.apartments Pre-Register Domain - .apartments Domain Information

18.1 Mission and Purpose of .APARTMENTS

DERApartments, LLC (hereafter "DERApartments"), a wholly owned subsidiary of Dominion Enterprises ("Dominion"), has filed this application for a .APARTMENTS gTLD with the intention of bringing to market a trusted, hierarchical, and intuitive namespace for consumers that will contain listings of apartments for rent, as well as a repository of goods and services related to apartments.

18.1.1 Dominion Enterprises

Dominion is a leading marketing services company serving the wide-ranging needs of many industries including real estate, apartments, specialty vehicles, employment, automotive, and travel, with over 3,000 employees located in 145 offices in 33 states and four countries. Its websites receive more than 17 million average monthly visitors and 279 million average monthly page views. For more information, see http://www.dominionenterprises.com/main/do/Fact_Sheet. Below is a representative listing of the apartment-related businesses that Dominion Enterprises currently owns and operates:

- For Rent Magazine®: For over 30 years, For Rent Magazine has been a trusted leader in showcasing rental housing in the multifamily space. With 70 print markets in major cities throughout the country, the magazineʹs print quantities exceed 20 million copies annually and are distributed in thousands of high-traffic grocery stores and other retail locations.

- ForRent.com® (http://www.forrent.com): ForRent.com is one of the leading websites in the apartment space. With over 20,000 paying customers, ForRent.com generates more than 3 million unique visitors each month. The site includes prices, floor plans, social sharing, virtual tours, and videos of apartment communities throughout the United States.

- After 55™ Housing and Resource Guide: Launched in 2001 as Senior Outlook Magazine, After 55 Housing and Resource Guide is available in 11 major markets. The publication is geared towards baby boomers planning for retirement, aging adults, and grown-up children who are researching housing options for their parents. More than a million Guides are distributed annually in thousands of locations nationwide.

- SeniorOutlook.com (http://senioroutlook.com): SeniorOutlook.com was introduced in 2001 to complement the print publication. An average of 60,000 unique visitors visit this site each month to view over 6,000 listings.

- Apartamentos Para Rentar® Magazine: Apartementos Para Rentar Magazine debuted in 2001 and currently covers 14 markets. The magazine targets one of the fastest growing demographics in the country and offers a way to reach out to the Hispanic consumer through custom-designed, full-color advertisements in a Spanish publication dedicated to apartment rentals.

- ParaRentar.com® (http://pararentar.com): ParaRentar.com launched in October 2006 and offers nearly 4,000 listings. ParaRentar.com is a fully Spanish-translated apartment listing website that offers an interactive, state-of-the-art medium to showcase apartment communities to an average of 46,000 monthly unique visitors.

- CorporateHousing.com® (〈http://corporatehousing.com〉): CorporateHousing.com launched in 2001 and is dedicated solely to short-term and/or temporary lodging. Approximately 70,000 unique visitors visit this site each month to find solutions for their temporary housing needs.

- ForRent.com mobile (m.forrent.com): ForRent.com mobile provides all the same great features as ForRent.com, but is customized for web-enabled phones. Prospective renters can view videos, pricing, floor plans, and more. ForRent.com mobile generates approximately 325,000 unique visitors each month.

18.1.2 Potential Business Models

DERApartments is still analyzing potential use case options regarding the type of domain names that will be permitted for registration and by whom. In undertaking this research, DERApartments is leveraging Dominion's experience in bringing critical business services to its customers in a safe and trusted online environment.

The business model for the .APARTMENTS gTLD is currently broken into two stages, one has been confirmed and the second is under evaluation and will be implemented after DERApartments has assessed the first stage. The two stages are as follows:

1. Allocated Strings and Client Strings

At the current stage of analysis, the business model for .APARTMENTS is one in which generic strings (ʺhigh-rise,ʺ ʺlow-rise,ʺ ʺmid-rise,ʺ ʺgarden style,ʺ ʺcondo,ʺ ʺloft,ʺ ʺbrownstone,ʺ ʺduplex,ʺ etc.) and geographic (city/state) domain names would initially be reserved and/or allocated to one or more Dominion online apartment-related properties. These domain names would provide a model for a hierarchical and intuitive framework and naming system for consumers to more easily navigate the .APARTMENTS namespace. This initial allocation would also provide Dominion's and its affiliates' IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .APARTMENTS gTLD domain names, and interoperability with various software and Web-based applications.

