gTLD	Full Legal Name	E-mail suffix	Detail
.EVERBANK	EverBank	steptoe.com	View

(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.

gTLD	Full Legal Name	E-mail suffix	Detail
.mint	Intuit Administrative Services, Inc.	markmonitor.com	View

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

Specialty

Currently, there is no top-level domain dedicated to personal and small business finance applications and services, and no top-level domain dedicated to Intuit’s Mint brand. The goal of the TLD, in terms of specialty, is to securely provide a top-level domain dedicated to providing products to Internet users and customers around the globe under Intuit’s trusted Mint brand.

Allowing Applicant to control its own Internet space for its parent’s Mint brand gives it the ability to customize domain and website names for Intuit’s Mint-related offerings and signal to the general population of Internet users that websites within the TLD will indeed be securely controlled by Applicant without having to incorporate traditional unrelated gTLD terms such as .com, .net, or .biz. In addition, the TLD will permit Intuit, Applicant and Applicant’s other Affiliates to send a consistent and focused branding image to web users across the globe, without the registration and operation impediments that can be inherent in ccTLDs. This specialty will benefit Internet users seeking a secure, authenticated online avenue to utilize Applicant’s Mint-related software products or services without the worry that they will become the next phishing or counterfeiting victim. This is particularly and uniquely important in the areas of personal and business financial software and services.

This specialization simultaneously makes it easier for Internet users who are looking for Applicant or parent-related information—and personal finance information—to locate this information more efficiently. The TLD’s appendage indicates to users what they can expect to find at all websites under the TLD—namely, premier and authentic software, personal finance content and online services offered by the Applicant’s parent and Affiliates and the reputable Mint Brand. The Mint brand stands for simplicity, quality, security, and value in a critically important segment of the technology sector.

It also presents another added benefit in that web addresses, namely subdomains and the URLs of other offerings hosted on the TLD can become shorter. One impact of a dearth of “good”, short web addresses has been for them to become lengthier and more complex over time. Using the TLD not only means Applicant’s sites can benefit from having an important keyword in their web addresses, but it will also be easier and faster to type in addresses. Built into a wider process of web optimization and marketing, the TLD’s inclusion as a consistent keyword into domain names will likely have positive implications for specialty, security, and global promotional purposes—not only for Applicant, its parent and Affiliates, but for those who collaborate with them. Applicant anticipates that the TLD will increase traffic to Affiliates’ websites and facilitate consumer use and trust.

Service Levels

Customer satisfaction is paramount to the Mint brand’s success and Applicant, Intuit and Intuit’s other subsidiaries seek to establish long-term relationships with customers and partners based on trust and responsiveness. Indeed, all of Intuit’s companies’ success depends upon meeting the companies’ commitments to outstanding customer relations as well as extremely careful Affiliate selection, as defined below in Section IV.

Accordingly, if made public, the goal of the TLD will be to ensure that the highest level of security, quality, and customer service is provided to Applicant’s and its Affiliates’ customers, for whom security and quality is a high-priority concern—especially in the financial, tax and business services realms. Initially, this entails ensuring that only Applicant and its Affiliates are able to register and control the second-level domain names in the TLD. Regarding the technical and operational aspects of service levels, this entails contracting with and using industry experts to provide the highest possible quality in registry and registrar services so as to operate the TLD smoothly and protect the security and quality of any information that Applicant will receive or provide through the TLD.

Applicant and its Affiliates will further endeavor, as they do with current websites, to provide—for any outwardly-facing domain name and website in the TLD—fast and responsive customer service contact options available in English during normal business hours by email or chat, to help any customer attempting to learn about, purchase or obtain support for Applicant’s Affiliates’ Mint-related software products and services. Similarly, Applicant or its Affiliates will provide a high level of service to trademark and other legal rights owners by providing an easily accessible point-of-contact on all outwardly-facing domain names and websites.

Applicant will ensure that it is providing an exceptional specialized user experience within the TLD. To do this, Applicant will employ testing to discern what user expectations are for a Mint-branded TLD, and related Web experience, and then tailor the TLD to those expectations. For example, when designing its current websites or adding a new look to its homepage, Applicant’s Affiliates ensure that such sites will ultimately serve the Internet user, rather than merely its own internal goals or bottom line. The homepage interface in the TLD will be clear and simple, with pages loading quickly. Affiliate’s software products and services will be provided through secure websites and networks at high speeds. Applicant and its Affiliates will continue to operate under this principle when designing websites and providing access to high-quality financial and productivity software and services through the TLD.

