.XFINITY New gTLD Application
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New gTLD Application Submitted to ICANN by: Comcast IP Holdings I, LLC
String: XFINITY
Originally Posted: 13 June 2012
Application ID: 1-1170-40267
Applicant Information
- Full legal name
Comcast IP Holdings I, LLC
- Address of the principal place of business
c⁄o Comcast Capital Corporation
1201 North Market Street, Suite 100
Wilmington De 19801
US
- Phone number
+1 302 594 8710
- Fax number
+1 302 658 1600
- If applicable, website or URL
Primary Contact
6(a). Name
Jason Dean Livingood
6(b). Title
Vice President, Internet & Communications Engineering
6(c). Address
6(d). Phone Number
+1 215 286 7813
6(e). Fax Number
6(f). Email Address
Secondary Contact
7(a). Name
Chae H Chung
7(b). Title
Senior Manager, Internet & Communications Engineering
7(c). Address
7(d). Phone Number
+1215 286 2691
7(e). Fax Number
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Limited Liability Company
8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).
National: United States
State: Delaware
8(c). Attach evidence of the applicant's establishment.
Attachments are not displayed on this form.
9(a). If applying company is publicly traded, provide the exchange and symbol.
9(b). If the applying entity is a subsidiary, provide the parent company.
Comcast Corporation
9(c). If the applying entity is a joint venture, list all joint venture partners.
Applicant Background
11(a). Name(s) and position(s) of all directors
11(b). Name(s) and position(s) of all officers and partners
Cheryl Diane Bertuccini Vice President, Assitant Secretary
Kristin Maney Kipp Vice President, Assistant Secretary
Rosemarie Stacey Teta President
Sandra Webster Crowell Vice President, Assistant Treasurer
11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares
Comcast Corporation Not Applicable
11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility
Applied-for gTLD string
- Provide the applied-for gTLD string. If an IDN, provide the U-label.
XFINITY
14(a). If an IDN, provide the A-label (beginning with "xn--").
14(b). If an IDN, provide the meaning or restatement of the string in English, that is, a description of the literal meaning of the string in the opinion of the applicant.
14(c). If an IDN, provide the language of the label (in English).
14(c). If an IDN, provide the language of the label (as referenced by ISO-639-1).
14(d). If an IDN, provide the script of the label (in English).
14(d). If an IDN, provide the script of the label (as referenced by ISO 15924).
14(e). If an IDN, list all code points contained in the U-label according to Unicode form.
15(a). If an IDN, Attach IDN Tables for the proposed registry.
Attachments are not displayed on this form.
15(b). Describe the process used for development of the IDN tables submitted, including consultations and sources used.
15(c). List any variant strings to the applied-for gTLD string according to the relevant IDN tables.
- Describe the applicant's efforts to ensure that there are no known operational or rendering problems concerning the applied-for gTLD string. If such issues are known, describe steps that will be taken to mitigate these issues in software and other applications.
The applied for gTLD string will not cause any operational or rendering problems. The applied for string is in ASCII and uses alphabetic characters only. The string, and its use in application will not be syntactically different than any existing Top Level Domains. The intended-use applications are alphabetical-string agnostic and is not a reserved top level domain string (from RFC2606).
- (OPTIONAL) Provide a representation of the label according to the International Phonetic Alphabet (http://www.langsci.ucl.ac.uk/ipa/).
Mission/Purpose
18(a). Describe the mission/purpose of your proposed gTLD.
18.1 Mission and Purpose of .XFINITY
18.1.1 Comcast Corporation
Comcast Corporation (“Comcast”) is a leading provider of video, high-speed Internet, and phone services to residential and business customers in the United States. As of December 31, 2010, Comcast cable systems served approximately 22.8 million video customers, 17.0 million high-speed Internet customers and 8.6 million phone customers and passed over 51 million homes and businesses in 39 states and the District of Columbia.
18.1.2 XFINITY
In 2010, Comcast launched XFINITY TV, its authenticated, On Demand online service. XFINITY TV offers online access to 150,000 entertainment choices, including movies, TV shows, premium and HD content, and a compelling search and discovery platform. All of Comcast’s digital video customers have access to XFINITY TV for no extra cost, making it a tremendous value-added service.
Comcast also launched the XFINITY TV app on iPads, iPhones and Android-based devices. The app now combines the functionality of a remote, a TV guide and a mobile video player, with a Play Now streaming feature that today gives customers access to nearly 4,500 hours of movies and TV shows. The iPad app alone has been downloaded more than 1.3 million times since it launched in mid-November 2010. Comcast is in the process of expanding its capabilities to include live TV programming and other features.
