.NORTON New gTLD Application

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New gTLD Application Submitted to ICANN by: Symantec Corporation

Application Downloaded On: 15 Nov 2014

String: NORTON

Application ID: 1-1027-83460

Applicant Information

1. Full legal name

Symantec Corporation

2. Address of the principal place of business

350 Ellis Street Mountain View, California - 94043 US

3. Phone number

+1 650 527 8000

4. Fax number

+1 916 632 1425

5. If applicable, website or URL

Primary Contact

6(a). Name

Philip Lodico

6(b). Title

Managing Partner

6(c). Address

6(d). Phone Number

+1 202 223 9252

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

Rick Graves

7(b). Title

Director - Corporate Marketing

7(c). Address

7(d). Phone Number

+1 916 632 1425

7(e). Fax Number

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

Corporation

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

United States – Incorporated in the State of Delaware, Headquartered in California

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.

NASDAQ / SYMC

9(b). If the applying entity is a subsidiary, provide the parent company.

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

Name

Position

Anita M. Sands Director

Daniel H. Schulman Director

David L. Mahoney Director

Frank E. Dangeard Director

Geraldine B. Laybourne Director

Michael A. Brown President and Chief Executive Officer

Paul V. Unruh Director

Robert S. Miller Director

Suzanne M. Vantrinot Director

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

Name

Position

Amit Mital EVP/GM, Emerging Endpoints and CTO

Amy L. Cappellanti-Wolf SVP and Chief Human Resources Officer

Francis C. Rosch EVP, Norton Business Unit

John B. Gannon EVP and GM, Information Management

Mark S. Garfield SVP and Chief Accounting Officer

Michael A. Brown President and Chief Executive Officer

Scott C. Taylor EVP, General Counsel and Secretary

Stephen E. Gillett EVP and Chief Operating Officer

Thomas J. Seifert EVP and Chief Financial Officer

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

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

NORTON

14A. If applying for an IDN, provide the A-label (beginning with "xn--").

14B. 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.

14C1. If an IDN, provide the language of the label (in English).

14C2. If an IDN, provide the language of the label (as referenced by ISO-639-1).

14D1. If an IDN, provide the script of the label (in English).

14D2. If an IDN, provide the script of the label (as referenced by ISO 15924).

14E. If an IDN, list all code points contained in the U-label according to Unicode form.

15A. If an IDN, upload IDN tables for the proposed registry.  An IDN table must include:

the applied-for gTLD string relevant to the tables,

the script or language designator (as defined in BCP 47),

table version number,

effective date (DD Month YYYY), and

contact name, email address, and phone number.

Submission of IDN tables in a standards-based format is encouraged.

15B. Describe the process used for development of the IDN tables submitted, including consultations and sources used.

15C. List any variants to the applied-for gTLD string according to the relevant IDN tables.

16. 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.

Symantec Corporation (“Symantec”) foresees no known rendering issues in connection with the proposed .NORTON gTLD for which it is applying. This answer is based upon consultation with Symantec’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.

17. OPTIONAL.

Provide a representation of the label according to the International Phonetic Alphabet (http://www.langsci.ucl.ac.uk/ipa/).

18A. Describe the mission/purpose of your proposed gTLD.

18.1 Mission and Purpose of .NORTON

Symantec Corporation (“Symantec”) is a leading global provider of information security and protection, serving the needs of consumers around the world, with more than 18,500 employees and operations in numerous countries. Symantec’s products are available for purchase online to consumers and Symantec’s online content is accessible in the .COM gTLD and in multiple ccTLDs, including .CA, .DE, .EU, and .RU. Symantec is applying for two branded gTLDs: .SYMANTEC and .NORTON.

The intended future mission and purpose of the .NORTON gTLD is to serve as a trusted, hierarchical, secure, and intuitive namespace provided by Symantec for its consumers. Symantec is committed to moving forward with a .NORTON gTLD application; however at the time of filing this application, there has not been enough time, and currently there is not enough market information available, to fully analyze and evaluate all potential use case options.

Symantec will be analyzing and evaluating other .BRAND gTLD applications as well as general market adoption to determine short- and long-term potential best-in-class use case options to most effectively serve and enhance Symantec’s online strategy as a leading provider of information security and protection. As a company, Symantec’s unique focus is to eliminate risks to information, technology, and processes independent of the device, platform, interaction, or location. Symantec helps individuals, small and medium-sized businesses, and global organizations ensure that their information, technology infrastructures, and related processes are protected and easily managed. Symantec delivers solutions that allow customers to access information when they need it and make it available to all of those who should have access to it. The .NORTON gTLD will be in line with the company’s current focus by providing a trusted, hierarchical, secure, and intuitive namespace.