Reputation

As web-based financial and productivity platforms are among the most targeted by cyberattacks and attempted fraud, one TLD goal is to further assist Applicant in providing its parent and other sister subsidiaries with another means to ensure even greater quality, authentication and security—through a uniquely technologically secure and advanced online environment. The TLD will provide an environment in which customers around the world can learn about and access the software products and services provided by Applicant’s parent and sister subsidiaries with certainty—by readily seeing the domain and knowing that they are interacting with the highly-reputable Mint Brand.

Mint already has a reputation for excellence and superior quality in the software industry. Applicant seeks, through the operation of the TLD, to maintain a reputation for providing a secure online environment for all Internet users to access financial-related software and content more efficiently. Mint.com and the Mint mobile offerings also have a reputation for enhanced creative capabilities and innovation in the software industry. A primary goal of the TLD, if made public, will be to continue to promote Mint’s reputation for excellence, creativity and innovation.

The Registry will initially be known for ensuring only Applicant and Applicant’s Affiliates register domain names in the TLD, that those domain names are used for Applicant-related purposes at the direction of Applicant, 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 and its parent Intuit will be the entities standing behind Intuit’s world-renowned software products and services, and that they can expect the highest level of online service and security. In all, Applicant will strive to continue to be known as an exemplary and model domain name services citizen through the use of the TLD.

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

Competition

The TLD will enhance competition in Applicant’s Affiliates’ existing and new markets by allowing Applicant and Intuit the additional space and flexibility to further innovate and create new online goods and services, and to reach new geographic areas with a consistent branding message—the latter being something that is presently hampered by variances in ccTLD registration and operation policies.

The TLD will also enhance Applicant’s and Intuit’s ability to create innovative approaches to marketing Mint-related products and services online through the use of unique, new and shorter second-level domains that delight consumers. Applicant further believes that these innovations and consistencies in how the Applicant and Affiliates will provide and market high-quality software products and services online will also incentivize other technology and online services companies that operate on existing and new top-level domains to improve the security and quality of their own online offerings and storefronts and to accelerate the introduction of new goods and services in order to continue attracting new customers. Thus, the entry of the TLD will benefit consumers by increasing the likelihood of the successful introduction of new and innovative online goods and services from both Applicant’s Affiliates and also from the software and online services industry as a whole.

Differentiation

The TLD will be differentiated from all other top-level domains currently available in the marketplace. Applicant’s Affiliates will be able to affix the Mint brand to a broad set of second-level domains and indicate to Internet users the source of the TLD. Indeed, no other existing top-level domain is similar in appearance to the TLD, none is used exclusively for high-quality financial software and services (including mobile and software-as-a-service offerings), and none exclusively serves Applicant’s current and prospective customers. Finally, unlike in existing top-level domains, initially only Applicant and Applicant’s Affiliates will be allowed to register or operate domain names within the TLD, allowing the TLD to become unique in that customers will not have to fear fraudulent sites, malware, security issues, spam, phishing, counterfeit products or information that is false or inaccurate, emanating from the domain.

Innovation

Applicant’s parent company, Intuit, and its Mint.com business are already recognized leaders in innovation. Indeed, Forbes recently named Intuit number 84 in the “World’s Most Innovative Companies” List for 2011. Technological innovation is a critical element of Intuit’s and Mint’s strategies, and is at the forefront of all Affiliates’ online software and service presences. Moreover, Intuit, and its subsidiaries strive to create an innovation culture among their employees. This is perhaps best evidenced by recognition that Intuit, for the last ten (10) consecutive years, has been recognized as one of “Americaʹs 100 Best U.S. Companies to Work for” by Fortune Magazine. This award incorporates direct feedback from employees about their ability to innovate and focus on customer delight.

Most importantly, Applicant believes that the TLD will open up significant new opportunities and permit Applicant to more easily enable the testing and launch an increasing number of new innovations. With the TLD, Applicant can test new applications and platforms with consumers to facilitate their desired Web and mobile experiences. The Applicant will have the capacity to allow its Affiliates to explore marketing and branding strategies that incorporate the new TLD and discover new ways to rapidly test consumer reaction to marketing, discounts, user interface differences, and other customized offerings that are valuable to them. This innovation will promote competition on the Internet and provide more innovations and higher levels of service to the Affiliates’ users and customers. Moreover, the TLD will be innovative in that—for the first time—it will allow more people to have greater access to a dedicated and secure top-level domain for Mint’s broad set of cutting-edge software products and services. The TLD will also allow Applicant to securely host its own platforms and infrastructure in new ways.