18.1.3 Mission and Purpose
Through a unified corporate approach, Comcast intends to submit two gTLD applications for the strings .COMCAST and .XFINITY. Comcast IP Holdings I, LLC, (“Comcast IP”) a wholly owned subsidiary of Comcast, will be the entity to file this application and bring the .XFINITY gTLD to market.
The intended mission and purpose of the .XFINITY gTLD is to serve as a trusted and intuitive namespace for the benefit of Comcast and its qualified subsidiaries’ and affiliates’ customers and other Internet users, that will deepen and broaden these entities’ relationships with those audiences.
Although ICANN has not specifically recognized a .BRAND gTLD specification in the current gTLD application round, it is widely anticipated in the brand-owner community that this will become a specialty subset of the gTLDs. The .XFINITY gTLD is intended to be one of those .BRAND gTLDs, with the goal of protecting Comcast’s online presence and identity, expanding its marketing and promotion efforts, providing a secure channel for online products and services, and offering a platform through which to consolidate many of the intellectual property activities of Comcast.
Comcast IP intends to initially limit registration and use of domain names within the .XFINITY gTLD to Comcast and its qualified subsidiaries and affiliates. This initial limited use will allow Comcast IP to establish .XFINITYʹs operations and achieve full sustainability. This limited distribution coupled with the other requirements set forth in Specification 9 of the template Registry Agreement is intended to exempt Comcast IP from its annual Code of Conduct Compliance requirements.
After the initial stages of operation, Comcast IP will evaluate whether opportunities exist to carry out the business strategy for the gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to parties other than Comcast and its qualified subsidiaries and affiliates.
Comcast IP currently plans a four-stage rollout for the .XFINITY gTLD:
Stage 1
The initial stage of implementation of the gTLD will involve Comcast registering a limited number of .XFINITY second-level domain names. This initial use will provide Comcast’s DNS Engineering personnel the time to run a number of tests to ensure seamless and secure access using the .XFINITY gTLD domain names, interoperability with various software and Web-based applications, and unbroken and secure use of all names. This initial allocation will also allow the appropriate Comcast staff to coordinate with the internal and external staff responsible for the application, delegation, and setup phases of the .XFINITY gTLD to ensure a proper transition from delegation to full operation.
Stage 2
Once all testing has been successfully completed, Comcast IP will begin allocating domain names in the .XFINITY gTLD for more widespread corporate use. During this same time period, Comcast will begin evaluating strategies to potentially migrate traffic away from its current patchwork network of second-level domain names, which are registered in a variety of TLDs, to Comcast IP’s new gTLDs, .COMCAST and .XFINITY.
It is in Stage 2 that Comcast will evaluate expanding the operations of the .XFINITY gTLD to permit registration by other registrants, such as select licensees or strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other parties, this expansion is currently planned to take place in Stage 3. However, any expansion would be conditioned upon a review of Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Comcast IP’s business model.
Stage 3
Depending on the analysis of the evaluations undertaken in Stage 2, Comcast may implement the permanent migration of Internet traffic away from the TLDs in which Comcast’s domain names are currently registered, and toward the new Comcast IP gTLDs, .COMCAST and .XFINITY. It is in this stage that Comcast IP also may implement Comcast’s decision to extend registration rights to licensees or strategic parties, depending upon compliance with Specification 9, as noted above. The dates of such expansion are subject to change depending upon business, strategic, and industry factors at the time.
After consideration of the following factors: analysis of Comcast’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Comcast will have full control over the number of registrations in the .XFINITY gTLD namespace, Comcast IP is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.
Stage 4
Based on their experiences with any expansion implemented in Stage 3, Comcast IP and Comcast will assess whether their business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, including potential customers of Comcast. It is anticipated by Comcast that changes to the domain name industry, and particularly the impact of .BRAND gTLDs, will take at least five years to be realized and assessed. Any decision to expand the gTLDs beyond corporate, qualified subsidiary⁄affiliate, and licensee⁄partner use will take into account this experience as well as the technical analysis of potential expansion.
Notwithstanding this potential future expanded use of the .XFINITY name space beginning in the sixth year of operation, Comcast IP 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 Questions 45-50 of this application.
