.XEROX New gTLD Application

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New gTLD Application Submitted to ICANN by: Xerox DNHC LLC

String: XEROX

Originally Posted: 13 June 2012

Application ID: 1-1046-44533

 

Applicant Information

 

  1. Full legal name

Xerox DNHC LLC

 

  1. Address of the principal place of business

Xerox Corporation

45 Glover Avenue

Norwalk CT 06856-4505

US

 

  1. Phone number

+ 1 203 968 3000

 

  1. Fax number

+1 203 849 2442

 

  1. If applicable, website or URL

http:⁄⁄www.xerox.com⁄

 

Primary Contact

 

6(a). Name

Joshua Slocum Bourne

 

6(b). Title

FairWinds Partners LLC, Managing Partner

 

6(c). Address

 

6(d). Phone Number

+1 202 223 9081

 

6(e). Fax Number

 

6(f). Email Address

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Secondary Contact

 

7(a). Name

Douglas H.  Marshall

 

7(b). Title

Director

 

7(c). Address

 

7(d). Phone Number

+ 1  203-849-2339

 

7(e). Fax Number

+1  585-216-2475

 

7(f). Email Address

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Proof of Legal Establishment

 

8(a). Legal form of the Applicant

Limited Liability Corporation

 

8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).

Delaware, United States

 

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.

Xerox 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

Christa Carone Director

 

11(b). Name(s) and position(s) of all officers and partners

 

11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares

 

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

 

  1. Provide the applied-for gTLD string. If an IDN, provide the U-label.

XEROX

 

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.

 

  1. 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.

Xerox DNHC LLC (“Xerox DNHC”) foresees no known rendering issues in connection with the proposed .XEROX gTLD for which it is applying. This answer is based upon consultation with Xerox DNHC’s selected back-end provider, VeriSign, Inc., which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, the following data points were analyzed:

 

-ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and Consequences (SAC009);

-IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”

-Known software issues which Verisign has encountered during the last decade launching new gTLDs;

-Character type and length;

-ICANN supplemental notes to Question 16; and

-ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance.

 

  1. (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 .XEROX

 

Xerox DNHC LLC (Xerox DNHC), a wholly owned subsidiary of Xerox Corporation (Xerox), has filed this application for a .XEROX gTLD to serve as a trusted, hierarchical, and intuitive namespace for the goods and services that Xerox provides to its customers on a global basis. As a registry operator, Xerox DNHC will be entrusted to provide domain name registration services to Xerox, its subsidiaries, affiliates, licensees, strategic partners, and⁄or any other designated third party. Through a unified corporate approach, Xerox DNHC also intends to submit an application for a .FUJIXEROX gTLD.

 

Xerox is primarily pursuing this application in ICANN’s first round for defensive reasons given the uncertainty regarding when ICANN will be opening a second round. Therefore, although Xerox DNHC is committed to moving forward with a .XEROX gTLD application, at the time of filing this application there has not been enough time or market information available to fully analyze and evaluate all potential use case options.

 

18.1.1 XEROX CORPORATION

 

Xerox is the world’s leading enterprise for business process and document management with over $22 billion in annual sales. With over 140,000 employees worldwide and operations in 160 countries, Xerox’s client base includes schools, small businesses, government agencies, healthcare providers, commercial printers, and Fortune 1000 companies. In addition to its own global sales force, Xerox relies upon an extended global network of 6,500 authorized sales agents and concessionaires, and approximately 10,000 technology resellers.

 

18.1.2 POTENTIAL BUSINESS PLAN

 

The potential use of the .XEROX gTLD will primarily be driven by Xerox’s future business strategies as identified in its annual report and investor filings, see http:⁄⁄news.xerox.com⁄pr⁄xerox⁄annual-reports.aspx. In addition, Xerox will be relying upon the valuable experience it has gained through the operation of the Xerox.com domain name since as early as 1986, predating the advent of HTML and the World Wide Web.

 

Today the Xerox.com website serves as both a source of news and information and a digital storefront. Through this website, customers can purchase the full range of Xerox products, including new printers, scanners, publishing equipment, software, paper, and ink. Customers are also able to buy refurbished products online.