Following initial allocation, Dominion's existing clients across the different apartment property groups would be initially permitted to register domain names. This initial rollout guarantees that the identity and contact information of each .APARTMENTS domain name registrant will be known based upon a pre-existing business relationship. This allocation mechanism also minimizes DERApartments' startup and operational costs.

2. Registration by Non-Clients

DERApartments is currently evaluating a validation process to allow non-Dominion clients and other domain name registrants to register domain names in the .APARTMENTS gTLD. However, the exact timing of this proposed expanded universe of potential .APARTMENTS registrants has not been determined, and will not be finalized until appropriate verification mechanisms can be put in place.

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

DERApartments believes that a proposed .APARTMENTS gTLD has the potential to offer the following benefits to Internet users and consumers:

• Establish a trusted online marketplace for consumers seeking apartments and related goods and services;
• Provide short and memorable domain names that will facilitate the ease with which consumers can locate information online;
• Ensure fewer incidents of phishing and malware often associated with mistypes of domain names in the .COM space; and
• Incorporate enhanced intellectual property rights (IPR) protection mechanisms. Specifically, DERApartments will incorporate a Digital Millennium Copyright Act (DMCA)-like takedown mechanism. This policy will be modeled after Dominion's existing DMCA practices.

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

The primary mission and purpose of the .APARTMENTS gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to aggregate apartment-related goods and services. As technologies for delivering content and services evolve, DERApartments will continue to pursue and explore opportunities to distribute its goods and services to consumers. DERApartments believes that a .APARTMENTS gTLD has the potential to provide a virtual platform to offer interactive features to deepen and broaden its relationship with existing and new customers.

With regard to reputation, DERApartments is driven by the same core values upon which its parent company, Dominion, is founded:

• CUSTOMER COMMITMENT. We maintain an unwavering focus on the needs of our customers and continually integrate new solutions that make interaction with our brands a rewarding experience.
• CREATIVITY. We strive to empower employees at all levels of our organization to think creatively about our business and the customers we serve, and to actively pursue positive change.
• PERSONAL GROWTH. We are dedicated to creating opportunities for all of our employees to fulfill their individual and professional goals.
• TEAMWORK. We foster an environment that encourages working together to achieve a common goal while treating each other with consideration, trust, and respect.
• ETHICS. We maintain a strict commitment to the highest standards of ethical business practices.
• DIVERSITY. We believe the diversity of our people is one of our core strengths, and respect and value the varied backgrounds and perspectives of our employees.
• OUTREACH. We pride ourselves on being both a responsible employer and active contributor to the growth, development, and prosperity of the communities in which we work and live.

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

Most generic gTLDs that ICANN has approved over the last decade have largely been operated by Internet start-ups and have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD. DERApartments parent company, Dominion, is an established international company, providing DERApartments the ability to increase the profile of the .APARTMENTS gTLD. DERApartments will have the advantage of leveraging Dominion's existing network of businesses and commercial customers in the apartment space, as well as Dominion's more than 17 million monthly unique visitors to its more than 45 market-leading websites.

While some of ICANN's new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, .APARTMENTS from its launch will be a trusted source of apartments and related goods and services for consumers looking for information online about apartments. DERApartments looks to follow the established good business practices of its parent, Dominion, in working with law enforcement to create a marketplace with safeguards designed to minimize fraud and other illegal activity.

DERApartments believes that the long-term success of the .APARTMENTS 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 .APARTMENTS gTLD. Using this benchmark, DERApartments strives to build consumer recognition and trust that rises 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?

