.insurance Pre-Register Domain - .insurance Domain Information

fTLD Registry Services, LLC (FRS) is submitting this application on behalf of the U.S. insurance community to ensure that the .insurance gTLD will serve as a trusted, hierarchical, and intuitive namespace for this community and the consumers it serves. All registrants within this gTLD will be vetted prior to registration to ensure their identity and their commitment to industry best standards developed by FRS before they are able to register in the .insurance gTLD. In addition, the registry will employ a network of active and passive safeguards in the operation of the registry to make certain these registrants continue to abide by the terms and conditions set forth in the registration agreement. The .insurance gTLD will also provide the industry with an innovative space to explore cutting edge business opportunities and mechanisms to better serve consumers using the Internet. Over time, one of the goals of this gTLD is to become the consumer's choice for information about the insurance industry.

As awareness and use of the .insurance gTLD increases over time, Internet users will come to learn, understand and trust that websites ending in .insurance are operated by legitimate members of the insurance community. FRS' implementation of stringent registration restrictions, enhanced security standards created by the financial services industry, content/use requirements and rigid enforcement will contribute to the security, stability, and resiliency of the .insurance gTLD, ultimately resulting in increased consumer trust and confidence in the gTLD.

The Internet represents a critical component of the trade and commerce engine and the .insurance gTLD is expected to address some of the online security challenges faced by the insurance industry. Regrettably, the industry's reputation has been marred by criminal and fraudulent activities that undermine consumer trust and enforcement agency confidence. Internet users, many of whom are consumers, are increasingly challenged by opportunists and charlatans who pretend to be legitimate online businesses. This is a particular concern of the insurance industry because their consumers are asked to entrust sensitive financial information to external third parties. Rogue online operators engage in cybersquatting and ʺphishingʺ attacks that often involve false websites designed to mimic legitimate businesses, including insurance companies and/or agents.

Due to the strict vetting process that will occur before an .insurance domain is awarded, the number of phishing attacks will be greatly reduced in the .insurance gTLD. FRS will work with the insurance industry to create a strategy that significantly reduces the risk of insurance-related phishing and other malicious activities that are perpetrated on the Internet.

Registrations within the community may initially be made by the following businesses, individuals or organizations:
- Licensed insurance companies regulated by a government entity
- Licensed insurance agents and brokers regulated by a government entity
- Associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board)
-Organizations that are majority controlled by insurance companies (if approved by the FRS Board)
- Entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board)
- Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board)

Why FRS?
In 2008, the American Bankers Association (ABA) and The Financial Services Roundtable's (Roundtable) executives and members allocated resources to work in conjunction with member committees to examine the potential impact the Internet Corporation for Assigned Names and Numbers' (ICANN) new gTLD program could have on the financial services industry and to make recommendations regarding next steps. Marked concern arose regarding the expansion program, especially in light of the resources and expenditures currently dedicated to stem existing online abuses.
During the last four years, the ABA and the Roundtable united to play an active role in ICANN's development of its new gTLD program. Both organizations engaged with ICANN to voice community concerns about the program, and were successful in raising awareness about the need to protect brands and intellectual property. In addition, the ABA and Roundtable were successful with their request to ICANN for a modification to the Security Policy question in the Applicant Guidebook and it now includes that gTLDs with unique trust implications, such as those that are financial services-oriented, are expected to deploy appropriate levels of security.  However, absent assurances that .insurance, .bank and other financial gTLDs would be protected, the Executive Committee and Board of each respective organization voted and authorized staff to take all actions necessary to secure financial gTLDs, specifically, .insurance and .bank.

At the behest and approval of both the ABA and the Roundtable members and Boards, FRS was formed in 2011 for the explicit purpose of applying for and operating financial services-related gTLDs. In addition, FRS seeks to protect the brand space, improve the protection available for a more secure Internet ecosystem, collaborate on delivering more innovative and secure products and services, and zealously advocate for the interests of the insurance community with ICANN.

The Operating Managers of FRS:
Founded in 1875, the American Bankers Association represents banks of all sizes and charters and is the voice for the U.S. banking industry's $13 trillion and 2 million employees. ABA marshals the talent, energy and perspectives of its members to bring about positive change for the banking industry. In conjunction with the financial services community, the ABA has developed and continues to own a number of innovative systems that support the financial services industry. The ABA Routing Number (RTN) system was developed in 1910 and serves to identify the specific financial institution responsible for the payment of a negotiable instrument. In 1964, the ABA organized the Committee on Uniform Security Identification Procedures (CUSIP), for the purpose of developing an identifier for financial instruments. ABA is also an active member of the International Banking Federation, formed in March 2004 to represent the combined views of a group of national banking associations. Collectively, the countries represented by the Federation reach more than 18,000 banks with 275,000 branches.

The American Bankers Insurance Association (ABIA), a subsidiary of the ABA, is the leading bank-insurance industry trade association in the U.S. ABIA members include banking institutions of all asset sizes, including insurance companies, service providers, consultants, and associations.

The first of the Roundtableʹs predecessor organizations, the Association of Reserve City Bankers, was formed in 1912. The Bank Holding Company Act of 1956 led to the 1958 formation of another independent organization, the Association of Registered Bank Holding Companies. The two organizations merged in July 1993, and became The Bankers Roundtable in October 1993. In early 2000, the first members from the securities, investment, and insurance sectors joined their banking brethren as founding members of The Financial Services Roundtable. Today, the Roundtable represents 100 of the largest integrated financial services companies providing insurance, banking, and investment products and services to the American consumer.

FRS has actively engaged several insurance-related trade associations to inform them of FRS' activities and what it could mean for their members. As of April 10, 2012, FRS' endorsers of the .insurance initiative include The Allstate Corporation, American Bankers Insurance Association, Nationwide, Prudential Financial Inc., and State Farm Insurance Companies.

The .insurance gTLD will serve as a trusted destination on the Internet for insurers, insurance services providers, consumers and Internet users. The .insurance gTLD will seek to reach insurance professionals, their employees and partners while modeling a template of trust for online commercial interactions. The pre-registration and screening conducted by FRS will serve the industry by allowing it to congregate under one umbrella gTLD. This presents consumers with clear choices in an environment that will encourage .insurance registrants to be innovative and provide maximum value to consumers in their online experience, while providing significant competition to existing gTLDs.

Additionally, the proposed .insurance gTLD will offer the following benefits:
- Provide a trusted online marketplace for consumers seeking to access insurance products and services;
- Provide FRS and its community members with memorable Internet addresses and improve navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;
- Protect the namespace for the benefit of institutions, consumers and the overall insurance community;
- Provide a variety of high value-added services through its backend registry services provider; and
- Create an opportunity to design innovative online products and services for the insurance industry and its consumers.

