.lifeinsurance Pre-Register Domain - .lifeinsurance Domain Information

18.1 Mission and Purpose of .LIFEINSURANCE

The American Council of Life Insurers ("ACLI") is a Washington, D.C.-based trade association representing an industry with more than 200 years of experience providing financial security to American families, workers, and businesses.

With more than 300 legal reserve life insurer and fraternal benefit society member companies operating in the United States, ACLI members represent more than 90% of the assets and premiums of the life insurance and annuity industry. In addition, ACLI member companies offer pensions, 401(k) and other retirement plans, long-term care and disability income insurance, and reinsurance.

Seventy-five million—or two out of three—American families count on life insurers' products for protection, long-term savings, and a guarantee of lifetime income when it is time to retire. Given today's economic uncertainties, the financial and retirement security that these products provide has never been more important.

ACLI's public website can be accessed at www.acli.com.

.LIFEINSURANCE Purpose

ACLI has filed this application for the .LIFEINSURANCE gTLD with the intention of bringing to market a trusted, hierarchical, and intuitive namespace for a self-defined community of organizations and potentially individuals, the primary focus of which is on providing and exchanging information regarding life insurance products and potentially annuities, pensions, 401(k)'s, and other retirement plans, long-term care, disability income insurance, and reinsurance. This .LIFEINSURANCE gTLD may also serve as a secure repository of products and services related to life insurance policies and other associated financial instruments.

ACLI does not intend to apply for a community designation under ICANN's Applicant Guidebook criteria. However, ACLI is committed to operating the .LIFEINSURANCE gTLD with a narrow focus and charter that ACLI will take the lead in establishing. This restrictive charter/membership criteria will be developed in consultation with ACLI's member organizations, representing more than 90% of the assets and premiums of the life insurance and annuity industry in the United States, and will serve multiple purposes, including but not limited to, a trusted online source of information, minimizing the need for defensive registrations and domain name speculation, enhanced rights protection mechanisms, and the prohibition of proxy registrations.

18.1.2 Potential Business Models

ACLI is still analyzing potential use case options for the type of domain names that will be permitted for registration in the .LIFEINSURANCE gTLD, as well as which entities and/or individuals will make up the potential registrant pool. However, these decisions will be embodied in the proposed gTLD charter/membership criteria. In undertaking this research, ACLI is leveraging its organizational experience in networking with existing members, affiliates, partners, and the customers of its members. ACLI currently envisions a three-stage rollout for the .LIFEINSURANCE gTLD as shown below.

Stage One

The initial stage of implementation of the .LIFEINSURANCE gTLD will involve ACLI registering a limited number of .LIFEINSURANCE second-level domain names.

The current best thinking involves a business model in which generic (ʺpolicy," "family," "jobs," "members," "benefits," "investing," etc., as examples) and geographic (city/state) domain names would initially be reserved/allocated to ACLI. These domain names would provide a framework for a hierarchical and intuitive naming system for members and consumers to more easily navigate the .LIFEINSURANCE namespace. This initial use will provide ACLI's IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .LIFEINSURANCE domain names and interoperability with various software and Web-based applications. The registration and use of these domain names are intended to be within the scope of Section 1B of Specification 9 of the Template Registry Agreement, regarding the maintenance, operation, and purpose of the gTLD.

Stage Two

Once successful testing has been completed, ACLI's existing members and potentially select partners would be allowed to register domain names in the .LIFEINSURANCE gTLD. At this time, ACLI has not determined the identity of these select partners; however, any third party would be required to have a prior commercial agreement with ACLI. This initial rollout guarantees that the identity and contact information for each .LIFEINSURANCE domain name registrant will be verifiable based upon a preexisting business relationship. This allocation mechanism also minimizes the startup and operational costs of the .LIFEINSURANCE gTLD.

This initial allocation of domain names within the gTLD will allow ACLI to properly and sustainably develop the .LIFEINSURANCE gTLD in such a manner as to ensure that the gTLD is viewed by Internet users as a trusted namespace for access to information regarding life insurance products, as well as potentially being a secure repository of goods and services related to life insurance policies and other financial instruments.

Given the fact that ACLI will have full control over the number of registrations in the .LIFEINSURANCE gTLD namespace, ACLI is confident that the number of domain name registrations will be less than 10,000 in the first three years of operation.

It is in Stage Two that ACLI will evaluate expanding the operations of the .LIFEINSURANCE gTLD to permit registration by other registrants outside of members and strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to these other parties, this expansion is currently planned to take place during Stage Three, and likely after the first five years of operation.

Stage Three

Based on its experience with any expansion implemented in Stage Two, ACLI will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of partners, potential customers of ACLI's members, and other third parties. However, it is the current intention that ACLI would require any class of future potential registrants to be in compliance with, and legally bound by, the restrictive membership / charter criteria mentioned above.

