gTLD	Full Legal Name	E-mail suffix	Detail
.CHESAPEAKE	Afterdot LLC	sedari.com	View

i. goal in terms of specialty, service levels, reputation

Definitions:
Registrants
As the proposed TLD is a closed registry model, the ʺregistrantʺ is effectively Chesapeake Energy Corporation, its subsidiaries and employees who are authorized to utilize an address or sub-domain under the TLD ʺ.CHESAPEAKEʺ.

Internet users
In the closed registry model, ʺinternet usersʺ refers to individuals and organisations that are legitimately interested in communication within or between Chesapeake Energy Corporation. This category may include authorised employees and stakeholders.

Others
ʺOthersʺ includes potential users of the Internet, potential clients or stakeholders, industry organisations and industry regulators⁄governments.

Background
Chesapeake Energy is the second-largest producer of natural gas, a Top 15 producer of oil and natural gas liquids and the most active driller of new wells in the United States. Chesapeake Energy has approximately 11,000 employees and has a number of affiliates in associated energy industry, technology and operative fields.

Community Partnerships
Chesapeake Energy has for five years in a row been recognised as one of the 100 Best Companies to Work For [ref: Fortune, 2012], and is a recognised leader in corporate social responsibility. In 2010, Chesapeake contributed more than $25 million to support community development, the arts, the environment, social services, health and medical causes and education.

Leading corporate citizenship is one of the key principles of all Chesapeake activities and a significant consideration in the decision to place its brand at the highest level of the Internet domain name system. The citizenship that Chesapeake displays in its core industry will be equally expressed in its operation and management of the TLD through its wholly owned subsidiary, Afterdot.

Chesapeake enthusiastically shares the policy goals of ICANN in this round of innovation in the development of the Internet. The proposed new TLD enables Chesapeake to promote, develop and deliver an optimal level of service that advances the Internet as a secure and efficient method for delivering information and transacting business.

Specialisation, Service Levels and Reputation

Specialisation
The team operating the TLD through the Registry brings considerable speciality experience in the Internet industry both in relation to high-level policy development, launch, operation and management considerations. Significant marketing resources together with registrar partnerships and technical facilities enable the Registry to specialise in the provision of a top-level domain that provides a valuable alternative model to existing gTLDs.

The Registryʹs domain name registry services will be driven by customer focus and, technological innovation. Specialty delivery of services will be closely mapped to clients and constituents, ensuring a higher level of relevance and efficiency.

The Registryʹs services in terms of DNS management expertise, registry operations and technical database management capabilities will be industry- leading standards. Together with the technical provider and management team, speciality services will be continually examined for optimal utility and functionality consistent with all ICANN requirements.

Service Levels
In order to advance its mission as stated above, the applicant has brought together a team with expertise, experience and technical capacity to ensure that the TLD is operated to the best industry standards in the provision of services.

The Registry will provide a substantial network infrastructure that can guarantee maximum performance and reliability as well, if required in the future, to scale seamlessly to meet variations in demand.

Reputation
The applicant is concerned to ensure that both the reputation of the TLD as well as the reputation of the Internet generally is enhanced by this delegation. Chesapeake Energyʹs reputation will be enhanced while simultaneously enhancing and promoting the Internet as a secure and efficient place for business. The applicant is mindful of the critical importance of confidence in the operation of the Internet. It is core to the application that the applicant is a leading model for Internet welfare in establishing a TLD that can be trusted .

Benefit to Registrant(s)
Chesapeake Energy will benefit from the capacity to shape and control the landscape of its Internet-related structure and presence. Chesapeake will be able to create bespoke solutions for secure, client-focused services that distinguish Chesapeake and set higher standards in the energy industry generally.

The longer-term micro benefit to Chesapeake in enhanced reputation, standing and security for investors is importantly extended to the macro level of the energy industry, corporate communities and the Internet generally.

Benefit to Users
The proposed gTLD will create a direct and straightforward external connection to Chesapeake Energy as well as secure and private internal communication. The proposed TLD will create a closed connection between Chesapeakeʹs clients, market and employees, thus enabling efficiency in communication and security of information. Efficiencies and security are enhanced by the control that flows from a bespoke top-down domain.

The applicantʹs intention is that users will be unified in the ʺvirtual spaceʺ of the Internet as though they were face to face. Chesapeakeʹs extensive range of services and large numbers of employees can cohere in a single web identity and location that utilises the Internet as a tool to gather unity in diversity.