18(b)(i) What is the goal of your proposed gTLD in terms of areas of specialty, service levels, of reputation?

FRS was founded by organizations that hold a leadership role in the U.S. insurance industry. FRS' Board and Advisory Board will be composed of insurers and insurance associations and therefore it is uniquely situated to understand the needs and goals of registrants in the insurance industry. FRS' goal is that there will be no confusion for Internet users when they encounter a .insurance website. Every .insurance registrant will be a legitimate member of the insurance community, committed to a trustworthy commercial transaction experience for its clients and consumers. Registrants will work with FRS and adhere to the strictest terms of service and security standards, generated specifically by the global financial services community for this undertaking.

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

FRS' primary driving factor is to provide a vetted and therefore, more secure online environment for businesses and consumers to interact with the insurance community. The success of the gTLD will not be measured by the number of registrants, but rather by the level of institutional and consumer recognition and trust placed in the .insurance gTLD. Using this benchmark, FRS will strive to build recognition and trust that rises to a level meeting or exceeding that found in the .edu and .gov gTLDs.

As noted above, FRS is committed to serving the insurance community as it increasingly relies upon emerging technologies to securely deliver information between institutions and about insurance products and services to its consumers. The .insurance gTLD has the potential to serve as the cornerstone of this type of online strategy for the industry. FRS seeks to become a trusted source for inter-institution exchanges and transactions and a platform for more secure, consumer-facing insurance activities, including the purchase of insurance products and services.

In addition to the education and outreach initiative discussed above, FRS is keen to continue its work with ICANN and the broader Internet community in promoting security controls within gTLDs that require enhanced security measures, such as financial gTLDs. Its most recent effort in this area was the creation of security requirements formally proposed to the ICANN Board in December 2011 by the joint ABA and BITS (the technology policy division of the Roundtable) Security Standards Working Group. Following its submission to ICANN, the requirements have since been referenced in question 30 of the Applicant Guidebook. FRS will contractually incorporate these requirements into both its Registry-Registrar Agreement (RRA) and the end Registrant Registration Agreement to ensure that it has the legal means to enforce these obligations.

The creation of the .insurance gTLD will provide the insurance community with opportunities to explore and create new products and services that support the community in addressing the Internet based issues and concerns referenced above. It will also provide the insurance community with a space to innovate, improve current insurance services, and address the increasing consumer demand for faster and more convenient transactions.

FRS plans for its operation of the .insurance gTLD to provide significant benefits to the larger Internet community in the following ways:

1. Trust
The .insurance gTLD will allow the Internet user, before he or she even clicks on a search engine result, to know that the site belongs to a trusted member of the insurance community.

Among the results that would arise in a typical search of existing gTLDs are fraudulent businesses that intend to put Internet users, especially consumers and their personally identifiable information, including, but not limited to, financial data, at serious risk. Often, these rogue online operators register domains that look similar to legitimate domains to intentionally mislead users, resulting in increased costs to the industry and consumers. FRS' ultimate goal on behalf of the industry is that the .insurance gTLD will reduce the efficacy of such attacks, as users on a bona fide .insurance site would know that their information was safe with a vetted insurance provider.

2. Ease of search
As the amount of information available online continues to grow, it will become increasingly more difficult for consumers to choose which websites to visit for their desired insurance services and products. However, consumers will know that Internet search results listing websites ending in .insurance belong to legitimate members of the insurance community. Will a typical Internet search produce legitimate insurance providers via the Internet? Yes. But, will the individual performing the search have the tools at hand to determine which of the results are trustworthy and legitimate? Not necessarily, but with .insurance they will.

3. Vetting and Oversight
The reason Internet users will be able to trust a .insurance domain is because FRS will aggressively govern both the issuance and continued use of a second-level .insurance domain. More information on the vetting and oversight can be found in 18(b)(iv) below.

18(b)(iii) What goals does your proposed gTLD have in terms of user experience?

FRS will ensure that the .insurance gTLD will create an enhanced user experience both for registrants and Internet users. FRS' goal is to operate the .insurance gTLD in a manner that instills trust and confidence in the domain names and websites associated with the gTLD. For users this means a small, specialized, highly controlled environment, free from much of the abusive behaviors found in existing gTLDs.

1. Registrants
The number of .insurance registrants will be relatively small. As such, registrants will receive higher levels of customer service than can reasonably be expected in existing gTLDs. Once granted a .insurance domain, registrants will benefit through the domain nameʹs positive brand identity and consumer trust. Likewise, .insurance's reputation will benefit from the upstanding efforts of second-level domain operators seeking to maintain their registration status.

2. Internet users
As stated above in 18(b)(ii), the restricted and manageable size of the .insurance community will provide both a trusted and secure online experience. The controls managing the community will foster competition among registrants to compete on a user-experience basis for Internet users.

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

To ensure a trusted environment, FRS will restrict registrations to a select group and will limit the types of activities that may take place within the gTLD with a series of policies meant to prevent and address negative behavior. These policies include:

Registrations within the community may initially be made by the following for-profit and not-for-profit businesses, individuals or organizations:
- Licensed insurance companies regulated by a government entity
- Licensed insurance agents and brokers regulated by a government entity
- Associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board)
- Organizations that are controlled by insurance companies (if approved by the FRS Board)
- Entities whose operations are dedicated to serving insurance companies (if approved by the FRS Board)
- Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board)

In working on behalf of the insurance industry, FRS understands its responsibilities to the industry. Because of the proposed insurance-service activities that will occur within the .insurance namespace, it is essential that registrations only be permitted by verified members of the insurance community. In addition to validating the eligibility of the registrant, the domain name to be registered must comply with appropriate name selection and use requirements.

To ensure strict compliance with these policies, FRS will develop and implement a Registrant Eligibility Evaluation Process. This process will require .insurance accredited registrars to collect registrant information that will be used by FRS, or its designated third party service provider, to validate that the registrant is a member of the insurance community. These requirements will be incorporated into FRS' Registry-Registrar Agreement (RRA).

As part of the registration process, potential registrants must provide its registrar with the following information:
- Full legal name
- Business address
- Professional title of representative of the administrative contact of the potential applicant
- Business name
- Point of contact within the business who can verify their representation of the business
- Phone
- Email
- Another proof of identity, necessary to establish that the registrant is an eligible member of the appropriate .insurance gTLD community
- For insurance companies, the state regulatory authority issuing its charter
- For agents and brokers, the state licensing agency
- For organizations that are majority controlled by insurance companies (if approved by the FRS Board), list of and proof of its owner(s)
- For entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board), corporate operating agreement or like document(s) as determined necessary to validate alignment with the goals of the community
- For specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board), a copy of the corporate operating agreement if for-profit or the mission statement if non-profit (or like document(s) as determined necessary to validate alignment with the goals of the community)

Applicants who meet the eligibility requirements and have been validated as legitimate members of the community will then be able to register their domains in .insurance.

