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
.MERCK	Merck Registry Holdings, Inc.	fairwindspartners.com	View

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

MRH believes that the proposed .MERCK gTLD has the potential to offer a variety of benefits to Internet end users, such as establishing a trusted source of information and online marketplace for the millions of end-users searching for related information through MSD’s online resources.

In addition, MRH anticipates that .MERCK can provide MSD and potentially its qualified subsidiaries and affiliates with short and memorable Internet addresses, as well as provide increased navigation to products, services, advertising campaigns, public interest content, and public awareness initiatives.

A .MERCK gTLD can also minimize the cost and need for defensive registrations because domain names within the .MERCK gTLD will initially only be allocated by MRH to MSDʹs internal departments and potentially to qualified subsidiaries and affiliates of MSD.

Also, end users may benefit from lower incidents of phishing and malware often associated with mistypes of domain names in the .COM space that are owned by cybersquatters since they will be navigating to domain names in the .MERCK gTLD.

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 .MERCK gTLD is to provide a trusted, hierarchical, and intuitive online marketplace for MSD content and other products and services. Given that end-users are increasingly demanding access to MSD information through a variety of channels, which include domain names, MRH believes that the .MERCK gTLD has the potential to provide an innovative, virtual avenue to content from MSD that will deepen and broaden its relationship with these end-users.

As MRH’s parent company, MSD, continues to expand its product offerings and research areas, the company has considered using .MERCK to pursue and develop opportunities to market and distribute its online content and products to end users on various platforms, including the Internet and mobile devices, among others. Providing end-users with a trusted experience is paramount to MRH and its parent company, MSD, and the .MERCK gTLD will be used to further that goal.

While healthcare companies, such as MSD, fight never-ending battles to protect their valuable intellectual property from fraud and piracy on the Internet, the .MERCK gTLD would offer end-users a safe and intuitive means of accessing authorized content from MSD and potentially MSD’s qualified subsidiaries and affiliates and potential licensees and strategic parties.

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 .BRAND gTLD, the primary driving factors of the .MERCK 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 levels of consumer recognition and trust that are placed in the .MERCK gTLD. Using this benchmark, MRH will strive to build consumer recognition and trust that rise to the levels of those found in the .EDU and .GOV gTLDs.

As noted above. MRH’s parent, MSD, is a leading healthcare company that leverages emerging technologies to deliver healthcare information, products, and services internationally.

The .MERCK gTLD has the potential to aid this online strategy, if potential consumer benefits that ICANN experts have anticipated become a reality.

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

MRH believes that the .MERCK gTLD will provide a single, trusted ecosystem experience for the millions of end-users seeking information about MSD and its products and services. In addition to providing end-users with short, memorable, and intuitive domain names, MRH will have best-in-class safeguards to minimize any potential infringing or pirated content within the .MERCK gTLD.

MSD will continue to stay abreast of changes in the new gTLD space following commencement of operations and will adjust its strategy as needed to ensure it is providing the most valuable and relevant experience for end users.

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

The .MERCK gTLD is currently intended to be exclusively used by MSD and potentially MSD’s qualified subsidiaries and affiliates.
Because of this condition precedent, any registration and use requirements are more appropriately vested in corporate⁄affiliate agreements and not in a domain name registration agreement. MRH reserves the right to consider allowing third party registrants outside of current affiliate or subsidiary relationships to own .MERCK domains for a fee at a future date. This would only be determined following an extensive, internal evaluation of MSD’s on-going branding and online goals, and discussions with MSD’s registry services provider.

MRH will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the appropriate agreements.

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.

MSD recognizes first hand that this is an evolving area of law in which there is no uniform international standard. As a global healthcare company, MSD respects the privacy of its end-users. The company employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information on its websites. MRH will take similar precautions to protect registrant and user data associated with the .MERCK gTLD.

Furthermore, given that every domain name will be registered to MSD or potentially a qualified subsidiary or affiliate and potentially licensees or strategic parties, MRH has a vested interest in ensuring that accurate and current registrant information is readily available in connection with each .MERCK domain name.

MSD will ensure that the operation of the .MERCK gTLD will be consistent with Merck’s Statement of Privacy Principles, available on its website at http:⁄⁄www.merck.com⁄privacy⁄.

In addition, MRH intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and 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.

MRH plans to start using .MERCK domain names primarily as redirects to existing .COM and other domains that MSD and potentially, MSD’s qualified subsidiaries and affiliates, currently operate. MRH also plans to carefully review the response from search engines to .BRAND gTLDs, and the perception of end users.

As the marketplace evolves, MRH will invest in outreach and communication as needed to ensure that its end-users continue to interact with MRH content, services, and products in a simplified, efficient, and productive manner.