 

Xerox DNHC currently plans a four-stage rollout for Xerox DNHC’s gTLDs:

 

  1. Stage One

 

The initial stage of implementation of the gTLD will involve Xerox Corporation registering a limited number of .XEROX second-level domain names.

 

This initial use will provide Xerox Corporation’s IT and security personnel the time to run a number of tests to ensure seamless and secure access using .XEROX 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 Xerox DNHC staff to coordinate with the internal and external staff responsible for the delegation and setup phases of the .XEROX gTLD to ensure a proper transition from delegation to full operation.

 

  1. Stage Two

 

Once all testing has been successfully completed, Xerox DNHC will begin allocating domain names in .XEROX to Xerox Corporation for more widespread internal corporate use. During this same period of time, Xerox Corporation 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 Xerox DNHC’s new Family of gTLDs.

 

It is in Stage Two that Xerox Corporation will evaluate expanding the operations of the gTLD to permit registration by other registrants such as 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 during Stage Three. However, any expansion would be conditioned upon a review of the Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Xerox DNHC’s business model.

 

  1. Stage Three

 

Depending upon the analysis of the evaluations undertaken in Stage Two, Xerox DNHC may begin to implement the permanent migration of Internet traffic away from the TLDs in which Xerox Corporation’s domain names are currently registered, and toward Xerox DNHC’s new family of branded gTLDs. It is in this stage that Xerox DNHC also may implement Xerox Corporation’s decision to extend registration rights to licensees or strategic partners, 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 Xerox Corporation’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Xerox Corporation will have full control over the number of registrations in the .XEROX gTLD namespace, Xerox DNHC is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.

 

  1. Stage Four

 

Based on their experience with any expansion implemented in Stage Three, Xerox DNHC and Xerox Corporation will assess whether the business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, and potentially customers of Xerox Corporation. It is anticipated by Xerox Corporation 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.

 

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?

 

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

 

-Establish a trusted source of information and online marketplace for the millions of consumers that purchase goods and services through Xerox online and  dealers, for investors and third parties seeking information, and for the general Internet user population;

-Provide Xerox with short and memorable Internet addresses that enable increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;

-Eliminate the cost of and need for defensive registrations by other brands because domain names will only be allocated by Xerox DNHC to Xerox and verified subsidiaries, affiliates, licensees, and strategic partners;

-Develop a potential platform for the secure access to, purchase of, and distribution of Xerox products and information to consumers in order to minimize the potential for counterfeit or infringing goods and services; and

-Increase consumer awareness to potentially minimize incidents of phishing and malware often associated with domain names that incorporate the XEROX mark or variations of said mark (typos) that are registered by cybersquatters and⁄or criminal elements.

 

Additionally, Xerox currently maintains 213 websites for 192 markets. The difference between the number of websites and markets is attributed to the fact that Xerox maintains multi-lingual websites for some markets, i.e., Canada (English⁄French), Luxemburg (German⁄English⁄French), Lebanon (English⁄French), Guinea-Bissau (French⁄Portuguese), etc. These 213 websites use a very structured naming convention in connection with each URL.

 

This naming convention is as follows: http:⁄⁄www.xerox.com⁄index⁄LLCC.html, where the two-character “LL” designation corresponds to the language of the website site, English (EN), Spanish (ES), French (FR), etc., and the two-character “CC” designation corresponds to the ISO-3166 country code, United States (US), France (FR), Argentina (AR), etc. As identified in the response to Question 22, Xerox DNHC believes that the potential use of geographic identifiers at the second level would be an innovative convention and highly beneficial for a global company such as Xerox.

 

Xerox DNHC does not initially anticipate offering registration of second-level domain names to its extended global network of 6,500 authorized sales agents and concessionaires, and 10,000 technology resellers. However, this expanded use of second-level domain names within the .XEROX namespace does potentially offer Xerox an enhanced trademark policing mechanism. Currently, Xerox is engaged in a continuous battle to ensure that this extended network of sales agents and resellers does not register domain names incorporating the XEROX mark. Providing this extended network of agents and resellers with registration and use of second-level domain names within the .XEROX gTLD is potentially a win-win situation for all involved parties. These agents and resellers are better able to market their strategic relationships with Xerox, and Xerox has the ability to revoke domain name rights in light of potential non-compliance.

