18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Prototypical answer:

(i)Specialty-
Improved security is arguably the most attractive benefit of the registry for Internet users. Presently, there is no top-level domain dedicated to banking and financial services, and no top-level domain dedicated to Applicant’s brand. The goal of the TLD, in terms of specialty, is for Applicant to securely and uniquely provide a top-level domain dedicated to providing banking and financial products and services to customers and Internet users across the country under its highly recognized and trusted brand. Allowing Applicant to control its own Internet space for its highly recognized brand gives it the ability to customize its domain and website names and signal to the general population of Internet users that websites within the TLD will indeed be securely controlled by Applicant. This specialty will benefit Internet users seeking secure online banking and financial services who will be able to bank with greater confidence as we greatly reduce the possibility that our customers will become the next phishing victim or subject to the numerous other malevolent schemes currently perpetrated from and through domains bought on the open market.
Navigation to Applicant and affiliate sites will be more efficient. Users will know that .EVERBANK sites are operated by Applicant and are a reliable source of information about all EverBank Financial Corp companies. Applicant’s exclusive access to keyword domain names will be mutually beneficial for Internet users and affiliates, as users may tie the keyword service to affiliate providers. Searches for the TLD will quickly yield Applicant sites. Shorter domain names, which would be feasible with the new TLD, will also increase navigational efficiency for users. Built into a wider process of web optimization and marketing, the inclusion of the TLD as a keyword in every domain name will likely have positive implications for specialty, security, and national promotion purposes. This will increase traffic to these websites, promote competition, and facilitate use and trust by banking and financial service consumers who prefer shorter domain names and want a trusted source of the specific services they seek.
Service Levels-
The goal of the TLD will be to ensure that the highest level of security, quality, and customer service levels are provided to Applicant and its affiliates’ financial services customers, for whom security is a high priority. Applicant will exercise tight control over domain ownership and limit distribution of the domains to related entities and agents. Applicant is contracting with proven industry experts to provide the highest possible quality in registry and registrar services for maximum security and stability to protect the highly confidential information that Applicant’s customers will provide through use of the sites associated with the TLD.
Applicant will further endeavor, as is currently done on Applicant and affiliate websites, to provide for any outwardly-facing domain name and website in the TLD, Customer service that will be available by email and phone 24 hours per day, 7 days per week to instantly help any customer attempting to learn about or utilize Applicant’s services. Similarly, Applicant will provide the highest level service to trademark, copyright, and other legal rights owners by providing an easily accessible point-of-contact on any outwardly-facing domain names and websites.
In addition, despite the fact that Applicant will operate a tightly controlled, closed registry, in which only it and its corporate affiliates will be permitted to register second level domains, Applicant is keenly aware of its responsibility as a financial institution to enact policies and procedures designed to minimize the possibility of abusive registrations and other activities that have a negative impact on Internet users in the TLD, and which maximize the security and stability of the TLD. Applicant’s strong commitment to this goal is demonstrated, among other things, by its adoption of several of the requirements proposed in the 2011 Proposed Security, Stability and Resiliency Requirements for Financial TLDs (i.e., the BITS Requirements, available at http:⁄⁄www.icann.org⁄en⁄news⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf). These standards were developed by the financial services sector for financial TLDs, and Applicant believes that adhering to these standards will result in a more robust approach to combating abuse. The specifics of this approach are set forth in response to Question 28.
Reputation-
Applicant already has a reputation for excellence, superior quality, and the highest level of security in the banking and finance industry, including online through its current websites and domain names. As noted above, Applicant already has an award-winning online track record. It intends to enhance Web services through use of the new TLD. As financial websites are among those with the highest exposure in connection with fraudulent online activity, Applicant seeks through the operation of the TLD to provide the most secure online environment in the industry, to enable Internet users to feel secure in providing highly sensitive personal information to Applicant and its affiliates. The goal of the TLD is to further enhance Applicant’s reputation for excellence and high levels of security and to advance and enhance technical capabilities.
Applicant will strive to ensure that the TLD is known for being tightly controlled, by ensuring only Applicant’s employees, agents, subsidiaries, affiliates, or related companies register domain names in the TLD, that those domain names are used for Applicant-related purposes, that the WHOIS is thick and reliable, and that the Registry is responsive to legal rights owners. Indeed, when Internet users visit a website within the TLD, they should know that Applicant will be the entity providing its nationally-renowned services, and that they can expect the highest level of online service and security. In all, Applicant will strive to be known as an exemplary and model domain name services citizen through the controlled use of the TLD.
(ii)Competition-
The TLD will enhance competition in the current Internet space. Through Applicant’s control of its own Internet space, and the flexibility to innovate and create new ways of accessing its ever-evolving online products and services, Applicant’s customers will experience a new level of service. These innovations will motivate competitors’ with existing and new top-level domains to improve the security and quality of the banking and financial products and services they provide online and to accelerate the introduction of new products and services in order to continue attracting new customers. Thus, the TLD will benefit consumers by increasing the likelihood of new and innovative online products and services in a more secure environment.
Differentiation-
The most obvious differentiation will be the TLD itself: it will be solely composed of Applicant’s unique service mark. Internet users will immediately know the source of the sites featuring the TLD. Indeed, no other top-level domain is similar in appearance to the TLD, none is used exclusively for banking and financial goods and services, and none exclusively serve Applicant’s users and customers. In terms of differentiated uses, Applicant will have the flexibility to customize the second-level domains within the TLD so as to signify the service offered as well as the source of the service. Finally, unlike in existing top-level domains, only Applicant’s employees and affiliated companies and agents will be allowed to register and⁄or operate domain names within the TLD, thus enabling the TLD to become unique in that customers do not have to fear corruption, weak security, malicious code, malware, spam, phishing or false or inaccurate information, and thereby allowing Applicant to become a more trusted provider of online banking and financial products or services.
Innovation-
Applicant is already a recognized leader in online banking and financial innovation. Of paramount importance to financial services customers is security. Ownership of the TLD will allow Applicant to impose higher security standards, to provide information, products and services to customers in a more secure and technologically advanced way and allow Applicant to implement technological advances with greater flexibility.
Indeed, Applicant believes that the TLD will open up new opportunities not yet imagined, and permit Applicant to innovate new services in a truly secure environment.
(iii) Applicant will strive to test, develop, and implement the TLD and associated websites to anticipate its customers’ Web needs and expectations in the most secure manner. Applicant will take great care to ensure that domain names in the TLD will primarily serve the Internet user by being intuitive and practical. Applicant will rely on its consumer and security-driven testing to provide a targeted user experience for those seeking robust, reliable, and secure online banking and financial products and services across the country and eventually perhaps even around the world. Because users will know that all domain names in the TLD will be owned and operated by Applicant, Applicant anticipates that the TLD will eventually provide an enhanced and secure online technological experience for those interested in obtaining more information about conducting online banking and financial transactions and purchasing Applicant’s products and services. Finally, the TLD will serve to differentiate Applicant from other banking and financial institutions and serve to create a more stable, competitive, and active marketplace.
(iv)To support the goals for the TLD, only Applicant, its affiliates, and its authorized and designated employees or agents, will be allowed to register domain names within the TLD. Accordingly, the general public will never be allowed to register, buy, or sell domain names in the TLD. Applicant, does however, reserve the right to sell, distribute, or transfer control or use of any registrations in the TLD to any third party that is an Affiliate of Applicant or is an agent of Applicant or of its Affiliates, for uses as specified by Applicant or its Affiliates. For the purposes of this application “Affiliate” is defined as (i) a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, Applicant, and (ii) “control” (including the terms “controlled by” and “under common control with”) means the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of a person or entity regarding the use of a domain name within the TLD, whether through the ownership of securities, as trustee or executor, by serving as an employee or a member of a board of directors or equivalent governing body, by contract, by credit arrangement or otherwise.
Further, as stated above, Applicant intends to operate a closed registry in order to continue to offer the high-quality secure online financial products and services it currently offers on its branded websites in existing top-level domains. Accordingly, policies and decisions regarding the registration and use of domain names within the TLD will continue to be provided through an internal team consisting of Applicant’s existing business and marketing decision-making channels.
The TLD’s domain name policies will be shaped by its abuse prevention and rights protection policies, and Applicant will strive to avoid registering domain names that are confusingly similar to third-party trademarks and related rights. Obscene, explicit, and offensive domain names will not be permitted to register in the TLD.
(v)Keeping information secure and private is of crucial importance to banking and financial institutions, whose websites are particularly vulnerable to attempts at online fraud. Initially, Applicant intends to operate a closed registry with limited domain ownership access, to ensure the security and privacy of the information available. As Applicant’s use may expand, Applicant will take all available steps to maintain the security and privacy of the information collected, and will remain in compliance with all applicable confidentiality and security regulations in relevant jurisdictions.
For example, Applicant and its Affiliates already haves Privacy Policies in place to safeguard the financial information of their respective customers. For online banking, for example, these include:
-Encryption software that ʺscramblesʺ messages in its secure web-based email system to allow account holders to communicate over a secured channel with EverBank Representatives.
-Customer authentication procedures to protect personal and account information against fraud and other Internet risks.
-Restricted access to nonpublic personal information to only those persons with a business need to know the information to process or service a customer’s account(s).
-Multiple channels of contact to allow users to discuss privacy issues or report anything unusual or inappropriate to Everbank.
For Applicant and its Affiliates’ policies in their entirety, see Privacy Policies for EverBank and its Subsidiaries, found at https:⁄⁄www.abouteverbank.com⁄privacy.aspx. When the TLD becomes public-facing such that external users are interacting with domains registered in the TLD, Applicant will, at a minimum, continue to provide similar security measures.
(vi)Applicant will create and implement marketing and outreach efforts in a variety of media to inform the public about the TLD and the information and services available there.
Applicant already uses a variety of outreach and communications methods and venues to communicate its mission and message to the public, including but not limited to, electronic mail, press releases, featured videos posted on its website, social media, including but not limited to Twitter, LinkedIn, and Facebook, various news feeds around the country, and paid advertising, which includes television and radio commercials, magazine and newspaper print, billboards and posters in major markets, and a variety of digital media. Applicant is able to incorporate the outreach and communication regarding the TLD into its current branding and marketing efforts to ensure that as many customers and users as possible understand the new resources available and how to interact with them to improve their consumer experience.

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