider.

In addition, ESIC intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language which has been included in the template Registry Agreement and which has been successful utilized by existing ICANN gTLD Registry Operators.

The new gTLD Registry Agreement states “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (“Personal Data”) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.ʺ


18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

ESIC sees the potential for this gTLD to serve as a component of ESIC’s future online strategic initiative. However, there remain a number of unanswered questions concerning consumer recognition and adoption of new gTLDs in the marketplace that first must be fully answered to ESIC’s satisfaction.

ESIC plans to start using these domain names primarily as redirects to existing .COM domains. After careful analysis and study of a targeted pilot rollout using the new .ESURANCE domains as addresses, ESIC may plan to engage in a broader, strategic initiative, should the results be positive. The actual usage of .ESURANCE domain names will dictate what public communications and consumer outreach may be done to encourage navigation to the .ESURANCE gTLD. This is not limited to, but may include advertising, media outreach, and email campaigns. However, there is currently no specific plan or budget for such communications given the uncertainty of consumer adoption of new gTLDs in the marketplace.