Domain names that pass the vetting process will enter a 5-day Add Grace Period (AGP), or Pending Create, before becoming valid. Applicants whose domain name fails the vetting process will be notified with reasons for denial and procedures for appeal. Any applicant who is rejected for either a non-eligibility criteria or use of domain evaluation can appeal the validator's decision to FRS.

FRS will audit approved registrants and their strings to ensure compliance with all applicable eligibility and use requirements.

Domains initially registered in the .insurance gTLD must correspond to a trademark, trade name or other service mark owned by the registrant. Initially, all other registrations (e.g., geographic, generic, etc.) will not be allowed. FRS will reserve a set of generic domain names prior to launch. These reserved domain names will either be used by FRS in its capacity as Registry Operator for the management, operation and purpose of the gTLD, or they will be equitably allocated to members of the community. The subset of domain names reserved for FRS' use is necessary to create a trusted, hierarchical, and intuitive framework for the .insurance namespace to facilitate the ease by which consumers can navigate the gTLD.

Although these reserved words will be commonly used words and phrases and/or geographic terms, FRS will provide an enhanced Rights Protection Mechanism that will provide trademark owners with an avenue to challenge the reservation and potential use of these domain names. This challenge process will be modeled after the highly successful dotAsia Pioneering Program.

18(b)(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.

The .insurance gTLD will be governed by strict guidelines and policies regarding issues of privacy and the protection of confidential registrant information. The policies will be transparent and rigorous. Each level of the gTLD (registry, registrar and registry services provider) will have privacy and security policies in place to protect against unauthorized access to confidential information.

Privacy and security will be key elements of the .insurance Acceptable Use Policy (AUP), which will govern how a registrant may use its registered name. Draft AUP language specifically addresses privacy by noting that a registrant may not use a .insurance domain for any activity that ʺviolates the privacy or publicity rights of another member of the .insurance gTLD community or any other person or entity, or breaches any duty of confidentiality that you owe to another member of the .insurance gTLD community or any other person or entity.ʺ

Members of the .insurance gTLD community operate under the highest standards of privacy and protection of personally identifiable information and financial data. Such protection is an essential component of the insurance industry and a legal necessity for any Internet enterprise. State insurance regulators and the National Association of Insurance Commissioners support strong laws and regulations that protect the privacy of individual consumer information. Every state has adopted comprehensive privacy laws to protect the extensive personal information collected by insurers to underwrite and administer insurance policies. Insurance regulators also support efforts to mandate fair treatment and notification to consumers when their private information is improperly disclosed to third parties, especially where such unauthorized disclosures may result in identity theft. It is in the best interest of an insurance provider or affiliate to continue to provide maximum privacy protections for consumers, and this will continue to be their responsibility in operating a .insurance gTLD. FRS will implement the latest online technology (e.g., DNSSEC and multi-factor authentication) and services to help ensure the .insurance domain is synonymous with trust. These steps will align with actions instituted by .insurance registrants, working in lockstep with FRS. This is a manifestation of the larger goal of .insurance, that of a trusted source of safe online transactions, as stipulated in 18(a).

The protection of privacy and confidential data is of paramount importance, especially in an industry as highly regulated as insurance services. Not only will the registry have its own set of measures, but each individual institution or registrant will be required to remain compliant with existing laws and regulations in place regarding privacy and the protection of customer data. FRS will accomplish this, in part, through the inclusion of contractual language in its RRA that is modeled after similar language in Registry Agreements of existing ICANN gTLD registry operators. Specifically, some of this language will include the following:
- Registry Operator shall notify the Registrar of the purposes for which Personal Data submitted to Registry Operation by Registrar is collected, the intended recipients (or categories of recipients) of such Personal Data, and the mechanism for access to and correction of such Personal Data.
- Registry Operator shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration or destruction.
- Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.
- Registry Operator may, from time to time, use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use.

The draft AUP informs registrants that FRS maintains ʺcomplete enforcement rights over registrant's use of their .insurance domain name. If registrant violates this AUP, registrant will be subject to a rapid domain name compliance action, be in material breach of the Agreement, and along with all other rights and remedies under this Agreement with respect to such a breach, FRS reserves the right to revoke, suspend, terminate, cancel or otherwise modify registrant's rights to the domain name.ʺ

On a regular basis, FRS will audit domain names, or require an attestation by second-level domain holders, registered in the .insurance gTLD space to ensure compliance with all eligibility and use criteria. If a violation is discovered, an investigation will begin immediately to rectify the violation. If an applicant chooses to appeal, FRS will review the appeal to determine if there is any material change to the action or activity. FRS will retain the right to assign the dispute to an ombudsman if necessary.

A more detailed discussion of FRS' privacy policies, specifically steps to avoid unauthorized access to sensitive information, can be found in responses to question 30.

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

Outreach and communications with the insurance services community will be critical to the success of this project and has already begun over the past four years by FRS' founding members. FRS' founding members have discussed possible impacts to the industry with domestic insurance associations as well as ICANN's Governmental Advisory Committee (GAC). Current conversations with and among insurance companies and members of the industry include ways to reach the insurance community and build an infrastructure that includes all members of the insurance services community. Ultimately, a communications strategy and plan will be implemented by FRS and its Board to guide its efforts. Advisory groups and committees will also be consulted to ensure continued alignment.

FRS and its Board will utilize all existing channels of communication to increase the awareness of the value and merit of the .insurance gTLD. Finally, the gTLD will be promoted by registrants themselves. Insurance providers will have an incentive to direct consumers to the .insurance sites they operate, and thus will promote their second-level domains containing .insurance throughout existing media channels.

The adoption of rules and elimination of social costs for the insurance community are at the core of FRS' strategy. Its proposed operating rules will provide the insurance community, businesses and consumers with a trusted online environment, and in turn minimize operating and social costs. Registrations for domains in the .insurance gTLD will be reserved exclusively for those members of the industry who meet the previously described eligibility criteria. This, coupled with a stringent name selection policy, will eliminate the need for an insurance provider company trademark and for brand owners to defensively register second-level domains in the .insurance gTLD. The goal is that this verified ecosystem will be poised to offer consumers with a place to find trusted sources of insurance information, products and services with a substantially lower risk of fraud and/or scams. In addition, FRS' processes are designed to protect the trademark rights of insurance companies and their affiliates. These strategies will serve to minimize financial costs both within the insurance industry and the Internet community as a whole.

18(c)(i) How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come/first-serve basis?

As detailed in FRS' response to question 29, FRS suggests running two different Sunrise periods followed by a Real Time Registration Period (i.e., first come, first served approach during general availability) for the entire insurance community. Due to the limited and restrictive nature of the .insurance namespace, FRS does not envision many significant issues regarding multiple insurance community members vying for the same domain name.