Comcast intends to use the .XFINITY gTLD in ways that are consistent with the business strategies of these or its other business segments as identified in its annual report and investor filings, see http:⁄⁄www.cmcsa.com⁄.
18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
Given that many consumers search for Comcast and its subsidiaries’ content online, Comcast believes that the proposed .XFINITY gTLD has the potential to offer the following benefits to Internet users and consumers:
-Provide a trusted online marketplace for the millions of consumers that use Comcast’s services;
-Provide Comcast and its qualified subsidiaries and affiliates with the use of short and memorable Internet addresses in order to facilitate increased ease for navigation to Comcast online content and other services;
-Minimize the need for defensive registrations because domain names within the .XFINITY gTLD will only be registered by Comcast IP to verified Comcast administrators and qualified subsidiaries and affiliates of Comcast, at least for the first three years of operation;
-Serve as a secure platform for the distribution of copyrighted material to consumers; and
-Incorporate enhanced intellectual property rights (IPR) protection mechanisms.
Also, through the adoption of new gTLDs by the wider Internet user community, consumers may benefit from lower incidents of fraud, misdirection, infringement, phishing, malware, or other scams often associated with mistypes of domain names in the .COM space that are owned by cybersquatters, since they will be navigating to domain names in the .XFINITY gTLD.
Comcast currently offers International programming to its video customers, including channels in the following languages and⁄or from the following regions:
Arabic
Chinese
Filipino
French
German
Greek
Israeli
Italian
Japanese
Korean
Polish
Portuguese
Russian
South Asia
Vietnamese
The above representative list of examples demonstrates the geographic nature of a particular Comcast service offering. Given these services, Comcast believes that a .XFINITY gTLD can provide an online single source-identifying location for its current and future customers.
Comcast IP would like to provide a hierarchical and intuitive framework for the .XFINITY namespace by using geographical identifiers as second-level domain names. This use of geographical identifiers to the left of the gTLD and as part of the domain name itself is believed to have a direct and material impact on search engine algorithms and their corresponding query results. Comcast would like to see if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality and innovation, as premised by ICANN.
18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
Comcast has filed this application for a .XFINITY gTLD in order to provide a secure and trusted virtual platform to aggregate Comcast’s already well-known and prestigious content and other goods and services. As technologies for delivering content and services evolve, Comcast will pursue opportunities to distribute its content and services to consumers in the U.S. on various platforms, including the Internet, mobile devices, and video-on-demand. As noted above, Comcast intends to use the .XFINITY gTLD as an intuitive means to offer its content and to deepen and broaden its relationship with audiences and viewers.
Most importantly, the Comcast content and services will be provided in an online namespace devoid of fraud, misdirection, infringement, phishing, malware, and other scams. While Comcast fights to protect its valuable intellectual property from piracy on the Internet, it would use the .XFINITY gTLD to offer to consumers a safe and intuitive means of accessing authorized content from Comcast and its qualified subsidiaries and affiliates.
With regard to service level and reputation, Comcast will operate the .XFINITY gTLD in accordance with the Comcast Corporation Code of Conduct, see: http:⁄⁄www.cmcsk.com⁄govdocs.cfm?DocumentID=9918.
18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
As a .BRAND gTLD, the primary factors driving Comcast to seek the .XFINITY gTLD are differentiation and innovation. Comcast is one of the world’s leading media, entertainment and communications companies, and it uses existing technology and leverages emerging technologies to deliver content and services to its millions of consumers. A .XFINITY gTLD has the potential to serve as a cornerstone of this online strategy.
While some of ICANN’s new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, .XFINITY from its launch will be a trusted online source of Comcast information, goods, and services. Comcast will follow its own established good business practices in working with law enforcement to create a marketplace with safeguards designed to minimize fraud and other illegal activity.
Comcast IP believes that the success of the gTLD will not be measured by the number of domain names registered, but rather by the level of consumer recognition and trust that is placed in the .XFINITY gTLD. Using this benchmark, Comcast IP 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?
In addition to providing a trusted ecosystem experience for its millions of customers who use its content, goods, and services, Comcast IP will minimize potential fraud, misdirection, infringement, phishing, malware, and other scams because domains will initially only be registered to Comcast and its qualified subsidiaries and affiliates. As a leading media, communications, and entertainment company, Comcast believes that it can be a pioneer in bringing innovation in consumer choice to this new Internet medium.
18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
Comcast 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 Comcast’s commitment and established track record in providing a safe ecosystem for consumers and vendors, Comcast intends to provide best-in-class safeguards that will evolve over time.
