gTLD	Full Legal Name	E-mail suffix	Detail
.MERCK	Merck Registry Holdings, Inc.	fairwindspartners.com	View

18.3.1 What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?

MRH has proposed operating rules to limit registration to MRH and potentially qualified subsidiaries and affiliates and will provide a trusted online environment for end-users.

Therefore, one way in which social costs will be eliminated is that there will be no defensive need for other trademark and brand owners to register second-level domains in the .MERCK gTLD. In addition, the .MERCK gTLD will provide end-users with a trusted source for MRH information, goods, and services.

18.3.2 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

MRH believes that the proposed operation of the .MERCK gTLD as set forth in this application has no known negative consequences or cost implications to end users. On the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to end users.

18.3.3 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?

MRH does not envision multiple applicants for the same domain name, as domain names will only be allocated to its parent company, MSD, and potentially MSD’s qualified subsidiaries and affiliates.

18.3.4 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

MRH does not envision any advantageous pricing, introductory discounts, or bulk registration discounts at this time because these marketing⁄commercial initiatives are inconsistent with the mission and purpose of the .MERCK gTLD as a trusted online source identifier for MSD, and potentially its qualified subsidiaries and affiliates.

Moreover, it is the current intention of MSD to have MRH provide domain name registrations initially at no cost, at least for the first five years of operation.

However, the company reserves the right to reevaluate this decision and may choose to impose a fee in the future. Any potential registrant fees imposed upon licensees or strategic parties will be commensurate with commercial agreements and made if this class of registrants is permitted to register domain names in the .MERCK gTLD.

18.3.5 Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

MRH is committed to providing the domain name registration periods set forth in the Registry Agreement. Moreover, it is the current intention of MSD to have MRH provide domain name registrations initially at no cost, at least for the first five years of operation. Therefore, providing contractual commitments in a domain name Registrant Agreement regarding the magnitude of price escalations does not seem relevant or appropriate. MRH acknowledges that the current template Registry Agreement requires that the Registry Operator “shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar.”

MRH acknowledges that the current template Registry Agreement requires that the Registry Operator “shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar.” However, MSD, as the sole registrant within the .MERCK gTLD, intends to only register domain names on an annual basis through a single registrar.

This is done to better account for costs on an annual basis as well as to provide for more concise financial statements in Question 46, (e.g., no multi-year registration or deferred revenue).

gTLD	Full Legal Name	E-mail suffix	Detail
.XFINITY	Comcast IP Holdings I, LLC	fairwindspartners.com	View

18.3 What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?

Comcast IPʹs proposed operating rules to limit registration to Comcast and its qualified subsidiaries and affiliates will provide a trusted online environment for consumers of Comcast’s content, goods, and services. Therefore, Comcast IP will minimize social costs by eliminating the need for third-party brand owners to defensively register their trademark in the .XFINITY gTLD, unlike other open registries. In addition, the .XFINITY gTLD will provide consumers with a trusted source for Comcast’s content, goods, and services without the risk of fraud, misdirection, infringement, phishing, malware, or malicious content.

18.3.1 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

Comcast IP believes that the proposed operation of the .XFINITY gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to consumer benefits.

18.3.2 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first serve basis?

Comcast IP does not envision multiple applicants for the same domain name, as domain names will initially only be registered to Comcast and its qualified subsidiaries and affiliates.

18.3.3 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

Comcast IP does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because it will not be marketing or creating commercial initiatives for the sale of .XFINITY domain names. Its intention is to use the gTLD as a recognizable, trusted, virtual platform offering Comcastʹs and its qualified subsidiariesʹ and affiliates’ content, goods, and services to customers and Internet users. Any potential registrant fees imposed upon licensees and strategic partners will be made in the future if this class of registrants are permitted to register domain names in the .XFINITY gTLD.

18.3.4 Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

Comcast IP is committed to providing the domain name registration periods set forth in the Registry Agreement. As a .BRAND gTLD, the use of any .XFINITY domain names is conditioned upon a subsidiary or affiliate relationship with Comcast. Therefore, there is a natural incentive for Comcast IP to provide domain names with minimal price escalations and the maximum flexibility in domain registration terms possible under ICANN rules. Understanding the ownership of .XFINITY domains as noted previously, contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations is not relevant or appropriate. That said, the .XFINITY domain agreements will be in accordance with all ICANN requirements.

Comcast IP acknowledges that the current template Registry Agreement requires that the Registry Operator “shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar.” However, Comcast and its qualified subsidiaries and affiliates, as the sole registrants within the .XFINITY gTLD, will initially only be registering domain names on an annual basis.

It is possible that at some future date, Comcast IP may wish to explore expanding the potential universe of registrants beyond the initially proposed closed network of itself and qualified subsidiaries and affiliates. If Comcast IP were to expand this potential universe of registrants it would ensure that these domain name registrants were provided adequate notice regarding any pricing terms and conditions of use, including the fact that the use of the domain name may be conditioned upon another legal obligation that the registrant has with Comcast IP.