However, when there are multiple registrations for a domain name during either the Founder's Sunrise (the first sunrise for members of FRS' Founder's Program, which will operate on a first come, first served basis) or General Sunrise for the broader community, a three-step process will determine which registrant receives the domain. First, within the guidelines set forth by ICANN for protecting trademark/registered name rights, first preference will be given to the applicant with proven rights to the name. Second, if all contending registrants have an equal right, all will be asked to submit a proposed use plan and application fee to demonstrate how the domain name will be used. Emphasis will be placed on developing and deploying the domain. FRS may employ an independent arbiter to review and make the initial recommendation to FRS' Board of Directors regarding awarding the domain. Third, in the event that there is not a clear cut winner after these two steps are undertaken, the parties will proceed to a mechanism of last resort: auction.

After the Sunrise periods, FRS plans to move to a Real Time Registration Period where members of the .insurance gTLD community can register strings that comply with registration policies on a first come, first served basis.

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

FRS has proposed a Founder's Sunrise Program that would allow members of the insurance community that have financially supported this initiative, to register their domain names in the .insurance gTLD before the General Sunrise Period. Potential registrants participating in the Founder's Program are eligible for discounted registrations. The registration and use of these domain names would be contingent upon the registration restrictions and eligibility requirements. At this time, FRS does not anticipate any other price discount programs, but reserves the right to revisit this question in conjunction with its Board of Directors and Advisory Board.

Except for the FRS Founder's discount noted in this section, FRS does not envision any pricing, introductory discounts, or bulk registration discounts because these marketing/commercial initiatives are inconsistent with the mission and purpose of the .insurance gTLD as a trusted online source identifier.

18(c)(iii) 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.

FRS is committed to providing domain name registration services in accordance with the periods set forth in the Registry Agreement and providing domain name registrants with pricing predictability. FRS further 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." If price increases are necessary, FRS intends to follow all necessary guidelines in terms of announcing them to registrars.

In connection with any premium domain names program, FRS will set pricing for premium domain names, as well as renewal terms, before offering these domains for registration. However, in connection with this premium class of domain names, there may be additional requirements necessary for registration. All additional terms necessary to legally bind registrants in connection with a registration of this type would be provided to registrants in advance.

The U.S. insurance community is a clearly delineated industry that has evolved over hundreds of years into a critical commercial enterprise within the global economy. While fTLD Registry Services, LLC's (FRS) members are based and regulated in the United States, the growth, reach and impact of the larger insurance services community is global. Due to the common characteristics that define the insurance community, it is a logical candidate for identification as a community under the Internet Corporation for Assigned Names and Numbers' (ICANN) guidelines. Further, since FRS was requested by members of this well-defined community to apply for and operate the .insurance gTLD for the community's benefit, FRS' .insurance gTLD is well positioned to serve the community and apply a straightforward approach to approve its potential registrants. The community is defined under the subheads below. • How the community is delineated from Internet users generally. Such descriptions may include, but are not limited to, the following: membership, registration, or licensing processes, operation in a particular industry, use of a language. The insurance community is composed of a specialized group of individuals and commercial entities including, but not limited to corporations dedicated to providing insurance services. Nearly all Internet users purchase products or participate in programs through this community of providers. The regulatory framework for the U.S. insurance industry has evolved over the past two centuries with a trend toward consistent regulations among states with increased federal oversight. Each insurance company is subject to all applicable state regulations within the states it chooses to operate and must remain in compliance with them in order to maintain the authority to offer insurance products in that state. The U.S. Supreme Court's ruling in 1944 in U.S. v. South-Eastern Underwriters Association made the insurance industry subject to the Commerce Clause of the U.S. Constitution. Since then, Federal regulation of the community has grown. This framework is critical to understanding the insurance community. The existing framework provides clear lines for defining the community. Further, FRS' knowledge of and relationships within the insurance services industry, as outlined below, will support it in providing a successful mechanism to approve solely those entities that belong within this community. The .insurance gTLD will be built to accommodate any shifts in the insurance community due to changes in regulations or laws. Only, those entities that maintain .insurance gTLD registration restrictions will be eligible to join. Those that leave the insurance community and no longer meet .insurance gTLD membership standards will be subject to domain name forfeiture if they are unable to remain in good standing. • How the community is structured and organized. For a community consisting of an alliance of groups, details about the constituent parts are required. There are many complexities in the insurance industry. Among them are the structure and organization of the industry, which depends largely upon the size of the company and the types of insurance the company has the state authority to offer. Major U.S. insurance companies often reside within a holding company structure typically owned by multiple admitted and surplus insurers, and at times also own excess insurers and reinsurers. Insurance holding companies also differ as to how various business functions are divided among subsidiaries or outsourced to third parties. In addition to the size of insurance companies, the community consists of two major components - the insurance companies themselves and the agents and brokers (also known in the industry as "producers") who interface with consumers to sell insurance products and services. Some of these agents and brokers are independent and sell the insurance products of multiple insurance companies and some are affiliates of a single insurance company and sell only the products of that agency. Agents and brokers must be state licensed in order to sell product and, therefore, represent a readily identifiable and distinguishable group. Type of insurance policy is another way the community is organized. There are many variations of insurance on the market. As a rule, they can be categorized under the following types: For individuals, the market includes Vehicle Insurance (e.g., automobile, motorcycle, recreational vehicle, and boat insurance), Property Insurance (e.g., homeowners, renters, personal umbrella liability, and flood insurance), Life Insurance (e.g., term life, whole life, and universal life insurance), and Specialty Insurance (e.g., Accident Medical, General Liability, Travel Services, Farm Insurance, Identity Theft Coverage). For businesses, the market includes General Business Coverage (e.g., business owners policy, general liability, crime insurance, commercial auto, business property, surety and other bonds, business interruption), Employee Benefits (e.g., Group benefit offerings, employee retention, participant accident medical, retirement plans, business travel insurance) and Agribusiness (e.g., farm and ranch insurance, commercial agribusiness coverage, insurance risk management). • When the community was established, including the date(s) of formal organization, if any, as well as a description of community activities to date. The history of the insurance industry in the United States goes back nearly three hundred (300) years to 1732 when an insurance company that underwrote fire insurance was founded in Charleston, South Carolina. The evolution of the industry and its regulatory framework is articulated above. Originally, the insurance community was dominated by small, local, single-line mutual companies and member societies. However, a significant change in the community occurred in the 1950s, when laws began to permit multi-line charters. Increasingly, the community began to feature multi-line, multi-state and even multi-national insurance conglomerates and holding companies. • The current estimated size of the community, both as to membership and geographic extent. The .insurance gTLD will be operated by FRS on behalf of the U.S. insurance industry. This includes 3,750 companies (according to a 2010 report by the National Association of Insurance Commissioners) and 2,250,000 agents and brokers (according to a 2010 report by the National Insurance Producer Registry). It also includes over 233 state insurance associations and 52 other types of insurance-related associations. The 2010 statistics were the most currently available information with FRS prepared its application.

