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
.OMEGA	The Swatch Group Ltd	fairwindspartners.com	View

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

Swatch Group believes that a proposed .OMEGA gTLD has the potential to offer the following benefits to Internet users and consumers:

- Establish a trusted, multilingual source of information and online marketplace for the millions of consumers that purchase goods and services through Swatch Group’s online retail stores and⁄or browse products through Omega’s website, for investors and third parties seeking information, and for the general Internet user population;
- Provide Swatch Group 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 Swatch Group to Swatch Group and qualified subsidiaries and affiliates;
- Develop a potential platform for the secure access to, purchase of, and distribution of Omega 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 OMEGA mark or variations of said mark that are registered by cybersquatters and⁄or criminal elements.

Omega does not expressly delineate its online content by country and instead maintains language-specific websites for its consumers around the world. Omega content is available in English, French, German, Italian, Spanish, Portuguese, Russian, Japanese, Simplified Chinese, Traditional Chinese (Hong Kong), Traditional Chinese (Taiwan), and Korean. These various websites are hosted under the OmegaWatches.com domain name using a hierarchical and structured naming convention that incorporates a linguistic pointer. Specifically, the naming convention is http:⁄⁄www.omegawatches.com⁄CC, where the two-character “CC” designation corresponds to the ISO-3166 country code, Spain (ES), France (FR), Japan (JP), etc. However, for technical reasons, the Asian languages are located in a relevant ccTLD extension; for example, Simplified Chinese content is available at http:⁄⁄www.omegawatches.cn⁄cn and content in Traditional Chinese for Hong Kong is available at http:⁄⁄www.omegawatches.com.hk⁄zh. In addition to these websites hosted under the OmegaWatches.com domain name, Swatch Group has registered its Omega mark at the second level in most ccTLDs, e.g., OmegaWatches.fr, OmegaWatches.es, OmegaWatches.jp, etc. Swatch Group also owns country code domain names like Omega.us, Omega.es, Omega.hk, and Omega.cn, which the company redirects to the appropriate OmegaWatches.com⁄XX destination. As identified in the response to Question 22 of this application, Swatch Group believes that the .OMEGA gTLD can provide an online single-source identifying function for its current and future customers around the world, instead of the present mix-and-match approach that Swatch Group is currently forced to employ in order to deliver online content to consumers in each of the world’s major regions.

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 .OMEGA gTLD is to provide a trusted, hierarchical, and intuitive online space to deliver Omega-branded retail content; information on the Omega brand, business, and focus; and other goods and services. As Swatch Group 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 its native Switzerland, in the United States, and internationally on various platforms, including the Internet and mobile devices, among others.

Given that customers increasingly demand access to Omega products and services through a variety of channels, which include domain names and the address bar, Swatch Group believes that a .OMEGA gTLD has the potential to provide an innovative, virtual avenue to Omega products that will deepen and broaden its relationship with consumers.

Most importantly, Swatch Group 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 Swatch Group, and a .OMEGA gTLD will be used to further that goal. While retail companies such as Swatch Group fight a never-ending battle to protect valuable intellectual property from piracy on the Internet, a .OMEGA gTLD potentially offers legitimate consumers a safe and intuitive means of accessing authorized content from Swatch Group and its qualified subsidiaries and affiliates.

Swatch Group is supportive of existing anti-cybersquatting legislation and consumer protection measures, including the U.S. Anti-Cybersquatting Consumer Protection Act (ACPA) and others. As Swatch Group invests in expanding the domain name space through the establishment of a .OMEGA gTLD, it will also actively prevent cybersquatting, fraud, phishing, and other malicious activities within the .OMEGA gTLD. Maintaining the highest standards within the .OMEGA gTLD will give Swatch Group the opportunity to take a proactive approach to protecting intellectual property rights and fostering a cleaner, 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 .OMEGA 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 .OMEGA gTLD. Using these levels as benchmarks, Swatch Group strives to build consumer recognition and trust in the usage of the .OMEGA gTLD that rise to the levels found in the .EDU and .GOV gTLDs.

As noted above, Swatch Group is a leading global retail company that leverages numerous distribution channels and emerging technologies to deliver its online content, products, and services to its customers internationally. A .OMEGA 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?

Swatch Group believes that the .OMEGA gTLD will provide a trusted destination for the millions of consumers worldwide that purchase the company’s Omega-branded retail goods and services, as well as those who seek information that Swatch Group 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 Swatch Group, thus protecting users from potential infringing, pirated, or harmful content within the .OMEGA gTLD.

The initial use of the .OMEGA gTLD will involve a limited number of second-level domain names. This initial use will provide Swatch Group’s IT and security personnel the ability to run a number of tests to ensure seamless and secure access to Omega’s websites and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Swatch Group will likely begin allocating domain names for internal corporate use and may redirect new .OMEGA 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, Swatch Group will evaluate potential strategies to migrate all traffic away from the current network of second-level domains registered in various gTLDs to the .OMEGA gTLD. This will provide customers with a centralized, 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.

Swatch Group currently intends for the .OMEGA gTLD to be exclusively used by Swatch Group and its qualified subsidiaries and affiliates, in particular by Omega. 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.
Notwithstanding these concerns, Swatch Group 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 retail company, Swatch Group 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 registered to Swatch Group or a qualified subsidiary or affiliate, at least in the initial stages of operation, Swatch Group has a vested interest to ensure that accurate and current domain name information is readily available in connection with each .OMEGA domain name. Swatch Group’s current privacy policy is available online at http:⁄⁄www.swatchgroup.com⁄en⁄services⁄privacy_policy. It is anticipated that Swatch Group will seek to operate the .OMEGA gTLD in a manner that is consistent with this policy, provided that it is not in conflict with any ICANN consensus policy.

In addition, Swatch Group 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.

Swatch Group sees the potential for this gTLD to play a large role in Swatch Group’s future online strategic initiatives for the Omega brand. 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 may influence the communication, marketing, and use strategies of the gTLD, Swatch Group anticipates a phased-in approach to using and promoting the gTLD, as described above.

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