Benefit to Others
The benefit of the proposed TLD extends beyond registrants and Internet users to others who have a policy concern in ensuring that the reputation of the specific industry and the Internet generally is enhanced. Potential users of the Internet in countries yet to develop access will encounter a more clearly defined, brand and product-specific environment on the Internet that facilitates search for services and enables more focused delivery of service by Chesapeake.

Chesapeake believes strongly in responding to community needs and specific conditions of its clients and stakeholders. A closer relationship between Chesapeake and its present and future clients strengthens the delivery of services. Chesapeakeʹs commitment to community and social programmes will find a more effective level of delivery and assessment, helping to build a stronger platform for Chesapeakeʹs existing projects of returning benefits to the community.

At the broadest policy level, Chesapeakeʹs strong corporate citizenship will be a case in point for the responsible running of a Top Level Domain that authenticates ICANNʹs core values.

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

Competition
The applicant believes that by setting higher standards in the industry with a secure and focused Internet presence, the industry as a whole will evolve similarly high standards of service in order to remain competitive. Enhanced competition amongst service providers flows directly to enhanced service to the end consumer.

The applicant aims to set leading corporate standards for communication and service through the Internet. By promoting market-appropriate information Chesapeake is able to facilitate accurately informed consumer choice, high levels of confidence and ultimately market-regulation by the end-user consumer. The applicant believes that this round of TLD applications will at its best allocate more strength and decision-making power in the individual consumer.

Differentiation
The applicantʹs proposal is founded on the belief that competition in the marketplace makes for stronger, more innovative and more creative alternatives for the consumer. Together with its technical and management partners, the applicant has a rich understanding of the needs of the global Internet community and is committed to building a domain name system that grows with and responds to the needs for services, products and information sought by this global community. A steady, secure and responsive service that offers users a competitively priced and distinctive service will enable the TLD to operate as a genuine and enduring alternative to existing TLDs.

Industry, product and service differentiation have become increasingly challenging as the Internet has expanded to over 200 million domain name registrations. In terms of service provision to users, lack of differentiation creates a greater likelihood of frustration, brand confusion or fraud.

Occupation of a TLD by an individual brand substantially addresses the possibility of error or uncertainty in identification of a brand and its associated services. The consumer is able clearly to differentiate Chesapeake from among all others on the Internet, quickly, simply and reliably.

Innovation
The innovation of the TLD is a key building block to its inherent differentiation. Innovation is core to survival in a competitive commercial environment. The applicant believes that in the case of a vital public service such as the Internet, innovation must be founded solidly on the critical requirements of DNS stability, longevity and utility. In other words, the applicant believes in evolution, not revolution.

There have been many years of outstanding effort involved in creating the existing mechanisms and policies for guiding change in the Internet. These mechanisms have been substantially successful in maintaining the stability of the Internet. As such, the applicantʹs policies have been developed with a view to extend and enhance existing procedures in an incremental and cooperative manner. While committed to innovation in the provision of services and technical standards, the applicant aims to measure and interpret the needs of the Internet community

The applicant is working closely with technical service provider, Afilias, to ensure that the proposed TLD innovates in ways that actively support the security and quality of services to clients, internal cohesion within Chesapeake, as well as structure of the Internet generally. While the capacity for innovation will undoubtedly accelerate, the applicant is committed to vigilant analysis of any proposed innovations so that they remain consistent with stated goals of both Chesapeake and ICANN.

iii. What goals does your proposed gTLD have in terms of user experience goals

User experience goals
Consistent with the applicantʹs key goals to work co-operatively and positively in the provision and management of a vital public resource, the applicant aims to ensure that the user experience is centered on the following goals which are consistent with ICANNʹs registry contract:

* rapid, responsive and reliable internal customer service
* robust neutrality
* robust data security and privacy
* robust data escrow
* Internet standards regarding naming and reserved names
* Industry standard acceptable-use policy and registrar agreements
* Leading protocols on technology, rights protection mechanisms and accurate WHOIS.
* Consumer confidence in security, privacy and authenticity thus building confidence in the usage of the Internet for business purposes
* Ease and facility in locating both Chesapeake and the desired location and or service
* A direct line of communication between Chesapeake and its clients
* Responsive and monitored business services, directly targeted to identified client needs

iv. Provide a complete description of the applicantʹs intended registration policies in support of the goals listed in iii (above)

Registration policies to support above goals
The applicant has developed the following explicit policies to support the user-experience goals enunciated in (iii) above.

(a) Customer service
In conjunction with the technical service provider the Registry will have advanced system functions and features to ensure high service reliability and a flexible systems architecture.

Strong cooperative relationships with registrar(s) will ensure that consumer needs are monitored, measured and responded to in a way that reflects the evolving role and purpose of the Internet.

(b) Robust Neutrality
The Registry will be operated on best industry and ICANN practices to ensure that it is a trusted, unbiased provider of core Internet DNS functionality while providing consistent and stable operation of a new TLD.

Among the most important aspect of the neutrality policy is the registryʹs relationship with registrars noted below.

(c) Robust Data Security and Privacy
The Registry, as a neutral and trusted registry, must maintain the trust of the registrars and the consumers. Therefore, the Registry will not market in any way the registrant information obtained from registrars for purposes of running the registry, nor will it share that data with any unrelated third parties. The Registry operator will only have access to such data as is necessary for operation of the registry itself and will use that data only as required by registry operations.

The Registry will provide registrars with a mechanism for accessing and correcting personal data and will take reasonable steps to protect personal data from loss, misuse, unauthorized disclosure, alteration or destruction.

(d) Robust Data Escrow: The Registry will follow all data escrow requirements mandated by ICANN and work with an ICANN accredited Data Escrow provider. By so doing, the Registry will ensure that all data necessary for operation of the registry will be available in the event of a catastrophic failure of the registry or following the selection by ICANN of a new registry using the EBERO system.

(e) Internet Standards Regarding Naming and Reserved Names
The Registry will reserve and block the registration of names as specified in Schedule 5 of the Registry Agreement. The Registry will consistently work with ICANN to ensure that registry practice confirms with ICANN requirements.

The Registry will reserve for itself a small number of names necessary for the secure operational and technical functions of the registry.

(f) Acceptable Use Policy and Registrar Agreements
The policy of the Registry and contracted registrars relating to the computer systems, hardware, servers, bandwidth, telecommunications transport and e-mail routing provided by the Registry and Domain Provider(s) will promote the integrity, security, reliability and privacy of the Registry Network and the Registrar(s).

The Registryʹs policy will follow leading industry standard that both (i) support the free flow of information over the Internet and (ii) inhibit the transmission of materials that offend relevant laws, rights, interests and codes of conduct. The policy will provide a complaints procedure and enforcement mechanisms.

The Registry and Domain Provider(s) and⁄or the Registrar may at its sole discretion remove any content or material or services such as URL forwarding, Email forwarding, DNS hosting, WHOIS protection, proxy service etcetera from its servers, or terminate access to the Registry Network where it has been determined by the Registry and Domain Provider(s) and⁄or the Registrar that a registrant has violated the Acceptable Use Policy.

(g) Leading Protocols on Technology, Anti- Cybersquatting and WHOIS
The Registry will adhere to all existing ICANN policies as well as commit to further evolution of TLD policies that advance ICANNʹs core principles in the operation of the Internet. While this round of applications for new TLDs may revolutionize the Internet, the Registry believes that such revolution be supported by evolutionary development of operational rules. The Registry is committed to a full and cooperative partnership with ICANN in the growth of Internet services on a secure and sustained basis. See further, below.

(h) General registration policies
As a wholly ʺin houseʺ closed registry TLD, .CHESAPEAKE will be available only to authorized users and members of Chesapeake and its subsidiaries. Together with technical provider, Afilias, the business management team and qualified registrars, the Registry will have in place a vigilant system of authentication and permission to ensure that registration is tightly controlled and monitored.

(i) Reservation of sub-domains
Second and subsequent level sub-domains will only be created as part of the communication structure and strategy within Chesapeake. Sub-domains will not be freely available on the market.

The Registry will comply with all the requirements and policies of ICANN as set out in the Schedule 5 to the Registry Contract.

v. Will your proposed gTLD impose any measures for protecting the privacy and confidential information of registrants or users?
Protection of Privacy
The Applicant recognizes the importance of balancing individual privacy rights with the rights of intellectual property owners, law enforcement and other interested third parties to have access to WHOIS data for legitimate uses. Comprehensive privacy and authentication rules are built into the operation of the proposed gTLD consistent with requirements under the Registry Agreement.

As privacy and confidentiality of personal information is a key element in the provision of a positive user experience, the Registry will take all reasonable steps to protect personal data from loss, misuse, unauthorized disclosure, alteration or destruction. The Registry will also comply, in accordance with the Registry Agreement, with all existing and future consensus policies as formally adopted by ICANN.

The Registry will operate a WHOIS service in accordance with Specification 4 of the Registry Agreement and operate this service in full compliance with applicable privacy laws or policies. The Registry will also implement appropriate measures to avoid abuse of WHOIS in order that access is restricted to legitimate authorized users.

vi. Describe whether an in what ways outreach and communications will help achieve your projected benefits
General
The applicant will put in place a system of communication to its existing and potential users to advance the policies underpinning its application for the gTLD.
These plans may include:

(i) Web site
Through its web presence, the applicant will systematically and comprehensively communicate to its customers the:
* Introduction of Chesapeakeʹs new Internet presence
* Timescale of introduction and or changes
* Manner and method of interaction with Chesapeake Energy
* Advantages and benefits to customers
* Provide customer service facilities to ensure client service is monitored and maximized

(ii) Press and media
As and when appropriate, the applicant will communicate through the press and media to ensure wide dissemination of key information about changes affecting its current and potential clients.

(iii) Industry Events
As and when appropriate, the applicant may communicate the existence, operation and advantages of its new TLD through industry events, including, but not limited to:

* Roadshows
* General Meetings
* Internal and external sponsoring events

(iv) Investor Relations
The applicant will ensure that full information is provided to all stakeholders through corporate reporting mechanisms, shareholder information and other corporate communication strategies.

gTLD	Full Legal Name	E-mail suffix	Detail
.vip	Charleston Road Registry Inc.	google.com	View

18.b. Benefits to Registrants, Internet Users, and Others

18.b.i.1 Specialty

The goal of the proposed gTLD is to create a new Internet environment that provides registrants, Internet users, and the public with the opportunity to associate with a meaningful term. Specialization will arise from this environment through market dynamics as entities align their offerings with the term.

The goal of this gTLD is to provide a mechanism by which registrants are able to create a distinct and dedicated space for their VIP users ⁄ customers. Specialization will result from registrants developing content targeted at specific, valued consumers to the benefit of the end user. The content delivered will provide not only a customized space for information specific to the end user, but will also serve as a unifying tool to connect other loyalty program participants.

18.b.i.2 Service Levels

Through its association with Google, Charleston Road Registry is uniquely positioned to enable and support the proposed gTLD by providing its service reliability and speed of delivery as a part of its services. Google brings unique expertise and a proven record of excellence in infrastructure operations: Google now runs the largest DNS system in the world, has industry-leading uptime on its services, such as web search, and offers enterprise services on which governments and businesses depend.

Google is known for its high level of quality and speed, and Charleston Road Registry’s service level goal for the proposed gTLD is to extend that high level of quality, speed, and service to registrars. Indeed, two of Google’s core principles in providing Internet search and related goods and services are “focus on the user and all else will follow” and that “fast is better than slow.”

Charleston Road Registry is committed to using the most technologically advanced, secure, and reliable registry services for all of the domain names in the gTLD so as to not compromise the service levels, security, and stability of the gTLD to users worldwide.

Charleston Road Registry will provide both Engineering and Customer Service support to registrars. All registrars will also have the same level of access to Charleston Road Registry resources to resolve disputes and technical and⁄or administrative customer service issues.

Charleston Road Registry will provide all registrars with 24-hours-a-day, 7-days-a-week Customer Support in the form of telephone, email, and⁄or web chat for technical and non-technical issues relating to the operation of the gTLD system. Charleston Road Registry will provide all registrars with the same level of access to customer support via telephone, email, and Charleston Road Registryʹs website; email and web-based interactions will be the primary method of provisioning customer service support to registrars.

Additionally, Charleston Road Registry will implement strict policies and procedures to minimize abusive domain name registrations and uses and other activities that have a negative impact on Internet users. It will dedicate ample resources for the purpose of responding promptly to abuse complaints from government, judicial and⁄or law enforcement.

18.b.i.3 Reputation

Google has a proven record of providing high-quality, secure online services. Charleston Road Registry seeks to enhance Google’s reputation for excellence, superior quality, and high level of security and become known as an exemplary domain name services provider. When registrants assess opportunities in the marketplace to obtain a name, they will have confidence in Charleston Road Registry’s ability to meet ongoing needs as the registry operator for the proposed gTLD. When Internet users visit a domain name in the proposed gTLD environment, they will be able to reliably expect and experience the high level of security and quality on which Google’s reputation has been built.

The registry will be structured so that Charleston Road Registry allows registrars to register and oversee second-level domain names in the proposed gTLD; that registrars develop and deploy a reasonable process for ensuring that those domain names are used for gTLD-relevant purposes as specified in the registry-registrar agreement; and per Specification 4 that the WHOIS is thick and reliable; and that the registry is responsive to legal rights owners (if applicable) who may have complaints about potentially abusive registrations.

In addition, Charleston Road Registry’s operation of the new gTLD will provide the opportunity for registrars and registrants to build and⁄or bolster their unique brands and brand reputation in association with the proposed gTLD.

18.b.ii.1 Competition

Charleston Road Registry supports the advancement of registry operators as a whole and the diffusion of gTLDs amongst diverse stakeholders to generate increased competition for the benefit of the Internet public. Increased competition will result in more competitive prices for consumers, generate efficiencies and increase productivity in enterprises, and spur innovation in the gTLD space.

The proposed gTLD, .vip, will provide a new online structure for the aggregation of VIP-related content, including loyalty programs. As an alternative to existing second-level domains, Charleston Road Registry anticipates that the .vip gTLD will increase competition among registrars by increasing consumer choice and creating new opportunities for registrar pricing differentiation. Charleston Road Registry also anticipates the .vip gTLD will facilitate registrantsʹ management of loyalty rewards programs, thereby increasing competition among businesses and organizations providing such programs. Charleston Road Registry further anticipates the .vip gTLD may contribute to an increase in online advertising given the specific nature of the domain. Entities will compete to advertise their goods and services that are specific to a particular .vip second-level domain.

Managing this Internet space will allow Charleston Road Registry to provide to registrars and registrants the high level of technical operations quality and service for which Google is known, which in turn will incent other existing and new gTLDs to improve the quality of their offerings.

Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines by fully complying with the Registry Operator Code of Conduct. Charleston Road Registry is committed to treating all registrars equitably and will not offer preferential treatment to Google in its capacity as registrar.

18.b.ii.2 Differentiation

Charleston Road Registry believes in the commercial viability of alternatives to existing gTLDs such as .com and .net. The proposed gTLD will provide the marketplace with opportunities for differentiation not currently available in the gTLD space.

The .vip gTLD will provide a mechanism whereby registrants can differentiate their content by signifying that this space is solely for the consumption of VIP members of a specific business or organization. Although similar content is currently available online, this allows to registrants to clearly distinguish entire sites dedicated to their VIP customers.

Given its association with Google, Charleston Road Registry offers a unique value proposition to registrars resulting from the strength of Google’s trusted brand, technical leadership, and support for free speech on the Internet. Registrars will have the opportunity to leverage this brand in devising their own market positions.

18.b.ii.3 Innovation

The proposed gTLD will foster innovation by creating a new space for the categorization and classification of online content. It will therein provide a mechanism by which registrars and registrants can better brand and manage their online presence by associating it with the .vip namespace. This namespace delivers value to the public through the provision of new and differentiated content, goods, and services to Internet users.

The proposed gTLD, .vip, will promote innovation among registrars by providing for the sale of a second-level domain in a gTLD that will attract a specific segment of registrants. This provides registrars with the opportunity to create and offer tailored new products and services that benefit registrants and⁄or improve user experience in association with the registration of a second-level domain in the .vip gTLD. The proposed gTLD aspires to become an authoritative online resource for VIP-related content. The concentration of content providers in the .vip gTLD will likely invite user comparison among second-level domain sites, encouraging second-level domain registrants to innovate and improve upon their content and⁄or offerings as a point of differentiation.

In addition, the proposed gTLD will promote innovation in the marketplace by providing additional second-level domain options for the public’s use. This will invite new entrants to establish a domain name presence, facilitating innovation in their offerings, and their interactions with Internet users.

Charleston Road Registry considers the proposed gTLD to be a platform for innovation with existing and future Google products and services. Charleston Road Registry, therefore, may incorporate these new offerings into future registry service options (subject to the ICANN approval process), infusing new ideas into the gTLD for the betterment of the public.

Google consistently aims to improve upon technologies that connect people with information, as demonstrated by a proven record of innovation and iteration. Charleston Road Registry strives to offer its constituents this same level of continuous development in advancing its management and operation of the gTLD, engendering benefits to registrars, registrants, and end users.