FRS was recently created by two established financial services associations - the American Bankers Association (ABA) and The Financial Services Roundtable (Roundtable). Between them, they have over 200 years of history representing the financial services industry in the United States. FRS was formed for the explicit purpose of applying for and operating financial services-related gTLDs including .insurance. As of April 10, 2012, endorsers of the FRS .insurance initiative include the American Bankers Insurance Association, The Allstate Corporation, Nationwide, Prudential Financial, Inc., and State Farm Insurance Companies. The first of the Roundtableʹs predecessor organizations, the Association of Reserve City Bankers, was formed in 1912. The Bank Holding Company Act of 1956 led to the 1958 formation of another independent organization, the Association of Registered Bank Holding Companies. The two organizations merged in July 1993, and became The Bankers Roundtable in October 1993. In early 2000, the first members from the securities, investment, and insurance sectors joined their banking brethren as founding members of The Financial Services Roundtable. Today, the Roundtable represents 100 of the largest integrated financial services companies providing insurance, banking, and investment products and services to the American consumer. Founded in 1875, the ABA represents banks of all sizes and charters and is the voice for the nationʹs $13 trillion banking industry and its 2 million employees. ABA marshals the talent, energy and perspectives of its members to bring about positive change for the financial services community. Through an effective collaboration between ABA members and staff, it combines experience and insights, in-depth expertise, unmatched resources and extensive products to make its members more successful. Examples include the ABA's ownership and/or support of several existing financial services standards and businesses, including CUSIP and routing number. Further, ABA currently serves as registrar of several ISO standards, including, ISO 7812. The American Bankers Insurance Association (ABIA), a subsidiary of the ABA, is the leading bank-insurance industry trade association in the U.S. ABIA members include banking institutions of all asset sizes, including insurance companies, service providers, consultants, and associations. The membership makeup is approximately 55% banking institutions and 45% all other providers. A study by Michael White Associates for ABIA found that in 2009, U.S. bank holding companies generated total insurance revenue of a record $15.08 billion, led by insurance operations at Citigroup, Inc., Bank of America Corporation and Wells Fargo & Company. Activities of the ABA, ABIA, Roundtable, and their members include, but are not limited to: - Supporting policies and activities that allow financial institutions to sustain the integrity and versatility of the payments system to meet customer needs and preferences efficiently and safely; - Supporting efforts to combat the continuous problem of identity theft and the means to identify and address emerging threats to consumers; - Supporting efforts to protect the nonpublic, personal information privacy of financial services customers; - Facilitating legitimate electronic communications between financial institutions and their customers and other businesses; and - Educating employees of the financial services community on the latest industry regulations and sound practices. • Relations to the community and its constituent parts/groups. The ABA's and Roundtable's members include representatives in the U.S. insurance community. These organizations represent the community's interests in Washington and around the globe. As such, these organizations maintain relationships, both formal and informal, with all sectors of the insurance community, through conferences, published research, best-practices projects, and representation on policy matters. The hybrid nature of ABA and the Roundtable--insurance organizations partnered with other financial institutions--perfectly reflects the U.S. insurance industry, as explained above in 20(a). The .insurance gTLD will serve the needs of, and provide benefits to, the insurance industry that does business in the U.S. Members of the community are clearly defined by law and include, licensed insurance companies regulated by a government entity, licensed insurance agents and brokers regulated by a government entity, associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board), organizations that are majority controlled by insurance companies (if approved by the FRS Board), entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board), and specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board). What all of the above have in common is that they operate within, for the benefit of and/or support entities that are regulated and those regulations set the parameters of what is included in, or excluded from, the insurance community. This is not a gTLD designed for widespread registrations. Instead, registrants and registrations will be restricted by guidelines included in 20(e) below. Containing recognized members of a regulated community under one gTLD will provide Internet users with a safe and convenient way to seek insurance information and services from vendors and entities that have already been vetted. As such, the .insurance gTLD will be initially reserved for the exclusive use of members of the U.S. insurance community clearly defined above. • Accountability mechanisms of the applicant to the community. The insurance community and the .insurance gTLD will exist in a synergistic relationship. FRS will employ multiple mechanisms to assure its ongoing accountability to the community including: - Oversight by FRS' Board of Directors that consists of representatives from insurance institutions and an Advisory Board as set forth below. Individual insurance institution directors will represent the interests of the community as direct community participants. - The Advisory Board will contain a group of additional members whose sole purpose is to represent the insurance and financial services community. Insurance associations may be selected to represent the broad cross-section of the community as well as the collective interest of their members. Additional insurance companies or support members will be chosen from organizations and associations within the insurance community to ensure diversified representation of the community's interests and needs. - The ABA and Roundtable, whose collective members expressed concerned about the protection of financial gTLDs, led the formation of FRS to protect the insurance community, including, its institutions and, most especially, the consumers of insurance services. Both will continue their involvement in two significant ways. First, they will be Directors on FRS' Board. Further, they will provide continuing oversight of the management of FRS, the operator of .insurance and will have as part of their ongoing service and mission the ability to communicate with and represent the entire insurance community as associations. - Collectively, this broad community of key insurance leaders will continually assess the policies, processes and operations of .insurance and assure that it continues to operate in the best interest of the insurance community and in the spirit of FRS' mission. Lastly, the community will hold FRS accountable to ensure that applicants for .insurance domains are thoroughly vetted and agree to adhere to the strict set of operating rules and security standards that govern the licensing and operation of a .insurance domain.