It is anticipated by ACLI that changes to the domain name industry, and particularly the impact of new generic-term gTLDs, will take at least five years to be realized and assessed. Any decision to expand the gTLD beyond member and partner use would likely be predicated by an ACLI analysis of both the market at the time for new gTLD registrations and consumer adoption of these new Internet addresses.

If ACLI's market analysis justifies this expansion before the sixth year of operation, ACLI would, if necessary, work with ICANN to secure an amended Continued Operations Instrument (COI)corresponding to a potential increase in registration volume above the current executed level. However, this scenario is unlikely because ACLI, in calculating its COI, has already exceeded the baseline guidance set forth by ICANN.

Notwithstanding this potential future expanded use of the .LIFEINSURANCE name space beginning in the sixth year of operation, ACLI currently anticipates implementing a throttle mechanism to ensure that any proposed expansion is controlled and responsible. This proposed "time-out" mechanism is described in greater detail in the responses to the financial questions (Question 45-50 of this application).

The potential use of the .LIFEINSURANCE gTLD will also be driven by ACLI's and its members' future business strategies.

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

ACLI believes that the proposed .LIFEINSURANCE gTLD has the potential to offer the following benefits to Internet users and consumers:

-Establish a trusted online hub and potential marketplace for consumers around the world seeking information and services related to life insurance policies and related products and instruments;
-Provide short and memorable domain names that will facilitate the ease with which consumers can locate this information and associated services online;
-Develop a potential platform for consumers for the secure access to, and purchase of, life insurance policies and related products and instruments, in order to minimize the potential for infringing or fraudulent products and services;
-Ensure fewer incidents of phishing and malware, which are often associated with the mistyping of domain names in the .COM space; and
-Incorporate enhanced intellectual property rights (IPR) protection mechanisms.

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

ACLI has filed this application for a .LIFEINSURANCE gTLD with the intention of bringing to market a trusted, hierarchical, and intuitive namespace for a community of individuals and organizations, the primary focus of which is on providing and exchanging information regarding life insurance products and related products and services.

The primary mission and purpose of the .LIFEINSURANCE gTLD is to provide a trusted online hub for ACLI, its members, and potentially partners and other third parties, to register domain names in a secure and natural online environment. The .LIFEINSURANCE namespace may also serve as a repository to aggregate information, products, and services related to life insurance, annuities, and other associated financial instruments, for use by consumers and those within the insurance community.

As technologies for delivering content and services evolve, ACLI will continue to pursue and explore opportunities for its members to market and distribute products and services to consumers. ACLI believes that the .LIFEINSURANCE gTLD has the potential to provide a virtual platform to offer secure, interactive features to deepen and broaden its members' relationships with existing and new partners, as well as deepening and broadening these members' relationships with their customers and Internet users.

With regard to service level and reputation, ACLI will operate the .LIFEINSURANCE gTLD in accordance with its position as a representative trade association of an industry with more than 200 years of experience providing financial security to American families, workers, and businesses.

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

Unlike most generic-term gTLDs that ICANN has approved over the last decade, which have largely been operated by Internet startups and have been primarily dependent upon ICANN-accredited registrars to market and promote their gTLD, ACLI is an established member organization with the ability to leverage its existing network of over 300 legal reserve life insurer and fraternal benefit society member companies and their customers, to increase the profile of the .LIFEINSURANCE gTLD. ACLI members represent more than 90% of the assets and premiums of the life insurance and annuity industry in the United States.

While some of ICANN's new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, .LIFEINSURANCE from its launch will be a trusted online source of information about life insurance and related products and services. ACLI will follow its own and its members' established good business practices in working with law enforcement to create a marketplace with safeguards designed to minimize fraud and other illegal activity.

ACLI believes that the long-term success of this gTLD will not be measured by the number of domain names registered. Instead, it will be measured by the level of consumer recognition and trust that is placed in the .LIFEINSURANCE gTLD. Using this benchmark, ACLI strives to build consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.

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

ACLI believes that the .LIFEINSURANCE gTLD has the potential to provide a single trusted ecosystem experience for the hundreds of millions of ACLI's members' existing and future consumers, who access content through existing online, print, mobile, and social platforms. By providing the foundation of this trusted ecosystem, all domain name registrants within the .LIFEINSURANCE gTLD will be able to share in the benefits of this collective resource. As the recognized representative trade association of the U.S. life insurance and annuity industry, ACLI believes that it can be a pioneer in bringing innovation in consumer choice to this new Internet medium, the .LIFEINSURANCE gTLD.

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

ACLI is fully committed to implementing all of ICANN's consensus policies and other Rights Protection Mechanisms (RPMs) identified in the Applicant Guidebook. Moreover, based upon ACLI's and its members' commitment and established track record in providing a safe ecosystem for consumers and vendors, ACLI intends to provide best-in-class safeguards that will evolve over time.

At the time of completing this application, ACLI has identified a Rights Protection Mechanism (RPM) that will allow trademark owners to challenge domain names initially reserved by the registry (e.g., generic and geographic names identified in Section 18.1.2). This process will be modeled after the dotAsia Pioneer Policies adopted by dotAsia in connection with its launch, see http://www.wipo.int/amc/en/domains/gtld/asia/.

18.2.5 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.

ACLI recognizes this is an evolving area of law in which there is no international standard. ACLI has a vested interest to make sure that accurate and current information is readily available in connection with each domain name. If unaffiliated third parties are eventually permitted to register personalized domain names in the .LIFEINSURANCE gTLD, ACLI will reevaluate its policies at that time to ensure that they are in compliance with the current best-in-class policies.

ACLI, as the recognized representative trade association of the U.S. life insurance and annuity industry the members of which operate in many legal jurisdictions and on the Internet, respects the privacy of its members, their customers, and other consumers. The organization employs a variety of electronic, contractual, and managerial safeguards to protect personal and confidential information on its websites. ACLI strives to ensure that all information not known to the general public is kept strictly confidential. ACLI will take similar precautions to protect registrant and user data associated with the .LIFEINSURANCE gTLD. For more information, see http://www.acli.com/Tools/Pages/Privacy%20Statement.aspx.

In addition, ACLI intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language which has been included in the template Registry Agreement and which has been successful utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states "Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person ("Personal Data") submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar 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.ʺ

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

As noted in 18.2.2, most of the generic gTLDs that ICANN has approved have primarily been operated by Internet startups created solely for the provision of domain name registration services, e.g., .INFO (Afilias, Limited), .BIZ (NeuStar, Inc.), and .TRAVEL (Tralliance). Most registries have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD. However, ACLI is an established trade association with an extensive network of more than 300 legal reserve life insurer and fraternal benefit society member companies operating in the United States. ACLI thus has the ability to leverage this network in order to increase the profile of the .LIFEINSURANCE gTLD.

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

Over the past decade, ICANN has approved fifteen new gTLDs which have historically been classified as either generic (.INFO, .BIZ, .NAME) or sponsored (.ASIA, COOP, .TRAVEL, .JOBS, etc.) gTLDs. It is anticipated that in this current new gTLD application round, many large international corporations will take the opportunity to register generic strings as top-level domains. This is a new approach to the operation of a gTLD in which the business plan relies on three important distinctions between it and the gTLDs that were approved in the 2001 and 2004 rounds of expansion.

First, there are now approximately ten small gTLDs that have fewer than 300,000 registrations and that offer clear models of successful operation; second, at least three experienced technical back-end suppliers (i.e., SRS/DNS services) are in place; and third, with many new generic-term gTLDs, well-understood registry operations will be fully supported by an established and financially sound business or organization operating a generic-term gTLD in addition to, and in conjunction with, its primary business or mission.

The .LIFEINSURANCE gTLD presented here minimizes the risk and uncertainty of prior gTLDs by drawing upon more than a decade of gTLD industry development and by relying upon the extensive member network and secure financial position of ACLI.

ACLI believes that the safeguards set forth in the Applicant Guidebook and additional RPMs identified in Section 18.2.4 of this Question 18, are primary drivers to minimize potential negative social costs. ACLI also believes that the initial launch of the .LIFEINSURANCE gTLD through known business entities with existing contractual relationships with ACLI will also be an important impediment to any potential negative social costs.

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

ACLI believes that the proposed operation of the .LIFEINSURANCE gTLD as set forth in this application has minimum known negative consequences or cost implications to consumers. To the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to consumers. ACLI believes that by following the ethical corporate business practices it has established it will be able provide real value to consumers and minimize any potential negative consequences/costs.

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

ACLI does not envision multiple applicants for the same domain name, given the phased approach and limited initial registrant universe. However, if such an instance should arise, ACLI believes that a phased equitable allocation approach, modeled after those that ICANN has previously approved in connection with numerous ICANN Registry Service Evaluation Process (RSEP) requests, would be the most prudent path forward, e.g., RFP, auction, and then first-come-first-serve.

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

During the initial rollout of the .LIFEINSURANCE gTLD, it is possible that select domain names will be allocated to existing members as a value-added service. However, there will likely be no determination made regarding long-term domain name pricing/discount policies until such time that policies regarding expanded registration and use of domain names to third parties outside the immediate network of ACLI members and select partners are implemented.

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

ACLI 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. However, as noted in the proposed business model in this Question 18 (refer to 18.1.2), ACLI currently envisions initially offering domain name registration services mainly to ACLI members. In these cases, having an existing contractual relationship with ACLI would be a condition for the ability to register a .LIFEINSURANCE domain name.