Because the domains within the .XFINITY gTLD are currently intended to be initially registered exclusively to Comcast and its qualified subsidiaries and affiliates, any registration and use requirements are more appropriately vested in the corporate-subsidiary and corporate-affiliate agreements, or corporate policies and practices, and not in a domain name registration agreement.
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.
As a leading media and communications company, with extensive online operations, Comcast has a vested interest in making sure that accurate and current domain name information is readily available in connection with each .XFINITY domain name. For the .XFINITY gTLD, all private and confidential information will be protected.
Comcast IP will ensure that the operation of the .XFINITY gTLD will be consistent with Comcast’s Web Services Terms of Service and Privacy Policy, available on here: http:⁄⁄customer.XFINITY.com⁄help-and-support⁄internet⁄comcast-web-services-terms-of-service-and-privacy-policy.
In addition, Comcast IP intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully 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.
Comcast sees the potential for the .XFINITY gTLD to play a meaningful role in the company’s future online strategy. While the extent of likely benefits is currently uncertain due to questions of consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace, all of which will influence the communication and usage strategies for the gTLD, Comcast IP anticipates a phased-in approach to using and promoting the .XFINITY gTLD.
At first, Comcast IP plans to start using .XFINITY domains initially as redirects to existing .COM domains and other domains that Comcast currently operates. Subsequently, Comcast IP expects to initiate a targeted rollout using select gTLD domains as primary addresses and, after a careful review and analysis of this rollout and of the release of new gTLDs by others, the response from search engines to .BRAND gTLDs, and the perception of consumer, Comcast IP and Comcast may engage in a broader initiative, should the results be satisfactory and in accordance with the company’s overall strategic goals. As the marketplace evolves, the actual usage of the gTLD will dictate what outreach and communication is needed to ensure that consumers continue to interact with Comcast content in this new namespace.
18(c). What operating rules will you adopt to eliminate or minimize social costs?
18.3 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)?
Comcast IPʹs proposed operating rules to limit registration to Comcast and its qualified subsidiaries and affiliates will provide a trusted online environment for consumers of Comcast’s content, goods, and services. Therefore, Comcast IP will minimize social costs by eliminating the need for third-party brand owners to defensively register their trademark in the .XFINITY gTLD, unlike other open registries. In addition, the .XFINITY gTLD will provide consumers with a trusted source for Comcast’s content, goods, and services without the risk of fraud, misdirection, infringement, phishing, malware, or malicious content.
18.3.1 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
Comcast IP believes that the proposed operation of the .XFINITY gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to consumer benefits.
18.3.2 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first serve basis?
Comcast IP does not envision multiple applicants for the same domain name, as domain names will initially only be registered to Comcast and its qualified subsidiaries and affiliates.
18.3.3 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
Comcast IP does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because it will not be marketing or creating commercial initiatives for the sale of .XFINITY domain names. Its intention is to use the gTLD as a recognizable, trusted, virtual platform offering Comcastʹs and its qualified subsidiariesʹ and affiliates’ content, goods, and services to customers and Internet users. Any potential registrant fees imposed upon licensees and strategic partners will be made in the future if this class of registrants are permitted to register domain names in the .XFINITY gTLD.
18.3.4 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.
Comcast IP is committed to providing the domain name registration periods set forth in the Registry Agreement. As a .BRAND gTLD, the use of any .XFINITY domain names is conditioned upon a subsidiary or affiliate relationship with Comcast. Therefore, there is a natural incentive for Comcast IP to provide domain names with minimal price escalations and the maximum flexibility in domain registration terms possible under ICANN rules. Understanding the ownership of .XFINITY domains as noted previously, contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations is not relevant or appropriate. That said, the .XFINITY domain agreements will be in accordance with all ICANN requirements.
Comcast IP 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.” However, Comcast and its qualified subsidiaries and affiliates, as the sole registrants within the .XFINITY gTLD, will initially only be registering domain names on an annual basis.
It is possible that at some future date, Comcast IP may wish to explore expanding the potential universe of registrants beyond the initially proposed closed network of itself and qualified subsidiaries and affiliates. If Comcast IP were to expand this potential universe of registrants it would ensure that these domain name registrants were provided adequate notice regarding any pricing terms and conditions of use, including the fact that the use of the domain name may be conditioned upon another legal obligation that the registrant has with Comcast IP.