• Intended registrants in the TLD. As stated above and in Question 18, the .insurance community will be clearly defined along the same lines as the current U.S. insurance community is defined by regulation and law. Registrations within the community may initially be made by the following for-profit and not-for-profit businesses, individuals or organizations: - Licensed insurance companies regulated by a government entity - Licensed insurance agents and brokers regulated by a government entity - Associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board) - Organizations that are majority controlled by insurance companies (if approved by the FRS Board) - Entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board) - Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board) • Intended end-users of the TLD. End users will not only include the registrants of the .insurance gTLD, but also millions of the industry's current and potential consumers. Once .insurance is established as a trusted gTLD for products, services and matters related to the insurance industry, consumers will acknowledge the security and stability associated with the .insurance gTLD. • Related activities the applicant has carried out or intends to carry out in service of this purpose. FRS is submitting this application on behalf of the insurance community to ensure that the .insurance gTLD shall serve as a trusted, hierarchical, and intuitive namespace for this community and the consumers that it serves. All registrants within this gTLD will be vetted prior to registration to validate their identity, chartering or licensing entity where appropriate and commitment to industry best standards developed by FRS before they are able to register in the .insurance gTLD (see 20(e) below). In addition, the registry will employ a network of both active and passive safeguards to the operation of the registry to ensure that these registrants continue to abide by the terms and conditions set forth in the registration agreement. Security standards, created by the financial services community for use specifically by financial gTLDs, will be employed by FRS (the details of which have already been worked out with FRS' backend registry operator). Marketing and promotion of the .insurance gTLD will be conducted on an ongoing basis to ensure acceptance, familiarity and trust among members of the community. FRS has actively engaged several insurance-related trade associations to inform them of FRS' activities and what it could mean for their respective members. However, the registry will also be promoted by the Board of Directors and registrants due to the security features and standards employed within this space. Insurance providers and affiliates will have an incentive to direct consumers to the .insurance sites they operate, and thus promote their second-level domains containing .insurance across all media. Consumers will quickly become familiar with .insurance and see that its use is limited to trusted organizations within the insurance industry. • Explanation of how the purpose is of a lasting nature. The .insurance gTLD will ensure that consumers are aware of a gTLD that provides trustworthy and vetted entities with legitimate insurance products and services, absent some of the abuses seen currently on the internet. This gTLD has a lasting nature because it shifts the burden of confirming authenticity from the consumer to the registry or its designated third-party service provider. Further, it will allow the consumer to conduct a simple search, within the domain, that will result in a limited pool of legitimate second-level registrants. The beauty of this streamlined search and worry-free access to insurance providers would best ensure the lasting nature of .insurance and result in a successful .insurance launch. As stated in 20(b) above, the continued success of .insurance is centered on its role as a trusted and safe environment. The Internet user increasingly finds him or herself challenged by opportunists and charlatans that present themselves as legitimate online businesses. This is a particular challenge in the insurance industry because consumers that are not well informed about the legitimacy of online businesses may provide and entrust sensitive personal and financial information to non-insurance providers. Rogue online operators register domains in other gTLDs that look similar to legitimate members of the insurance community because they also have second-level domains registered in other gTLDs. Consumers are consistently lured into ʺphishingʺ attacks by email either promising them unrealistic deals or posing as their own insurance providers. These online practices cost the insurance industry and consumers in time and dollars. RSA, a premier provider of security, risk and compliance management solutions for business, provided the following in their Online Fraud Report of January 2012: - In 2011, approximately one in every 300 emails was deemed to contain phishing elements, most targeted to the public sector, followed by the SME business sector. - The cumulative number of phishing attacks recorded through 2011 was 279,580—a 37% increase from 2010. - In 2011, phishing attacks targeted brands from 31 different geographies and emails communicated in 16 different languages - reaching an even more diverse crowd of Internet users. The top countries in which the most brands were attacked include: the U.S., the UK, Australia, Canada, India, and Brazil. Phishing has become easier with more automated toolkits available. On average, every phishing attack yields a $4,500 profit. - The U.S. was the second-most targeted country with 28% of all phishing attacks. Only the United Kingdom was targeted more. - Together, the U.S. and UK accounted for 43% of the world's targeted brands, while the brands of 14 additional countries accounted for a total of 39% of phishing attacks in December. FRS seeks to minimize the incidence of this type of online behavior within the .insurance gTLD by the strict vetting planned for each second-level .insurance domain. With the addition of employing security standards developed by the financial services industry, FRS plans to significantly diminish the risk of insurance-related phishing for millions of insurance consumers.

• Relationship to the established name, if any, of the community. The .insurance gTLD is perfectly aligned with the needs and services of the insurance community as defined in 20(a), providers of insurance and their affiliates, and the gTLD name - the industry product sold - solidly identifies the community and its products. Founding members from the insurance industry have reported to FRS that based on their consumers' online and search behavior, "insurance" is the term that consumers associate most with the insurance industry. As a result, FRS' Board of Directors, comprised of members of the insurance industry, voted and approved that it move forward with an application for the .insurance gTLD. Consumers will understand the connection between the gTLD and the existing business. As already established in 20(c), any second-level domain registrant in the .insurance space will have been vetted to ensure they are an eligible member of the community. As .insurance gains more registrants and those registrants promote their .insurance URLs to consumers on the Internet, the .insurance name will become increasingly more familiar to the online community. The key goal will be that the .insurance gTLD be linked in the consumer's mind with the community identified in 20(a), specifically insurance providers and affiliates. As stated above, the .insurance gTLD is not intended for widespread distribution, so with no registrants outside the defined community, there will be little confusion on the part of consumers or potential registrants. • Relationship to the identification of community members. Members of the community are insurance providers and their affiliates. Vertical and horizontal integration are found within the community, but all potential registrants shall have the criteria established in 20(c) in common. As such, registrants include licensed insurance companies regulated by a government entity, licensed agents and brokers regulated by a government entity, associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board), organizations that are majority controlled by insurance companies (if approved by the FRS Board), entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board), and specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board).  The creation of FRS was requested by insurance providers; it represents insurance community members and therefore has a direct stake in ensuring the trustworthiness and reliability of .insurance and its governance. FRS' broad reach in the insurance industry provides it with an advantage in its operation of .insurance. FRS's Board of Directors and Advisory Board will serve as representatives of the insurance community. FRS' Operating Managers, ABA and the Roundtable, represent the insurance community and each has members that are insurance providers. As is the case in such organizations, FRS and its Operating Managers have strict governance protocols to ensure no one insurance industry player unduly influences or controls the organization. Further, that strong governance protocol carries vertically to FRS and to the operation of .insurance. Potential .insurance registrants will be aware that FRS will operate the .insurance gTLD without bias toward any particular sector or player within the broader insurance community. • any connotations the string may have beyond the community. None.