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

Mint.com has been universally praised by users and the press alike for providing a superior user experience, and has won numerous awards related to same. Similar to how it operates its current domain names and websites in third-party top-level domains, Applicant will strive to test, develop, and implement the TLD and its websites to satisfy Mint customers’ and prospects’ expectations in the most secure and user-friendly manner possible. In doing so, Applicant will take great care to ensure that domain names in the TLD will ultimately serve the Internet user, not just its or its Affiliates own internal infrastructure goals or bottom line.

Accordingly, Applicant will rely on its consumer- and security-driven testing to provide the best user experience possible—which will be enabled by the ability to use multiple second-level domains within the TLD to provide different experiences to different consumers and test their preferences—all in order to improve their experience with Applicant’s Affiliates’ offerings. Because users will know that Applicant will own and operate all domain names in the TLD, Applicant anticipates that the TLD will provide an enhanced and more-secure online experience for those interested in obtaining information about and access to Mint-related products and services. The TLD will differentiate Intuit’s Mint business from other providers of financial and business productivity software and online services and create a more stable, competitive, expansive and active marketplace in the industry.

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

In order to support the goals listed above, only Applicant through its parent’s authorized employees will be able to register domain names within the TLD. Thus, the general public will not be allowed to register, buy, or sell domain names in the TLD. Applicant, however, reserves 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 (under the control of Applicant or its parent company) for uses as specified by Applicant. Affiliate will be defined for the purpose of this application as a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, the person or entity specified (i.e., Applicant). 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, 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.

As stated above, Applicant intends to operate a closed registry in order to enable its parent to offer the software-based products and services it currently offers on its existing websites in existing top-level domains, together with new innovations and offerings Applicant and⁄or its Affiliates plan to develop. Accordingly, TLD policies and decisions for domain name registration and use will continue to be provided through an internal team consisting of Applicant’s or its parent’s existing business, marketing and technical decision-makers, utilizing existing well-established internal processes. As a publicly-traded company, Applicant’s parent has extensive controls already in place to ensure legal and operational compliance.

The TLD’s domain name policies will be limited by its abuse prevention and rights protection policies discussed further herein, and Applicant will strive to avoid registering domain names that are confusingly similar to third-parties’ trademarks and related rights. Obscene, explicit, and offensive domain names will be precluded from registration.

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.

Keeping customer information secure and private is of crucial importance to providers of financial-related software and online services—especially Applicant’s parent and other Affiliates. That said, initially, Applicant intends to operate a registry as a closed TLD, with access limited to Applicant’s and Affiliates’ authorized employees. As Applicant’s use may expand, Applicant will take commercially reasonable steps to maintain the security and privacy of the information collected therein, and will remain in compliance with confidentiality and security regulations in relevant jurisdictions.

Applicant’s parent already has well-established Privacy Policies in the U.S. and global jurisdictions to safeguard its customers’ information. Intuit also works closely with third-party privacy standards bodies. See e.g. Intuit, Privacy Highlights, available at http:⁄⁄security.intuit.com⁄privacy⁄ (Feb. 10, 2010); see also Mint.com, Privacy and Security, available at https:⁄⁄www.mint.com⁄how-it-works⁄security⁄ (Feb. 10, 2010).

If the TLD becomes publicly visible such that external users are interacting with content and information about software products and services accessed through the TLD, Applicant or its Affiliates will, at a minimum, provide similar security and privacy policies and measures that clearly outline how Applicant or its Affiliates protect the privacy and confidentiality of visitors and users, and provide users with industry-leading clarity and choice options with respect to how their data is used, according to then-current Applicant and Affiliate policies and the relevant laws in the appropriate jurisdictions.

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

In the event that the TLD is publicly used, outreach and communication will be among Applicant’s and Intuit’s important goals in connection with the TLD. Given Applicant’s and its Affiliates’ intent to use the TLD to expand the Affiliates’ offerings, testing and marketing, Applicant will certainly institute marketing and outreach efforts to inform the public about new SLDs within the TLD in order to draw consumers to such new offerings, tests and marketing materials—including the applications, services, content and information hosted therein.

Applicant’s parent and the Mint business already use several different outreach and communications methods and venues to promote Mint’s mission and messages to the public about the value of using its offerings, including but not limited to: press releases; featured Internet videos; social media, blogs, YouTube, Twitter, and Facebook; various global news feeds; and paid advertising, including in various digital media and search. If the TLD is expanded to enable use and registration of second-level domains by the general Internet public, Applicant or its Affiliates will be able to incorporate the outreach and communication regarding the TLD into Mint’s current branding, public relations and marketing channels and efforts to ensure that as many prospective customers and users as possible understand the new resources available and how to interact with them.