 

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 .XEROX gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to deliver Xerox retail content, information on Xerox’s business and focus, and other goods and services. As Xerox continues to expand, it is the company’s desire to pursue and develop opportunities to market and distribute its online content and products to consumers in the U.S. and internationally, and on various platforms, including the Internet and mobile devices, among others. Given that customers increasingly demand access to Xerox products and services through a variety of channels, which include domain names and the address bar, Xerox believes that a .XEROX gTLD has the potential to provide an innovative, virtual avenue to Xerox products that will deepen and broaden its relationship with consumers.

 

Most importantly, Xerox will be able to provide access to its products and online content in a namespace void of piracy, cybersquatting, and other malicious activities. Providing consumers with a trusted experience is paramount to Xerox, and a .XEROX gTLD will be used to further that goal.

 

While global companies such as Xerox fight a never-ending battle to protect valuable intellectual property from piracy on the Internet, a .XEROX gTLD potentially offers legitimate consumers a safe and intuitive means of accessing authorized content from Xerox and its partners.

 

Xerox is supportive of existing anti-cybersquatting legislation and consumer protection measures, including the U.S. Anti-Cybersquatting Consumer Protection Act (ACPA) and others. As Xerox invests in expanding the domain name space through the establishment of a .XEROX gTLD, it will also actively prevent cybersquatting, fraud, phishing, and other malicious activities within the .XEROX gTLD. Maintaining the highest standards within the .XEROX gTLD will give Xerox the opportunity to take a proactive approach to protecting intellectual property rights and fostering a cleaner, safer online experience for all Internet users.

 

Xerox DNHC will seek to operate the .XEROX gTLD in connection with the following core values by which Xerox has operated since its inception:

 

-“Succeed through satisfied customers.

-Deliver quality and excellence in all we do.

-Require premium return on assets.

-Use technology to develop market leadership.

-Value our employees.

-Behave responsibly as a corporate citizen.”

 

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 branded gTLD, the primary driving factors of a .XEROX gTLD are differentiation and innovation. The number of domain names registered will not measure the success of the gTLD, but rather success will be judged by the level of consumer recognition and trust that is placed in the .XEROX gTLD. Using this benchmark, Xerox strives to build consumer recognition and trust in the usage of the .XEROX gTLD that rises to the level of that found in the .EDU and .GOV gTLDs.

 

As noted above, Xerox is a leading global company that leverages numerous distribution channels and emerging technologies to deliver its online content, products, and services to its customers internationally. A .XEROX gTLD has the potential to serve as a cornerstone of this online strategy, if potential benefits that ICANN has projected become a reality.

 

18.2.3 WHAT GOALS DOES YOUR PROPOSED GTLD HAVE IN TERMS OF USER EXPERIENCE?

 

Xerox believes that the .XEROX gTLD will provide a single, trusted ecosystem experience for the millions of consumers worldwide that purchase the company’s goods and services, as well as those who seek information that Xerox provides, such as investors and members of the press. In addition to providing consumers with short, memorable, and intuitive domain names, consumers will know all domains and content are owned and controlled by Xerox, thus protecting users from potential infringing, pirated, or harmful content within the .XEROX gTLD.

 

The initial use of the .XEROX gTLD will be primarily defensive in nature, with Xerox DNHC registering a limited number of second-level domain names. This initial use will provide Xerox’s IT and security personnel the ability to run a number of tests to ensure seamless and secure access to the Xerox website and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Xerox DNHC will likely begin allocating domain names for internal corporate use and may redirect new .XEROX domain names to pre-existing content. This phased rollout will likely take place over a multi-year period, but is subject to change depending upon a range of external factors.

 

During this same period of time, Xerox will evaluate potential strategies to migrate all traffic away from the current network of second-level domains registered in various gTLDs to the .XEROX gTLD. This will provide customers with a single, trusted online source for its products and services.

 

18.2.4 PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANT’S INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.