• Eligibility: who is eligible to register a second-level name in the gTLD, and how will eligibility be determined? Registrations within the community may initially be made by the following business, individuals or organizations: - Licensed insurance companies regulated by a government entity - Licensed insurance agents and brokers regulated by a government entity - Associations whose members include licensed insurance companies, agents or brokers (if approved by the FRS Board) - Organizations that are majority controlled by insurance companies (if approved by the FRS Board) - Entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board) - Specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board) As the potential operator of .insurance, FRS considers its commitment to both the insurance industry and the consumers it serves of paramount importance. The nature of the activity that will be conducted in .insurance requires that registrations only be permitted by verified members of the insurance community. In addition to validating the eligibility of the registrant, the domain name must comply with name selection and use policies. To ensure strict compliance with these policies, FRS will develop and implement a Registrant Eligibility Criteria Process. This process will require .insurance accredited registrars to gather materials from proposed registrants that will be used by the registry or its designated third party services provider, to authenticate the registrants' eligibility to register in .insurance. The registration process for a .insurance name includes that potential registrants must provide the registrar with the following information: - Full legal name - Business address - Professional title of representative of the administrative contact of the potential applicant - Business name - Point of contact within the business who can verify their representation of the business - Phone - Email - Another proof of identity necessary to establish that the registrant is an eligible member of the .insurance gTLD community - For insurance companies, the state regulatory authority issuing its charter - For agents and brokers, the state licensing agency issuing its permission to act as an agent or broker - For organizations that are majority controlled by insurance companies (if approved by the FRS Board), list of and proof of its owner(s) - For entities whose operations are principally dedicated to serving insurance companies (if approved by the FRS Board), corporate operating agreement or like document(s) as determined necessary to validate alignment with the goals of the community - For specialized organizations (e.g., research or risk coordination) (if approved by the FRS Board), a copy of its corporate operating agreement if for-profit or its mission statement if non-profit (or like document(s) as determined necessary to validate alignment with the goals of the community) Applicants who meet the eligibility requirements and have been authenticated will then be permitted to register domains in .insurance. Domain names that pass the vetting process will enter a 5-day Add Grace Period (AGP), or Pending Create, before becoming valid. Applicants whose domain name fails the vetting process will be notified with reasons for denial and procedures for appeal. Any applicant who is rejected for any reason can appeal the decision to FRS. FRS will audit all approved registrants and their domains to ensure compliance with all applicable eligibility and use requirements. • Name selection: what types of second-level names may be registered in the gTLD. Domains initially registered in .insurance must correspond to a trademark, trade name or other service mark owned by the registrant. Initially, all other registrations (e.g., geographic, generic, etc.) will not be allowed. FRS will reserve a set of generic domain names prior to launch. These domain names will either be used by FRS in its capacity as Registry Operator for the management, operation, and purpose of the gTLD or they will be equitably allocated to community members at a date and time to be determined by FRS' Board. The subset of domain names reserved for FRS' use is necessary to create a trusted, hierarchical, and intuitive framework for the .insurance gTLD. Although these reserved words will be commonly used words and phrases and or geographic terms, FRS will provide an enhanced Rights Protection Mechanism that will offer trademark owners with an avenue to challenge the reservation and potential use of these domain names. This challenge process will be modeled after the highly successful dotAsia Pioneering Program. • Content/Use: what restrictions, if any, the registry operator will impose on how a registrant may use its registered name? FRS will have an Acceptable Use Policy (AUP) that will govern how a registrant may use its registered name. A DRAFT version of the policy (which may be amended from time to time) follows: All .insurance domains must be used to serve the needs of the insurance community. By registering a name in a gTLD operated by FRS, you agree to be bound by the terms of this Acceptable Use Policy (AUP). In using your domain, you may not: 1. Use your domain for any purposes prohibited by the laws of the jurisdiction(s) in which you do business or any other applicable law. For insurance companies, agents and brokers specifically, use your domain name for any purposes prohibited by the insurance regulations of the regulator or government agency that issued your charter or license is strictly prohibited. 2. Use your domain for any purposes or in any manner that violates a statute, rule or law governing use of the Internet and/or electronic commerce (specifically including "phishing," ʺpharming,ʺ and/or distributing Internet viruses and other destructive activities). 3. Use your domain for the following types of activity: - Violating the privacy or publicity rights of another member of the insurance community or any other person or entity, or breaching any duty of confidentiality that you owe to another member of the .insurance gTLD community or any other person or entity; - Promoting or engaging in hate speech, hate crime, terrorism, violence against people, animals, or property, or intolerance of or against any protected class; - Promoting or engaging in defamatory, harassing, abusive or otherwise objectionable behavior; - Promoting or engaging in pornography; - Promoting or engaging in any spam or other unsolicited bulk email, or computer or network hacking or cracking; - Promoting or engaging in any money laundering or terrorist financing activity; - Infringing on the intellectual property rights of another member of the .insurance gTLD community or any other person or entity; - Engaging in activities designed to impersonate any third party or create a likelihood of confusion in sponsorship; - Interfering with the operation of .insurance gTLD or services offered by FRS; - Distributing or installing any viruses, worms, bugs, Trojan horses or other code, files or programs designed to, or capable of, disrupting, damaging or limiting the functionality of any software or hardware; - Disseminating content that contains false or deceptive language, or unsubstantiated or comparative claims, regarding FRS; - Licensing your domain to any third party during the period of your registration; or - Engaging in behavior that is anti-competitive, boycotts or otherwise violates anti-trust laws. You are responsible for the usage of your domain at all times during the period of your registration. Proxy registrations are prohibited for all gTLDs operated by FRS. By "use," "usage" or "using" your domain name we mean any use involving the Internet, including but not limited to website(s) and/or any pages thereof resolving at your domain, either directly or indirectly (including redirection, framing, pop-up windows/browsers, linking, etc.) and email distribution and/or reception. As part of the AUP, FRS will have complete enforcement rights over registrants' use of domain names. • Enforcement: what investigation practices and mechanisms exist to enforce the policies above, what resources are allocated for enforcement, and what appeal mechanisms are available to registrants? FRS proposes the use of both active and passive enforcement mechanisms to enforce the policies outlined above. As part of the AUP, FRS will have complete enforcement rights over registrant's use of .insurance domain names. If Registrant violates this AUP, Registrant will be subject to a rapid domain name compliance action, be in material breach of the Agreement, and along with all other rights and remedies under this Agreement with respect to such a breach, FRS reserves the right to revoke, suspend, terminate, cancel or otherwise modify Registrant's rights to the domain name. On a regular basis, FRS will audit domain names registered in the .insurance gTLD to ensure compliance with all eligibility and use criteria. If a violation is discovered, an investigation will immediately begin to rectify the violation. If a registrant chooses to appeal, FRS will review the appeal to determine if there are any material changes to the action or activity. FRS will retain the right to assign the dispute to an ombudsman if necessary. This appeal or referral process will operate on a cost-recovery basis.