Although ICANN has not specifically recognized a .BRAND gTLD specification in the current version of the Applicant Guidebook, it is widely anticipated within the brand-owner community that this will become a specialty subset of gTLDs. The .NORTON gTLD is planned as a .BRAND gTLD with the goal of protecting Symantec’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 Symantec.

Symantec intends to initially limit registration and use of domain names within the .NORTON gTLD to Symantec and its qualified subsidiaries and affiliates. This initial limited use will allow Symantec to establish its 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 Symantec from its annual Code of Conduct Compliance requirements.

After Stage 3 (see below), Symantec 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 Symantec and its qualified subsidiaries and affiliates.

Symantec currently plans a four-stage rollout for the .NORTON gTLD:

Stage 1: The initial stage of implementation of the gTLD will involve Symantec registering a limited number of .NORTON second-level domain names.

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

Stage 2: Once all testing has been successfully completed, Symantec will begin allocating domain names in .NORTON for more widespread internal corporate use. During this same period of time, Symantec 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 Symantec’s new gTLDs.

It is in Stage 2 that Symantec 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 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 Symantec’s business model.

Stage 3: Depending on the analysis of the evaluations undertaken in Stage 2, Symantec may begin to implement the permanent migration of Internet traffic away from the TLDs in which Symantec’s domain names are currently registered, and toward the new Symantec branded gTLDs. It is in this stage that Symantec may implement its 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 Symantec’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Symantec will have full control over the number of registrations in the .NORTON gTLD namespace, Symantec 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 its experience with any expansion implemented in Stage 3, Symantec will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, potentially including customers of Symantec. It is anticipated by Symantec 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, partner, and licensee use will take into account this experience as well as the technical analysis of potential expansion.

The potential use of the .NORTON gTLD will also be driven by Symantec’s future business strategies as identified in its annual report and investor filings, see: http:⁄⁄investor.symantec.com⁄phoenix.zhtml?c=89422&p=irol-reports.

Utilizing current projections based upon Symantec’s existing businesses, future business plans, current domain name portfolio, and other strategic factors, Symantec estimates second-level domain name registrations to be in line with the projections set forth in the financial template provided in response to Question 46 of this application.

18B. 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?

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

-Establish a trusted source of information and an online marketplace for the millions of consumers who purchase goods and services through Symantec’s online stores, for investors and third-parties seeking information, and for the general Internet user population;

-Provide Symantec and its qualified subsidiaries and affiliates with short and memorable Internet addresses; provide increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;

-Minimize the cost and need for defensive registrations because domain names within the .NORTON gTLD will only be allocated internally to Symantec and its qualified subsidiaries and affiliates, at least for the first three years of operation; and

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

In addition, Symantec currently operates a number of websites using a combination of second-level and top-level domain names. A representative sampling of Symantec’s websites that incorporate geographical identifiers into domain names include:

-NortonAntivirus.no

-Firewall-Plus.be

-Norton360.pl

-GeotrustNewZealand.co.nz

-Geotrust-Europe.de

-Hamburg-TrustCenter.de

-UpgradeSymantec.dk

-Veritas.tw

Symantec believes that a .NORTON gTLD can provide a verifiable online source-identifying function for its current and future customers around the world, instead of the current mix-and-match approach that Symantec has used in different markets around the world.

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 .NORTON gTLD is to provide a trusted, hierarchical, secure, and intuitive online marketplace to deliver Symantec content, services, and information about our business and focus, as well as other goods and services. As Symantec 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 on various platforms, including the Internet and mobile devices, among others.

Businesses are increasingly adopting cloud, virtualization, and mobile technologies to reduce the cost of their IT infrastructures and enhance access to their information. By providing products and solutions that support the adoption of these key technology trends, Symantec seeks to maintain a position of leadership in helping businesses protect, secure, and mange their information and identities. Given the increasing demand to access Symantec and its products through a variety of channels, which include domain names, Symantec believes that a .NORTON gTLD has the potential to provide an innovative, virtual avenue to Symantec goods and services that will deepen and broaden its relationship with consumers.

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

While security companies such as Symantec fight a never-ending battle to protect information, consumers, businesses, and governments from piracy on the Internet, a .NORTON gTLD would offers consumers a safe and intuitive means of accessing authorized content from Symantec and its qualified subsidiaries and affiliates.

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 the .NORTON 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 .NORTON gTLD. Using this benchmark, Symantec strives to build consumer recognition and trust through the usage of the .NORTON gTLD 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?

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

The initial use of the .NORTON gTLD will be primarily defensive in nature, with Symantec registering a limited number of second-level domain names. This initial use will provide Symantec’s IT and security personnel the ability to run a number of tests to ensure seamless and secure access to the Symantec websites, and interoperability with various software and Web-⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Symantec will likely begin allocating domain names for internal corporate use and may redirect new .NORTON domain names to preexisting 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, Symantec will evaluate potential strategies to use the .NORTON gTLD in other ways that will advance Symantec’s corporate mission and goals.

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

Symantec currently intends for the .NORTON gTLD to be exclusively used by Symantec and its qualified subsidiaries and affiliates, at least for the first three years of operation. Because of this condition, and because the Norton mark is a valuable brand, the protection of which is paramount to the company, Symantec intends to address registration and use requirements in its qualified subsidiary and affiliate agreements, rather than in a domain name registration agreement.

Notwithstanding this, Symantec 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 agreements.

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 information and security company, Symantec recognizes that this is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will be registered to Symantec and its qualified subsidiaries and affiliates, at least for the first three years of operation, Symantec has a vested interest in making sure that accurate and current domain name information is readily available in connection with each .NORTON domain name. For the .NORTON gTLD, all private and confidential information will be protected.

Symantec will ensure that the operation of the .NORTON gTLD will be consistent with its Statement of Privacy Principles, available on its website, see http:⁄⁄www.symantec.com⁄about⁄profile⁄policies⁄privacy.jsp.

In addition, Symantec 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.”

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

Symantec sees the potential for this gTLD to play a large role in Symantec’s future online strategic initiative. However, 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 this, Symantec plans to start using .NORTON domains initially as redirects to existing .COM domains. Symantec also plans to carefully review the release of new gTLDs by others, the response from search engines to branded gTLDs, and the perception of consumers. As the marketplace evolves, Symantec will invest in outreach and communication as needed to ensure that its consumers, partners, and affiliates continue to interact with Symantec content in a simplified and efficient manner.

18C. 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)? What other steps will you take to minimize negative consequences/costs imposed upon consumers?

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)?

Symantec’s proposed operating rules to limit registration to Symantec and its qualified subsidiaries and affiliates, at least for the first three years of operation, will provide a trusted online environment for consumers to access Symantec’s online content, and by default will minimize social costs. This verified ecosystem provides consumers with a single, trusted source for Symantec goods and services with a substantially lower risk of the fraud, misdirection, infringement, or scams that consumers are plagued with in .COM and other open gTLDs. Symantec does not anticipate consumer vulnerabilities. Therefore, one way in which social costs will be eliminated is that there will be no need for other trademark and brand owners to defensively register second-level domains in the .NORTON gTLD. In fact, Symantec’s expectation is that the usage of a .NORTON gTLD will eliminate many of the vulnerabilities that Symantec consumers face in the wider Internet today.

18.3.1 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

Symantec believes that the proposed operation of the .NORTON 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 direct and quantifiable benefits to consumers.

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?

Symantec does not envision multiple applicants for the same domain name, as domain names will only be allocated to Symantec and its qualified subsidiaries and affiliates, at least for the first three years of operation, in accordance with Symantec’s business plan for the .NORTON gTLD.

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

Symantec does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the mission and purpose of the .NORTON gTLD as a trusted online source identifier. Moreover, it is the current intention of Symantec to provide domain name registrations to itself and its qualified subsidiaries and affiliates at no cost, though the company 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.

Symantec is committed to providing the domain name registration periods set forth in the registry agreement. However, as noted above, as a branded gTLD, the registration and use of the domain name is conditioned upon a separate qualified subsidiary or affiliate relationship with Symantec. Therefore, providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate. Additionally, as noted above, the current business model envisions Symantec providing domain name registrations to itself and its qualified subsidiaries and affiliates at no cost, at least for the first three years of operation.

Symantec 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, Symantec and its qualified subsidiaries and affiliates, as the sole registrants within the .NORTON gTLD, will only be registering domain names on an annual basis. This is done to better account for costs on an annual basis as well as to provide for more concise financial statements in Question 46, therefore there will be no multi-year registrations or deferred revenue.