DERApartments believes that the .APARTMENTS gTLD will provide a single trusted ecosystem experience for the hundreds of thousands of Dominion's existing and future consumers who access content through its existing online, mobile, and social platforms. By providing the foundation of this trusted ecosystem, all domain name registrants in the .APARTMENTS gTLD will be able to share in the benefits of this collective resource. As an industry leader with a proven track record in expanding from traditional media (paid and free magazines) to newer media (market-leading websites), DERApartments believes that it can be a pioneer in bringing innovation in consumer choice to this new Internet medium, the .APARTMENTS gTLD.

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

DERApartments 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 Dominion's commitment and established track record in providing a safe ecosystem for consumers and vendors, DERApartments intends to provide best-in-class safeguards that will evolve over time.

At the time of completing this application, DERApartments has identified at least two registration policies that are currently intended to be adopted prior to launch of the .APARTMENTS gTLD. The first is a DMCA takedown policy regarding violations of copyrighted material found within the .APARTMENTS gTLD. Dominion currently has a compliance program in place to promptly respond to DMCA complaints received in connection with hosting and other value-added services provided to its network of apartment property managers and owners. While this current program can easily be migrated to the .APARTMENTS gTLD for its launch due to the fact that all registrants are existing Dominion clients, this policy will likely require amendments when domain name registration services are expanded beyond Dominion's existing clients.

The second policy will be an 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.

DERApartments recognizes this is an evolving area of law in which there is no international standard. Because the proposed business model set forth in Section 18.1.2 initially envisions .APARTMENTS domain names being registered to businesses, DERApartments has a vested interest to make sure that accurate and current domain name information is readily available in connection with each domain name. If individuals are eventually permitted to register vanity/personalized domain names in the .APARTMENTS gTLD, DERApartments will reevaluate its policies at that time to ensure that they are in compliance with the current best-in-class policies.

Dominion, as a leader in the online apartment industry and with operations in many marketplaces and on the Internet, respects the privacy of its partners, customers and other consumers. The company employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information on its websites. Dominion strives to ensure that all information not known to the general public is kept strictly confidential. Dominion and DERApartments will take similar precautions to protect registrant and user data associated with the .APARTMENTS gTLD. For more information, see http://www.dominionenterprises.com/main/do/Privacy_Policy.

In addition, DERApartments 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 successfully utilized by existing ICANN gTLD registry operators. Specifically, DERApartments shall notify any Registrar of the purposes for which Personal Data submitted to DERApartments by the 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. DERApartments shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration or destruction. DERApartments shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars. DERApartments 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.

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 start-ups created solely for the provision of domain name registration services, e.g., .INFO (Afilias), .BIZ (NeuStar), and .TRAVEL (Tralliance). DERApartments' parent company, Dominion, is an established international company with the ability to leverage its extensive network of apartment property managers and owners, customers, and websites to increase the profile of the .APARTMENTS gTLD. While most registries have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD, Dominion provides DERApartments the ability to leverage its existing network of more than 17 million unique visitors to its more than 45 market-leading websites.

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 backend suppliers (i.e., SRS/DNS services) are in place; and third, with many new .GENERIC gTLDs, well-understood registry operations will be fully supported by an established and financially sound business operating a .GENERIC gTLD in addition to and in conjunction with its primary business.

The .APARTMENTS 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 established online track record of Dominion.

DERApartments believes that the safeguards set forth in the Applicant Guidebook and additional RPMs identified in Section 18.2.4 are primary drivers to minimize potential negative social costs. DERApartments also believes that the initial launch of the .APARTMENTS gTLD through known business entities with existing contractual relationships with Dominion 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?

DERApartments believes that the proposed operation of the .APARTMENTS gTLD as set forth in this application has minimal 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. DERApartments believes that by following the core business values as established by its parent company, Dominion (see Section 18.2.1), it will be able to 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?

DERApartments does not envision multiple applicants for the same domain name, based upon the initial business model set forth in Section 18.1.2. However, if such an instance should arise, DERApartments believes that a phased equitable allocation approach, modeled after the ones 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).