22.1 fTLD Registry Services, LLC (FRS) has Properly Researched this Topic

FRS is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the DNS. In preparation for answering this question, FRS reviewed the following relevant background material regarding the protection of geographic names in the DNS:

- ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain, see http://www.icann.org/en/minutes/minutes-10sep01.htm;
- ICANN's Proposed Action Plan on .INFO Country Names, see http://www.icann.org/en/meetings/montevideo/action-plan-country-names-09oct01.htm;
- Second WIPO Internet Domain Name Process - The Recognition and Rights and the Use of Names in the Internet Domain Name System, Section 6, Geographical Identifiers, see http://www.wipo.int/amc/en/processes/process2/report/html/report.html;
- The GAC Principles Regarding New gTLDs, see https://gacweb.icann.org/download/attachments/1540128/gTLD_principles_0.pdf?version=1&modificationDate=1312358178000
- ICANN's Generic Names Supporting Organization Reserved Names Working Group - Final Report, see http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.htm

22.2 Initial Reservation of Country and Territory Names

FRS is committed to initially reserving the country and territory names contained in the internationally recognized lists described in article 5 of Specification 5 attached to New gTLD Applicant Guidebook at the second level and at all other levels within .insurance gTLD at which FRS will provide for registrations. Specifically, FRS will reserve;

1. the short form (in English) of all country and territory names contained on the ISO 3166-1 list, as updated from time-to-time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union 〈http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166- 1_decoding_table.htm#EU〉;

2. the United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and

3. the list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

22.3 Fair & Non-Misleading Use of Geographical Identifiers

The members of the financial services community are a highly regulated industry in their respective countries, and thus have a compelling interest to make sure that any use of geographic identifiers in advertising is fair and non-misleading. In fact many members of the financial services community make regular use of geographical identifiers at the second level or third level in domain name registrations usually coupled with their company name or trademark. This is in addition to registration of their company name and other trademarks across a wide number of gTLDs and ccTLDs.

FRS would like to provide a hierarchical and intuitive framework for the .insurance namespace by using geographical identifiers as a second-level domain name. This use of geographical identifiers to the left of the TLD and as part of the domain name itself, upon information and belief is belief to have a direct and material impact on search engine algorithms and their corresponding query results. As ICANN has largely premised this new gTLD round on promoting innovation, FRS would like to see if this type of hierarchical and intuitive use of second-level domain name within a TLD provides increased consumer functionality.

22.4 The Legal Protection of Geographical Identifiers

One of the more authoritative resources on the current state of the law in connection with the protection of geographical identifiers was authored by the World Intellectual Property Organization (WIPO) in its 2001 Second WIPO Internet Domain Name Process, The Recognition of Rights and the Use of Names in the Internet Domain Name System (DNS). Chapter six of this report was devoted exclusively to the protection of Geographical Identifiers.

In analyzing the well-established framework against the misuse of geographical identifiers at the international, regional and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications. See Second WIPO Internet Domain Name Process (Paragraphs 206 and 210).

Notwithstanding WIPO's recommendation that the protection of geographical identifiers is "a difficult area on which views are not only divided, but also ardently held" (Paragraph 237) national governments within the ICANN Governmental Advisory Committee (GAC) and other international fora have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the domain name system.

FRS and the members of the financial services community parent, as responsible international businesses, seek to minimize any potential business practices that might mislead consumers. However, at the same believe that it is important to be able to use geographical identifiers in a fair use and non-misleading manner, if such use can benefit users as proposed in FRS' proposed business model.

22.5 Fair & Non-Misleading Use of Geographical Identifiers

In undertaking a thorough research of this subject matter prior to filing this application, FRS' subject matter experts were able to uncover the following representative sampling of fair and non-misleading use of geographical identifiers used in the existing gTLD domain name space:

Fair Use of National Geographical Identifiers

〈AUSTRALIA.COOP〉 - Is operated by Co-operatives Australia the national body for State Co-operative Federations and provides a valuable resource about cooperatives within Australia.

〈UK.COOP〉 - Is operated by Co-operatives UK the national trade body that campaigns for co-operation and works to promote, develop and unite co-operative enterprises within the United Kingdom.

〈NZ.COOP〉 - Is operated by the New Zealand Cooperatives Association which brings together the country's cooperative mutual business in a not-for-profit incorporated society.

〈USA.JOBS〉 - Is operated by DirectEmployers Association (DE). While Employ Media the registry operator of the .JOBS gTLD is currently in a dispute with ICANN regarding the allocation of this and other domain names. Direct Employers has a series of partnerships and programs with the United States Department of Labor, the National Association of State Workforce Agencies and Facebook to help unemployed workers find jobs.

〈MALDIVIAN.AERO〉 - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.

Fair Use Regional /Local

〈TEXAS.JOBS〉 - Is operated a joint effort between DE, Texas Workforce Commission and the National Labor Exchange to connect job seekers with approximately 96,000 job openings. An additional domain name operated by this joint effort was 〈WORKINTEXAS-VETERANS.JOBS〉 a resource devoted to helping Texas veterans translate their military skills to jobs in the civil marketplace.

〈BOISE.COOP〉 - Is operated by Boise Co-op a member owned cooperative, founded in 1973 by a few dozen individuals who shared a mutual interest in buying healthy and organic food at reasonable prices.

〈BROOKLYN.COOP〉 - Is operated by Brooklyn Cooperative Federal Credit Union who began as a modest storefront business in 2001, but is now New York City's fastest growing credit union and a model for community development credit unions nationwide.

〈HYDERABAD.AERO〉 - Is operated by the Hyderabad International Airport and provides a range of interactive services and information for both business and leisure travelers.

〈SACRAMENTO.AERO〉 - Is portal website operated by Sacramento county to provide links to each of the airports serving the Sacramento area: Sacramento International Airport (SMF), Mather Airport (MHR), Executive Airport (SAC) and Franklin Field (F72).

22.6 Protection of Regional and Local Geographic Names for Misleading Use

Although FRS has stated its intention to use non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading use to help consumers navigate the .insurance namespace. FRS is committed to operating the .insurance namespace in a manner that minimizes potential consumer confusion, and will with actively work with others in the ICANN community regarding any future policy development in this area.

22.7 Potential Future Release of Initially Reserved Names

FRS and the other members of the global financial services community look forward to working in connection with other new gTLD registry operators (especially those financial service community members that might be securing their own .brand TLD) in potentially working with ICANN's Governmental Advisory Committee to explore potential processes that could permit the release of initially reserved country names (including ISO-3166 two characters). Specifically, FRS is interested in exploring other Registry Service Evaluation Process (RSEP) requests that have been filed by existing gTLD registry operators in releasing previously reserved domain names.

22.8 Dispute Resolution

Applicant does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .insurance gTLD based upon its proposed use set forth in Answer 18 above.

However, FRS is committed to working with governments, public authorities, or Intergovernmental Organizations (IGOs) that may have a concern regarding the registration of names with national or geographic significance at the second level within the .insurance gTLD. Therefore, should there arise any potential disputes, FRS will undertake an immediate policy development process as identified below.

22.9 Creation and Updating the Policies

If there should arise some future need for the creation or updating of the policies regarding this class of domain names, FRS will act in an open and transparent manner consistent with its prior practices within the global financial services community to develop such a policy and/or recommendation.

FRS is also committed to continually reviewing and updating these lists to prevent misleading use of geographical identifiers. Consistent with this commitment, FRS intends to remain an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.