 

Xerox DNHC currently intends for the .XEROX gTLD to be exclusively used by Xerox, its subsidiaries, affiliates, licensees, and strategic partners. Because of this controlled use, any registration and use requirements are more appropriately vested in corporate⁄affiliate agreements and not in a domain name registration agreement.

 

While Xerox DNHC is fully supportive of and committed to ICANN’s bottom-up, consensus-driven model, Xerox DNHC is mindful that some registries have had amendments to their registrar⁄registrant agreements delayed because of internal ICANN processes. Because the Xerox trademark is a valuable brand of which protection is of paramount importance, any registration and use requirements (e.g., trademark quality control provisions) must vest in these other agreements.

 

Notwithstanding these concerns, Xerox DNHC will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each partner will execute.

 

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 global company, Xerox recognizes firsthand that privacy protection is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will be initially registered to Xerox or a qualified subsidiary or affiliate, Xerox has a vested interest to ensure that accurate and current domain name information is readily available in connection with each .XEROX domain name. Xerox’s current privacy policy is available online at http:⁄⁄www.xerox.com⁄about-xerox⁄privacy-policy⁄enus.html. It is anticipated that Xerox DNHC will seek to operate the Xerox family of gTLDs in a manner that is consistent with this policy, provided that it is not in conflict with any ICANN consensus policy.

 

In addition, Xerox intends to include contractual provisions to protect confidential and personal data in its registrar agreement, including provisions modeled after language in the template Registry Agreement 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.

 

While Xerox sees the potential for this gTLD to play a large role in Xerox’s future online strategic initiatives, there are a number of unanswered questions concerning consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace that will influence the usage of the gTLD and communication about that usage.

 

Notwithstanding these concerns, Xerox’s current best thinking involves an implementation of .XEROX domain names in a multi-stage approach set forth in Section 18.1.2 above. The actual usage of .XEROX domain names will dictate what public communications and consumer outreach initiatives are undertaken to encourage navigation to .XEROX gTLDs. This is not limited to, but may include advertising, media outreach, email campaigns, etc.

 

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)?

 

Xerox DNHC’s proposed operating rules to initially limit registration to Xerox and its qualified subsidiaries and affiliates will provide a trusted online environment for consumers to access Xerox’s online content and, by default, will minimize social costs. This verified ecosystem provides consumers with a single, trusted source for Xerox goods and services with a substantially lower risk of fraud and⁄or scams.

 

Xerox DNHC does not anticipate consumer vulnerabilities. In addition, there is no need for other trademark and brand owners to defensively register second-level domains in the gTLD. In fact, Xerox DNHC’s expectation is that the usage of a .XEROX gTLD will eliminate many of the vulnerabilities that Xerox customers and consumers face on the wider Internet today.

 

18.3.1 WHAT OTHER STEPS WILL YOU TAKE TO MINIMIZE NEGATIVE CONSEQUENCES⁄COSTS IMPOSED UPON CONSUMERS?

 

Xerox believes that the proposed operation of the .XEROX gTLD as set forth in this application has no 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 by providing a unified framework for the access to and distribution of Xerox goods and services.

 

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?

 

Xerox DNHC does not envision multiple applicants for the same domain name, as domain names will initially only be allocated to Xerox and its qualified subsidiaries and affiliates; licensees; and strategic partners.

 

18.3.3 EXPLAIN ANY COST BENEFITS FOR REGISTRANTS YOU INTEND TO IMPLEMENT (E.G., ADVANTAGEOUS PRICING, INTRODUCTORY DISCOUNTS, BULK REGISTRATION DISCOUNTS).

 

Xerox DNHC does not currently envision any pricing, introductory discounts or bulk registration discounts because these marketing⁄commercial initiatives appear to be inconsistent with the mission and purpose of the .XEROX gTLD as a trusted online source identifier. Moreover, Xerox DNHC plans to provide domain name registrations to Xerox and its qualified subsidiaries and affiliates, at no cost, though Xerox DHNC reserves the right to reevaluate this decision and may alter it in the future.

 

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.

 

Xerox DNHC is committed to providing the domain name registration periods set forth in the registry agreement. However, as noted above, because this will be a branded gTLD, the registration and use of the domain name is conditioned upon a separate contractual relationship with Xerox. Therefore, providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate.