gTLD	Full Legal Name	E-mail suffix	Detail
.site	Interlink Co., Ltd.	urbanbrain.com	View

The current gTLD domain space is dominated by a handful of gTLDs, and Interlink anticipates that several great alternatives to the current domain space will be approved through the New gTLD Program. Internet users will be given the opportunity to easily register a domain name that better suits their needs. Through educational marketing more and more users will become aware of these alternatives. Interlink believes that .SITE is a viable alternative to other generic word gTLDs currently in existence today as well as those that will be applied for in this round of New gTLD applications.

Interlink has been an active member of the ICANN community for over 6 years and has gained a deep appreciation for the transparency of the multi-stakeholder model. With the delegation of .SiTE, Interlink commits to fully comply with ICANNʹs requirement to cooperate with economic studies regarding the launch of New gTLDs. We believe that providing such data is key to enhancing the DNS and ensuring the success of future TLD implementations.

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

A TLD registry must establish consumer confidence and build trust among users. To do so, the registry must have adequate understanding of technical requirements, policy implications on business, and the needs of the registrar communities as well as the end users. Interlink believes that .SiTE’s reputation will be largely driven by the registrants (communities, individuals, businesses, organizations, and government bodies). Legitimate registrations with legitimate content will play a vital role in the sustainability of the TLD. Interlink plans to implement policies that will allow it to effectively manage a safe, secure namespace for registrants and Internet users.

Interlink has teamed up with Neustar, a world-class registry services provider and Iron Mountain, the industryʹs most trusted Registry Data Escrow provider to ensure that service levels meet or exceed SLA requirements. By teaming up with the best in the business, Interlink can focus on recruiting and working with the industryʹs top registrars to offer first rate services to end users.


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

Currently there are 22 gTLDs in use on the Internet today. However, most novice Internet users are only accustomed to seeing, .com, .net, and .org. .biz and .info on the right-most side of domain names. gTLDs that have been introduced since ICANN’s inception have been able to build up a steady number of registration volumes. Some have drastically reduced pricing to do so, and therefore have an abundance of non-useful names, parking web pages, spam sites, and phishing sites. According to a report compiled by McAfee, Mapping the Mal Web in 2010, Internet criminals choose to register domain names in a TLD based on the prices, regulations, and the ease of registration. This makes generic top-level domains and non-regulated, inexpensive ccTLDs prime targets for cyber criminals. (The full report can be located at the following URL: http:⁄⁄www.mcafee.com⁄cf⁄about⁄news⁄2010⁄q4⁄20101026-02.aspx)

Interlink envisions .SiTE not as a competitor to the TLDs mentioned above, but as a new platform that will allow users so build on online presence that meets their needs. An increase in the number of gTLDs increases the number of alternatives available to consumers and Interlink believes that this is key for increasing competition, reducing prices and growing the overall domain name industry.

Interlink plans to focus a substantial amount of effort in communicating the availability of .SITE in developing countries. These countries have experienced tremendous economic growth in the past decade as well as rapid growth in communications and Internet infrastructure. This has increased the Internet penetration rate substantially. For example, according to InternetWorldStats.com, the population of Indian Internet users grew from 5 million in the year 2000 to 121 million in 2011. Likewise, Internet users in China increased from 22.5 million in year 2000 to 513.1 million in year 2011. A majority these new users were not able to participate in the launch of any true generic TLDs. SiTE expects to be able serve these users needs by creating and launching the .SiTE space.

.SiTE is a perfect fit among todays top TLDs and is a viable alternative to current generic TLDs. .SiTE has meaning to the entire online population, and Interlink believes that it will be a natural selection for new domain holders as they venture out to secure an online identity. Additionally, SiTE will be a popular choice among many consumers looking to secure names that more closely match what they stand for.


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

Interlink believes that creating a high quality namespace is about attracting legitimate registrations, and reducing speculative registrations. Successfully achieving both will allow for a better user experience because when consumers navigate to a page under a .SiTE domain name they can have the assurance that the content will be useful.

In order to encourage implementation of the new gTLD, competition among registrars, and broad sales channels for the TLD, there will be no restrictions on which ICANN accredited registrars may connect to the SRS for the provision of .SiTE domain names. All ICANN accredited registrars will have the ability to test their connectivity with the systems and sign an agreement with the Registry after passing operational and testing phases.

Interlink will use a proven system with industry-standard connect-ability, we can ensure that all current ICANN accredited registrars have immediate access to the SRS to upon execution of the Registry-Registrar agreement and testing. In many cases, the SRS has already been connected to and integrated into the systems of many of the industryʹs top ICANN Accredited Registrars, which will allow for rapid implementation and immediate sales channels.

Interlink has carefully considered various factors that will likely play a role in creating a successfully TLD and a great user experience for users of .SiTE. Among the factors analyzed were;

　• defining its market
　• marketing techniques used in today’s TLDs;
　• analysis of how various price points impact the number, quality, and type of registrations and associated content.

Interlink has worked closely with its backend provider, Neustar to come up with a viable plan to launch a successful registry that user benefits. These factors were taken into account and have been implemented in Interlink’s business approach as described in Questions 45-50.

As described above in relation to point II, a registry’s choice of policies and price points at which to sell domain names has an impact on the safety for other Internet users. Generic, TLDs and non-regulated, inexpensive ccTLDs are targets for cybercriminals. Interlink will implement a Acceptable Use Policy (AUP), which is further described in response to Question 28. The strict enforcement of this policy will allow for a cleaner namespace compared with existing gTLDs.

Interlink will use a proven system with industry-standard connect-ability, and can ensure that all current ICANN accredited registrars have immediate access to the registry system upon execution of the Registry-Registrar agreement and passing all requisite operational testing. The utilization of a proven registry system, which already maintains over 300 registrar connections globally will positively affect the integration pace of .SiTE among registrars who wish to sell the TLD, thereby rapidly growing sales channels.


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

Maintaining a safe, stable and reliable environment for registrars and registrants is central to Interlinkʹs mission for the .SiTE top-level domain. Interlink proposes that .SiTE shall be an open, unrestricted top-level domain for all consumers. The objective of the registry is to achieve seamless implementation by participating ICANN accredited registrars in order to easily allow legitimate registrations by all consumers.

Interlink has developed the following policies to facilitate in reaching our goals:

　1. SiTE Domain Name Eligibility Requirements
　2. Acceptable Use Policy
　3. Reserved Names
　4. Founders Program
　5. Sunrise Launch Policies
　6. Landrush Launch Policies
　7. ICANN Consensus Policies and Proposed Rights Protection Mechanisms


1. SiTE Domain Name Eligibility Requirements

SiTE Domain Name Eligibility Requirements defines who or what entities can register a domain name, the types of names that maybe registered, as well as the technical criteria for allowable labels within the .SiTE top-level domain. A brief description of each criterion is briefly outlined below:

1a Registrant Restrictions

No restrictions on who or what entities can register a domain name. All registrants will be required to apply for registration, renewal and transfer of domain names through ICANN accredited registrars which have signed an agreement with the registry operator, Interlink Co., Ltd. Furthermore, Interlink will make an list of registrars available on its website.

1b Domain Name Restrictions

A domain names that will be accepted as valid for registration is a domain name that;

　• has not been blocked or reserved by the registry (see Reserved Names policy below)
　• meets the technical requirements (defined below)
　• has not already been registered (registrants will be encouraged to use the WHOIS database
　　provided by the registry to ensure the availability of a domain)

Internationalized Domain Names (IDN) registrations will be permitted in the .SiTE TLD. Interlink believes that IDNs provide a means of creating a more global namespace. Interlink’s philosophy regarding the implementation of IDNs is to take a very cautious approach to ensure that conflicts with naming do not occur. Additional information regarding Interlink’s IDN implementation can be found in response to Question 44.


Technical Requirements

　• Labels containing letters ʺaʺ to ʺzʺ or ʺAʺ to ʺZʺ in standard US ASCII character set, the digits ʺ0ʺ to ʺ9ʺ
　　and the hyphen (ʺ-ʺ); (the registry plans to initially reserve all one and two letter domain names as briefly
　　described below under ʺ2. Reserved Namesʺ below. The release of one and two character strings will be
　　implemented at the registryʹs discretion.)
　• Labels may contain a maximum of 63 characters. (This does not include the ʺ.SiTEʺ suffix)
　• Labels may not begin or end with a hyphen (ʺ-ʺ) and may not include a hyphen (ʺ-ʺ) in the third and fourth positions
　　unless they represent valid internationalized domain names in their ASCII encoding).

2. Acceptable Use Policy

The Acceptable Use Policy (AUP) is one of central policies of the SiTE registry and will be implemented to ensure that the registry maintains the rights to protect the integrity of its registry and achieve its goal of maintaining a safe and stable operation. The policy further describes the process for applying for and registering, renewing, and transferring a .SiTE domain name as well as any restrictions, and how Interlink, the registry can enforce its policies. Additional details can be found in response to Question 28.

3. Reserved Names

This Reserved Names Policy satisfies ICANN contractual requirements and protects the interests of governmental organizations. Certain names on the Reserved Names List will also be utilized for the general promotion of the registry.

Interlink will reserve all names according to Specification 5 of the New gTLD Registry agreement as described below. Additionally, Interlink will, at it’s own discretion, reserve other names it sees fit.

The term ʺexampleʺ will be reserved at the second level. No other levels will be available for registration.

b. Two-Character Labels:

All two-character labels will be initially reserved, however may be released in the event that the registry reaches an agreement with the relevant government or country code manager or so long as the implementation of the two-character labels does not cause confusion with existing country codes.

c. Tagged Domain Names:

These are names with hyphens in the third and fourth position that do not represent valid IDN (Internationalized Domain Names) in ASCII encoding.

d. Second-Level Reservations for Registry Operations:

The following names will be reserved or registry operations: NIC, WWW, IRIS, and WHOIS.

e. Country and Territory Names:

All country and territory names indicated in Specification 5 of the New gTLD Agreement will be initially reserved. A process for the release of these names as well as names listed above in ʺb. Two Character Labelsʺ is further described in Question 22.

4. Founders Program

The SiTE registry may elect to introduce an early domain adoption program, or founders program. The SiTE founders program is an initiative recruit Internet users who are enthusiastic about .SiTE to come forward with their idea and plan to launch a name or names that will help relay the message about .SiTE to worldwide audiences.

It is anticipated that communications regarding this program will be launched as soon as the Registry Agreement with ICANN is signed. The registry will publish a proposal format and evaluate applications against predetermined criteria. Approved applicants will be required to agree to some basic terms and conditions and have their name launched before the official pubic launch of the registry.

Specific timelines and criteria are currently under development and depend on the progress of this application for the .SiTE TLD.

5. Sunrise Launch Policies

The sunrise period is a pre-launch mechanism that will allow Trademark holders to the first right to register their trademarks as .SiTE domain names. The overall purpose of the .SiTE sunrise launch is to ensure that trademark holders have the ability to secure domain names in a straightforward manner as well as ensure that their brand names are not victimized by cybersquatting. The sunrise period will run for at least a minimum of 30 days and a maximum of 60 days in total. Eligible participants in the sunrise phase will be constrained to those entities that a valid mark registered in the Trademark Clearinghouse.

In processing Sunrise applications, Interlink will collect all the applications submitted through ICANN accredited registrars throughout the duration of the sunrise period. All applications will be considered as having been received at the same time. The registry will verify that each application matches the data in the Trademark Clearinghouse. Duplicate applications having met the criteria specified by the registry will auctioned off at a later date. Interlink will fully publish details and policy related information regarding the auction on its website well in advance of the launch.

To ensure the protection of trademark holders, Interlink will implement the trademark claims services for the life of the registry. As of the submission date of this application, the Trademark Clearinghouse is still in the early stages of development and the actual protocol for connecting to the clearinghouse is not yet known. Further details regarding the sunrise launch can be found in answer to question 29.

6. Landrush Launch Policies

The registry will offer a landrush period in which any interested party will be permitted to submit one or more applications to purchase high value domains at reasonable costs. Only domain names that have not been reserved, restricted, or registered will be available during this launch period. Applications in the landrush period will be accepted throughout the period and will be considered as accepted at the same time. At the end of the landrush period domain names for applications that do not have any competing applications will be approved and the domain name will be allocated to the registrant.

Applications for domain names having one or more competing applications will be auctioned at prescribed date and time.

7. ICANN Consensus Policies and Proposed Rights Protection Mechanisms

Interlink is aware of, and understands, all current ICANN consensus policies listed at http:⁄⁄www.icann.org⁄en⁄general⁄consensus-policies.htm. As the registry operator for .SiTE, Interlink will ensure continuing compliance with all existing and future consensus policies.

Interlink believes that SiTE will grow to be an important public resource and has committed to ensuring that all rights holders have adequate protections for their intellectual property assets. The SiTE registry will implement the fall mandated rights protection mechanisms as described in Part C below.


v. 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.

Interlink takes the privacy of its users very seriously and will not market information obtained from registrars pertaining to registrants in any way. All data obtained with regards to a registration of a domain name will only be used for the purposes of running the .SiTE Registry. No personal data will be shared with unrelated third parties and such data will only be accessed in cases where the registry needs it to be necessary for the operation of .SiTE.

All registrant data as required by the WHOIS policy and ICANN standards will be publicly available where the registrant does not use privacy registration services at their registrar of choice. Registrars will be responsible for ensuring the safety and security of the payment information used in conjunction with a domain name registration. A detailed discussion of the WHOIS database can be found in response to Question 26.

Interlink will notify each ICANN-accredited registrar of their requirement to adhere to specific consensus policies. Additionally Interlink is aware of the current work being done to analyze the current WHOIS model as well as the movement to improve it. Along with ourselves, our partners are involved deeply in the ICANN community and we commit to implementing any and all new procedures as approved by ICANN.


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

Interlink believes that an effective and wide-spread marketing plan coupled with an effective distribution network will play a vital role in building consumer confidence in .SiTE. The registry plans to launch the TLD on a global scale with an emphasis on the growth of Internet, the ability to register a memorable name under a new domain space.

Interlink will use a unified strategy for creating a strong brand, consumer awareness, sales, and use of the TLD by influential companies and people. The actual timing of the marketing and communications campaign may prove challenging due to several anticipated issues with timelines in the New gTLD evaluation process, however, Interlink has set aside sufficient marketing funds and will use appropriate judgment on when to implement and subsequently ramp up marketing communication and outreach programs.

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

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

18.b.i.1. Specialty

Charleston Road Registry intends to apply for an exemption to ICANN’s Registry Operator Code of Conduct and operate the proposed gTLD with Google as the sole registrar and registrant. The proposed gTLD will specifically align with Google Calendar, an existing Google product, and will provide users with improved capabilities that meet their diverse needs.

The specialization goal of the proposed gTLD is to provide a dedicated second-level domain space for a user’s or enterprise’s management of their Google Calendar. This specialization introduces a new domain name hierarchy that will generate new Google Calendar namespace, and provide for streamlined, internal Google management of the introduction and phase out of new or retiring products and⁄or services in the second-level domain.

This specialization offers Internet users Google services that will enhance their current and future experience with Google Calendar. Google will manage a process whereby users will be able to make use of unique vanity names in the gTLD; such second-level domains will only point to the Google offering. This provides users with a distinctive namespace as they develop and implement a unique, customized vision for their use of Google Calendar. Google strives to offer its customers leading edge tools that will not only enable them to better personalize their respective second-level domain content, but also spur further creativity and generate new options on the Internet.

As the Internet is ever changing, these services will evolve to meet users’ needs to the benefit of the Internet public. Google seeks to continuously provide tools that solve problems faced by Internet users, and, in partnership with Charleston Road Registry, the proposed gTLD will open the opportunity for Google to provide these customer-centric solutions.

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.

Charleston Road Registry’s service level goal for the proposed gTLD is to ensure that Google, as the proposed sole registrant, is supported in delivering the high level of quality, speed, and service to users for which it is known. 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 “fast is better than slow.”

In focusing on the user, Google strives to provide the best user experience possible. Google will continue to operate under this principle when designing new offerings and providing goods and services within the proposed gTLD.

Google keeps speed in mind with each new product it releases, from faster mobile applications to improved Web browsers designed for rapid search and navigation. Google continues to devote its resources to improving speed and efficiency. In managing the proposed gTLD, Google expects to keep its service reliability and speed to this standard through direct management of all technical infrastructure related to DNS resolution other than the operation of the root servers.

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

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, high level of security, and become known as an exemplary domain name services provider.

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 Google registers and manages domain names in the .cal gTLD, that those domain names are used for only Google Calendar-related purposes, and that the registry is responsive to legal rights owners (if applicable).

As noted, Charleston Road Registry intends to apply for an exemption to ICANN’s Registry Operator Code of Conduct and operate the proposed gTLD with Google as the sole registrar and registrant. This facilitates Google’s ability to further enhance the Google Calendar brand and the reputation of Google Calendar offerings.

In addition, Charleston Road Registry’s operation of the new gTLD will provide the opportunity for users to build and⁄or bolster their unique brands or tailor unique user identities 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, increase productivity in enterprises, and spur innovation in the gTLD space.

Google will have the opportunity to differentiate and innovate upon its Google Calendar products and services through its use of the gTLD.

The proposed gTLD, .cal, will provide a new mechanism for users to make use of a unique, vanity second-level domain name that points to the userʹs Calendar account. Charleston Road Registry anticipates the .cal gTLD will help grow the volume of calendar offerings on the Internet, thereby increasing competition among web-based calendar service providers.

The proposed gTLD will promote competition in the gTLD space by inciting competitors to respond with improved gTLD operations, greater range and higher quality products and services integrated with domain name offerings, and⁄or the creation of their own respective gTLDs, to the benefit of all Internet users. Launching the proposed gTLD will also generate increased competition in the online marketplace by adding incremental availability to the second-level domain pool.

As noted above, Charleston Road Registry intends to apply for an exemption to the ICANN Registry Operator Code of Conduct. Given that the proposed gTLD is exclusively intended for use in connection with Googleʹs service, Charleston Road Registry believes that there is a reasonable case for such an exemption. Should ICANN not approve this proposed exemption, Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines.

18.b.ii.2. Differentiation

The proposed gTLD will clearly be differentiated from other gTLDs due to its purposefully limited scope. This differentiation includes: (1) uniqueness in terms of the users the proposed gTLD seeks to benefit; (2) a clear indicator that second-level domains within the gTLD offer a particular, targeted content; (3) and because the TLD will be associated with a Google offering, Internet users will immediately be able to rely on the quality of the product.

The gTLD will provide an authoritative environment for the provision of Google Calendar offerings. New, higher quality products offered in the gTLD will also attract new users to the Google offering.

The .cal gTLD will provide Google with the opportunity to differentiate its Calendar offerings from other calendar and meeting scheduling service providers by virtue of its branded gTLD. This gTLD is not currently available in the gTLD space, and its provision will eliminate the need for Google to use more generic gTLDs, such as .com, to deliver its Calendar offerings.

The proposed gTLD will also encourage differentiation among users. Google’s services, including tools to improve and customize users’ unique Google Calendar experiences, will provide users with new ways of distinguishing themselves from others.