Dominion currently offers its existing clients a suite of services that are often bundled together. During the initial rollout of the .APARTMENTS gTLD, it is very likely that these domain names will be bundled into Dominion's existing product/service offerings 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 by non-Dominion clients 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.

DERApartments 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 (18.1.2), DERApartments currently envisions initially offering domain name registration services mainly to Dominion apartment-related businesses and their existing clients. In these cases, having an existing contractual relationship with Dominion would be a condition for the ability to register a .APARTMENTS domain name.

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

When DERApartments moves forward with a validation process whereby third parties with no existing relationship with Dominion are permitted to register and use .APARTMENTS domain names, DERApartments is fully committed to offering these domain name registrants multi-year registrations that include pricing predictability and notice in connection with the terms of registration. Pricing for premium domain names will be determined before the domain names are offered for registration. 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 No.22

22 DERApartments, LLC has Properly Researched this Topic

DERApartments, LLC ("DERApartments") 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, DERApartments 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," Chapter 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; and

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

DERApartments 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 .APARTMENTS gTLD at which DERApartments will provide for registrations. Specifically, DERApartments 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

DERApartments' parent company, Dominion Enterprises, is a leading marketing services company serving the wide-ranging needs of many industries including real estate, apartments, specialty vehicles, (employment, automotive, and travel, with over 3,000 employees located in 145 offices in 35 states and 4 countries. Dominion Enterprises' more than 40 market-leading websites attract more than 17 million unique monthly visitors.

In providing these services, Dominion Enterprises makes regular use of geographical identifiers in providing consumers with a hierarchical and intuitive namespace to navigate for relevant content. For example, at its ForRent.com website, users are provided the ability to search for apartment spaces across all fifty states within the United States, see http://www.forrent.com/.

This fair and non-misleading use of geographical identifiers by ForRent.com occurs in the following hierarchical construct of URLs within the website, e.g. http://www.forrent.com/results.php?search_type=home_page&ssradius=-1&seed=1151101645&page_type_id=home&view_type=list&city_state=Virginia+Beach%2C+VA&zip=&min_price=%240&max_price=No+Limit&sbeds=99&sbaths=99&submit.x=108&submit.y=8.

Instead of restricting the usage of these geographical identifiers to the right of the TLD, DERApartments would like to provide a hierarchical and intuitive framework for the .APARTMENTS namespace by using geographical identifiers as second-level domain names. This use of geographical identifiers to the left of the TLD and as part of the domain name itself, upon information and belief, 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, DERApartments would like to see if this type of hierarchical and intuitive use of second-level domain names within a TLD provides increased consumer functionality.


22.3 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 in its 2001 report "Second WIPO Internet Domain Name Process, The Recognition of Rights and the Use of Names in the Internet Domain Name System." 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 Report," paragraphs 206 and 210. Neither of these elements is present in Dominion Enterprises' current use or DERApartments' proposed use of geographical identifiers.

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," see 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 domain name system.

DERApartments' parent, Dominion Enterprises, acting as a responsible international business, seeks to minimize any potential business practices that might mislead consumers. At the same time, however, Dominion Enterprises and DERApartments believe that it is important to be able to use geographical identifiers in fair and a non-misleading manner, if such use can benefit Internet users as proposed in DERApartments' business model.

22.4 Fair & Non-Misleading Use of Geographical Identifiers

In undertaking thorough research of this subject matter prior to filing this application, DERApartments' 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 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 (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 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 healthy 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

Although DERApartments 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 .APARTMENTS namespace, DERApartments is committed to operating the .APARTMENTS 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

Given that DERApartments' parent, Dominion Enterprises, is an international organization currently operating in at least four countries, DERApartments looks forward to collaborating with other new gTLD registry operators (especially .BRANDs) in potentially working with ICANN's GAC to explore potential processes that could permit the release of initially reserved country names (including ISO-3166 two characters). Specifically, DERApartments 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.