18.b.iii User Experience

Charleston Road Registry will strive to provide the highest level of user experience through operational stability, security, and performance to serve the interest of registrants in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

The proposed gTLD will provide registrants with the opportunity to differentiate their dedicated domain space such that the end users are able to discern the type of content intended to be found within the proposed gTLD. This will enable increased user visibility of registrants’ offerings, as well as provide registrants with the opportunity to enhance their respective content offerings and innovate in new ways.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the .vip gTLD can flourish. Charleston Road Registry seeks to have users deem the gTLD trustworthy and reliable and recognize it as an aggregated source of targeted goods, services, and information.

The proposed gTLD, furthermore, facilitates an improved online user experience through greater structure and categorization on the Internet.

18.b.iv Registration Policies

Charleston Road Registry believes that given its wide variety of uses, the .vip gTLD will best add value to the gTLD space by remaining totally open and unencumbered by registrant restrictions. There will, therefore, be no restrictions on second-level domain name registrations in the proposed gTLD, .vip.

Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars. Domain names within the proposed gTLD will be available to the general public for registration and use.

Charleston Road Registry is committed to implementing strong and integrated intellectual property rights protection mechanisms. Doing so is critical to Google’s goals of model Internet citizenship and fostering Internet development, especially in emerging regions. Accordingly, Charleston Road Registry intends to offer a suite of rights protection measures, which builds upon ICANNʹs required policies while fulfilling our commitment to encouraging innovation, competition and choice on the Internet.

18.b.v Protection of Privacy and Confidential Information

Charleston Road Registry will strive to ensure the appropriate level of privacy and security will be met for its users. Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection; additional specifics regarding the practices for the registry include but are not limited to the following:

- All data transmitted from registrars to the registry will be encrypted using transport layer security (TLS) or other similar data protection schemes to ensure that third parties cannot access personally identifying information or other sensitive data as it crosses the Internet.

- Charleston Road Registry will attempt to prevent the misuse of WHOIS data for improper purposes such as spam, intellectual property theft, or phishing. Charleston Road Registry will attempt to identify patterns of abusive usage of the WHOIS and will appropriately use CAPTCHA, query throttling or other techniques to prevent information scraping.

- Google will restrict access to data and information systems maintained by the registry to a specific list of individuals involved with supporting the Google Registry system in production. Google will review this list on a periodic basis to ensure that the level of access granted to individuals is appropriate. Google uses two-factor authentication and other mechanisms to ensure that staff with access to user information are properly identified prior to using registry systems.

- Google data backups stored offsite are encrypted with passwords that are securely managed on Google’s internal systems. Google can effectively remove the ability to access this data by destroying the relevant encryption password.

- Supplying Google account information will be optional for registrants unless the domain registration is directly associated with another Google product offering. Google will not disclose Google account information except for any contact information provided by the user that is required by ICANN (per Specification 4) to be displayed in response to a WHOIS query.

- Registrar billing and payment information will not be stored alongside domain name registration information. All registrar billing and payment information will be stored in a payment card industry (PCI)-compliant billing system similar to that used by Google Ads.

- Data will not be shared with third parties without the permission of registrants, except as required for registry operations or as required under the law, such as in response to a subpoena, other such court order, or demonstrated official need by law enforcement.

Beyond these specific mechanisms, both Charleston Road Registry and Google will govern its approach to privacy by the Google Privacy Policy. This policy applies to registrars, registrants and end users of registry services such as DNS zone publication and WHOIS data publication. The Privacy Policy is located at http:⁄⁄www.google.com⁄policies⁄privacy⁄.

18.b.vi. Outreach and Communications Efforts

Once Charleston Road Registry begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity to obtain domain space there through investments in marketing and public relations.

Charleston Road Registry intends to promote gTLDs in its portfolio, such that the public gains an awareness and understanding of new gTLDs and the availability of new second-level domain space on the Internet. Charleston Road Registry believes that this approach will make the strongest impact in modifying consumer behavior and is the best path to achieving success for all new gTLDs collectively.

Charleston Road Registry will reach out to the Internet community via a number of different outreach and communications methods and venues to deliver its mission and message to the public, including but not limited to: press briefings, videos posted on various Internet sites, blogs and other social media, and paid advertising. In addition, when developing resources for localized Internet registrars in different global regions, Charleston Road Registry will use local marketing and communications platforms as needed.