ACLI 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." ACLI will initially offer one-year domain name registrations with an option to renew annually.

If ACLI moves forward with a validation process whereby parties outside the proposed network of ACLI members and select partners, without such a stringent commercial agreement, are permitted to register and use .LIFEINSURANCE domain names, ACLI is fully committed to providing these domain name registrants with annual registrations that include pricing predictability and notice in connection with the registration of domain names. However, in connection with potential premium generic or geographic domain names there may be additional requirements that would legally bind these registrants in connection with the registration and use of these domain names. These terms will be known by this class of domain name registrants prior to the creation of any legal obligation between the parties.

Answer for Question 22

22 ACLI Has Properly Researched This Topic

The American Council of Life Insurers ("ACLI") is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the Domain Name System (DNS). In preparation for answering this question, ACLI 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;

Report of the 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.

22.1 Initial Reservation of Country and Territory Names

ACLI 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 the New gTLD Applicant Guidebook at the second level and at all other levels within the .LIFEINSURANCE generic top-level domain (gTLD), at which ACLI will provide for registrations. Specifically, ACLI will reserve:

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, see http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166- 1_decoding_table.htm - EU;

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

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

22.2 Fair & Non-Misleading Use of Geographical Identifiers

ACLI is a Washington, D.C.-based trade association representing an industry with more than 200 years of experience providing financial security to American families, workers, and businesses.

With more than 300 legal reserve life insurer and fraternal benefit society member companies operating in the United States, ACLI members represent more than 90% of the assets and premiums of the life insurance and annuity industry. In addition, ACLI member companies offer pensions, 401(k) and other retirement plans, long-term care and disability income insurance, and reinsurance.

Given the national network of ACLI members and their customers, ACLI intends to explore the option of providing a hierarchical and intuitive framework for the .LIFEINSURANCE namespace by using geographical identifiers as second-level domain names. ACLI believes the use of geographical identifiers to the left of the gTLD and as part of the domain name itself has a direct and material impact on search engine algorithms and their corresponding query results.

In addition, such naming conventions are intuitive and practiced by direct navigation Internet users (those who type their intended destination into address bars as opposed to search engines). As ICANN has largely premised this new gTLD round on promoting innovation, ACLI would like to determine if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality.


22.3 The Legal Protection of Geographical Identifiers

The World Intellectual Property Organization (WIPO) authored an authoritative resource on the current state of the law in connection with the protection of geographical identifiers, its 2001 ʺReport of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name Systemʺ ("WIPO Report"). Section six of the WIPO Report was devoted exclusively to the protection of geographical identifiers.

From its analysis of 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 WIPO Report (Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in ACLI's current or proposed use of geographical identifiers.

Notwithstanding WIPO's observation 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 Government Advisory Committee (GAC) and other international fora have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the DNS.

ACLI, acting as a responsible member organization, seeks to avoid business practices that could potentially mislead consumers. ACLI believes, however, that it is important to be able to use geographical identifiers in a fair and non-misleading manner, if such use can benefit Internet users and consumers as proposed in the .LIFEINSURANCE business model.

22.4 Fair & Non-Misleading Use of Geographical Identifiers

In undertaking a thorough research of this subject matter prior to filing this application, ACLI uncovered the following examples 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 cooperation and works to promote, develop, and unite cooperative enterprises within the United Kingdom.

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

USA.JOBS - Is operated by DirectEmployers Association (ʺDEʺ). 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, DE 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 of Regional/Local Geographic Identifiers

TEXAS.JOBS - Is operated through a joint effort between DE, the 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 healthful and organic food at reasonable prices.

BROOKLYN.COOP - Is operated by Brooklyn Cooperative Federal Credit Union, which 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 a 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).

22.5 Protection of Regional and Local Geographic Names for Non-Misleading Use

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

22.6 Potential Future Release of Initially Reserved Names

As a national organization, ACLI looks forward to collaborating with other new gTLD Registry Operators in potentially working with the GAC to explore processes that could permit the release of initially reserved country names (including ISO-3166 two characters). Specifically, ACLI is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD Registry Operators in releasing previously reserved domain names.

22.7 Dispute Resolution

ACLI does not anticipate any disputes with governments or public authorities arising in connection with the registration and use of geographic names within the .LIFEINSURANCE gTLD based upon its proposed use set forth in Answer 18 of this application. Nevertheless, ACLI is committed to working with governments, public authorities, or IGOs to quickly resolve any such potential disputes.

22.8 Creation and Updating the Policies

Should the need arise in the future for the creation or updating of the policies regarding this class of domain names, ACLI will act in an open and transparent manner to develop such a policy and/or recommendation.

ACLI is also committed to the ongoing review and updating of these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, ACLI intends to participate in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.