18.b.ii.3. Innovation

The proposed gTLD will promote further innovation by creating a new space for the categorization and classification of online content. The proposed gTLD is in itself innovative, as it seamlessly combines DNS services with other Google products and services.

The proposed gTLD will spur further innovation at Google by providing an accelerated platform for the introduction of new Calendar offerings to the public. The proposed gTLD will provide a mechanism for enhanced branding and management of Google’s Calendar offerings.

The proposed gTLD, .cal, will promote innovation by encouraging Google to create new offerings for distribution in the .cal gTLD. In addition, the proposed gTLD will encourage other online services to create new offerings and⁄or provide an umbrella gTLD in which to link their respective offerings, providing Internet users the same benefits as .cal will provide. In addition, Google may choose to innovate within its portfolio of web spaces and introduce distinguishing features that further crystallize the relationship between offerings provided in the gTLD and the Google brand and reputation. This will likely invite user comparison among domain sites, encouraging competitors to innovate and develop new features and services.

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 users this same level of continuous development in advancing its management and operation of the gTLD, engendering an improved user experience.

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 users in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; per its SEC filings, Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

Google keeps user experience in mind with each new service it releases, from allowing users to personalize their Gmail accounts to providing small to medium businesses with tools customized for their specific needs. The proposed gTLD provides Google with a formal mechanism whereby it can continue to improve its services to address the ever-changing needs of all Internet users.

The proposed gTLD, furthermore, facilitates an improved online user experience by provisioning the DNS on users’ behalf and streamlining the process by which users are able to link to and make use of the Google offering.

The proposed gTLD, .cal, will provide users with an improved Google Calendar experience by allowing for users’ direct management of their respective content within the .cal gTLD

In focusing on the user, Google strives to provide the best user experience possible. Google will continue to operate under this principle when designing and providing new service offerings in the proposed gTLD. The proposed gTLD will provide users with improved customization services and facilitate additional opportunities to enhance their current and future experience with Google Calendar.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the .cal 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.

Lastly, the proposed gTLD improves the Internet user experience by creating greater structure and categorization on the Internet.

18.b.iv. Registration Policies

Because the sole purpose of the proposed gTLD is to associate domain names with the Google Calendar offering, Charleston Road Registry intends to apply for an exemption to the ICANN Registry Operator Code of Conduct and operate the gTLD with Google as the sole registrar and registrant. As the sole registrant, Google will have the opportunity to differentiate and innovate upon its Google Calendar products and services through its use of the gTLD.

Given the proposed limited scope and use of the gTLD, Charleston Road Registry believes that there is a reasonable case for such an exemption. Should ICANN not condone this proposed exemption, Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars.

Charleston Road Registry believes that given its specific use, the .cal gTLD will best add value to the gTLD space by limiting all second-level domains to the sole use of pointing at Google Calendar offerings. Google will manage a process whereby users will be able to make use of unique vanity names in the gTLD; such second-level domains will only point to the user’s Google Calendar account. In addition, only entities and individuals with a Google Calendar account or who create a new account may be eligible to enact a second-level domain within the gTLD.

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 its 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. Although Google will be the only registrant (and is intended to serve as the only registrar for the gTLD as well), Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection for their users; additional specifics regarding the practices for the registry include but are not limited to the following:

- Since Google will be the only registrant, personally identifying information regarding individual users will not be sent to or stored by the registry. Such data will remain on Google’s infrastructure used to provide the individual service, and is subject to Google’s existing privacy policy.

- 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 service 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.

- In the event that other registrars are involved, 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 PCI-compliant billing system similar to that used by Google Ads.

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 Google begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity for users to obtain domain space there through marketing and public relation investments.

Charleston Road Registry, in conjunction with Google, intends to promote gTLDs under its purview collectively, 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 and Google believe 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 and Google 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, Google will use local marketing and communications platforms as needed.