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
.XEROX	Xerox DNHC LLC	fairwindspartners.com	View

18.2 HOW DO YOU EXPECT THAT YOUR PROPOSED GTLD WILL BENEFIT REGISTRANTS, INTERNET USERS, AND OTHERS?

Xerox believes that a proposed .XEROX gTLD has the potential to offer the following benefits to Internet users and consumers:

-Establish a trusted source of information and online marketplace for the millions of consumers that purchase goods and services through Xerox online and dealers, for investors and third parties seeking information, and for the general Internet user population;
-Provide Xerox with short and memorable Internet addresses that enable increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;
-Eliminate the cost of and need for defensive registrations by other brands because domain names will only be allocated by Xerox DNHC to Xerox and verified subsidiaries, affiliates, licensees, and strategic partners;
-Develop a potential platform for the secure access to, purchase of, and distribution of Xerox products and information to consumers in order to minimize the potential for counterfeit or infringing goods and services; and
-Increase consumer awareness to potentially minimize incidents of phishing and malware often associated with domain names that incorporate the XEROX mark or variations of said mark (typos) that are registered by cybersquatters and⁄or criminal elements.

Additionally, Xerox currently maintains 213 websites for 192 markets. The difference between the number of websites and markets is attributed to the fact that Xerox maintains multi-lingual websites for some markets, i.e., Canada (English⁄French), Luxemburg (German⁄English⁄French), Lebanon (English⁄French), Guinea-Bissau (French⁄Portuguese), etc. These 213 websites use a very structured naming convention in connection with each URL.

This naming convention is as follows: http:⁄⁄www.xerox.com⁄index⁄LLCC.html, where the two-character “LL” designation corresponds to the language of the website site, English (EN), Spanish (ES), French (FR), etc., and the two-character “CC” designation corresponds to the ISO-3166 country code, United States (US), France (FR), Argentina (AR), etc. As identified in the response to Question 22, Xerox DNHC believes that the potential use of geographic identifiers at the second level would be an innovative convention and highly beneficial for a global company such as Xerox.

Xerox DNHC does not initially anticipate offering registration of second-level domain names to its extended global network of 6,500 authorized sales agents and concessionaires, and 10,000 technology resellers. However, this expanded use of second-level domain names within the .XEROX namespace does potentially offer Xerox an enhanced trademark policing mechanism. Currently, Xerox is engaged in a continuous battle to ensure that this extended network of sales agents and resellers does not register domain names incorporating the XEROX mark. Providing this extended network of agents and resellers with registration and use of second-level domain names within the .XEROX gTLD is potentially a win-win situation for all involved parties. These agents and resellers are better able to market their strategic relationships with Xerox, and Xerox has the ability to revoke domain name rights in light of potential non-compliance.

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 .XEROX gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to deliver Xerox retail content, information on Xerox’s business and focus, and other goods and services. As Xerox continues to expand, it is the company’s desire 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, among others. Given that customers increasingly demand access to Xerox products and services through a variety of channels, which include domain names and the address bar, Xerox believes that a .XEROX gTLD has the potential to provide an innovative, virtual avenue to Xerox products that will deepen and broaden its relationship with consumers.

Most importantly, Xerox 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 Xerox, and a .XEROX gTLD will be used to further that goal.

While global companies such as Xerox fight a never-ending battle to protect valuable intellectual property from piracy on the Internet, a .XEROX gTLD potentially offers legitimate consumers a safe and intuitive means of accessing authorized content from Xerox and its partners.

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

Xerox DNHC will seek to operate the .XEROX gTLD in connection with the following core values by which Xerox has operated since its inception:

-“Succeed through satisfied customers.
-Deliver quality and excellence in all we do.
-Require premium return on assets.
-Use technology to develop market leadership.
-Value our employees.
-Behave responsibly as a corporate citizen.”

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 .XEROX gTLD are differentiation and innovation. The number of domain names registered will not measure the success of the gTLD, but rather success will be judged by the level of consumer recognition and trust that is placed in the .XEROX gTLD. Using this benchmark, Xerox strives to build consumer recognition and trust in the usage of the .XEROX gTLD that rises to the level of that found in the .EDU and .GOV gTLDs.

As noted above, Xerox is a leading global company that leverages numerous distribution channels and emerging technologies to deliver its online content, products, and services to its customers internationally. A .XEROX gTLD has the potential to serve as a cornerstone of this online strategy, if potential benefits that ICANN has projected become a reality.

18.2.3 WHAT GOALS DOES YOUR PROPOSED GTLD HAVE IN TERMS OF USER EXPERIENCE?

Xerox believes that the .XEROX gTLD will provide a single, trusted ecosystem experience for the millions of consumers worldwide that purchase the company’s goods and services, as well as those who seek information that Xerox provides, such as investors and members of the press. In addition to providing consumers with short, memorable, and intuitive domain names, consumers will know all domains and content are owned and controlled by Xerox, thus protecting users from potential infringing, pirated, or harmful content within the .XEROX gTLD.

The initial use of the .XEROX gTLD will be primarily defensive in nature, with Xerox DNHC registering a limited number of second-level domain names. This initial use will provide Xerox’s IT and security personnel the ability to run a number of tests to ensure seamless and secure access to the Xerox website and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Xerox DNHC will likely begin allocating domain names for internal corporate use and may redirect new .XEROX 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.

During this same period of time, Xerox will evaluate potential strategies to migrate all traffic away from the current network of second-level domains registered in various gTLDs to the .XEROX gTLD. This will provide customers with a single, trusted online source for its products and services.

18.2.4 PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANT’S INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.

Xerox DNHC currently intends for the .XEROX gTLD to be exclusively used by Xerox, its subsidiaries, affiliates, licensees, and strategic partners. Because of this controlled use, any registration and use requirements are more appropriately vested in corporate⁄affiliate agreements and not in a domain name registration agreement.

While Xerox DNHC is fully supportive of and committed to ICANN’s bottom-up, consensus-driven model, Xerox DNHC is mindful that some registries have had amendments to their registrar⁄registrant agreements delayed because of internal ICANN processes. Because the Xerox trademark is a valuable brand of which protection is of paramount importance, any registration and use requirements (e.g., trademark quality control provisions) must vest in these other agreements.

Notwithstanding these concerns, Xerox DNHC 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 partner 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 company, Xerox recognizes firsthand that privacy protection is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will be initially registered to Xerox or a qualified subsidiary or affiliate, Xerox has a vested interest to ensure that accurate and current domain name information is readily available in connection with each .XEROX domain name. Xerox’s current privacy policy is available online at http:⁄⁄www.xerox.com⁄about-xerox⁄privacy-policy⁄enus.html. It is anticipated that Xerox DNHC will seek to operate the Xerox family of gTLDs in a manner that is consistent with this policy, provided that it is not in conflict with any ICANN consensus policy.

In addition, Xerox 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.

While Xerox sees the potential for this gTLD to play a large role in Xerox’s future online strategic initiatives, there are a number of unanswered questions concerning consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace that will influence the usage of the gTLD and communication about that usage.

Notwithstanding these concerns, Xerox’s current best thinking involves an implementation of .XEROX domain names in a multi-stage approach set forth in Section 18.1.2 above. The actual usage of .XEROX domain names will dictate what public communications and consumer outreach initiatives are undertaken to encourage navigation to .XEROX gTLDs. This is not limited to, but may include advertising, media outreach, email campaigns, etc.