.aaa New gTLD Application
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New gTLD Application Submitted to ICANN by: American Automobile Association, Inc.
String: aaa
Originally Posted: 13 June 2012
Application ID: 1-1386-27446
Applicant Information
- Full legal name
American Automobile Association, Inc.
- Address of the principal place of business
1000 AAA Drive
Heathrow FL 32746
US
- Phone number
+1 407 444 7000
- Fax number
+1 407 444 7380
- If applicable, website or URL
http:⁄⁄www.aaa.com
Primary Contact
6(a). Name
Mr. Christopher Niemi
6(b). Title
Domain Operations Supervisor
6(c). Address
6(d). Phone Number
+1 208 685 1857
6(e). Fax Number
+1 208 389 5771
6(f). Email Address
Secondary Contact
7(a). Name
Ms. Carole Sustak
7(b). Title
Manager, Brand Management
7(c). Address
7(d). Phone Number
+1 407 444 7613
7(e). Fax Number
+1 407 444 7614
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Non-stock corporation
8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).
Connecticut, 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.
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
Antonia Hernandez Vice Chairman, American Automobile Association
Brian W. Thomas President & CEO, AAA Akron Auto Club
Chris M. Bauer CEO, AnchorBank
Dennis I. Okamoto Retired
Donald R. Gagnon President & CEO, AAA Mid-Atlantic
Donald W. Main Owner, Pik-a-Dilly RV Center
John A. Tomlin Chief Operating Officer, AAA Auto Club Group
Mark A. Shaw President & CEO, AAA Southern New England
Paula R. Collins Founder and CEO, WDG Ventures, Inc.
Robert L. Darbelnet President & CEO, American Automobile Association
Thomas V. McKernan CEO, Auto Club Enterprises
Wayne A. Budd Chairman of the Board, American Automobile Association
11(b). Name(s) and position(s) of all officers and partners
John G. Schaffer Vice President and Chief Financial Officer
Kathleen F. Marvaso Vice President, AAA Public Affairs
Mark H. Brown Executive Vice President, Association and Club Services
Marshall L. Doney Vice President, AAA Automotive, Financial Services & E-Business
Richard D. Rinner Executive Vice President, Administration & Publishing
Robert L. Darbelnet President & CEO, American Automobile Association
Satish Mahajan Vice President, Chief Information Officer
William J. Sutherland Vice President, Travel Services
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
- Provide the applied-for gTLD string. If an IDN, provide the U-label.
aaa
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.
As is the case with any new TLD that is added to the DNS root zone, some general technical acceptance issues with the delegation of this TLD are expected. The back-end registry services provider selected by the Applicant has a significant experience in introducing new TLDs to the DNS root, including .BIZ, .US, and – more recently – .CO.
Following discussions with various domain name experts, we have not been able to determine any particular issues with respect to the applied-for gTLD, since:
- the string is entirely in Standard US ASCII characters;
- the length of the string is within the acceptable range of characters, as set out by ICANN;
- similar strings of the same nature have been successfully introduced in the root, including the TLDs referred to above, without the registry operator, registrars, registrants or Internet users having experienced technical, operational or rendering issues with respect to this string.
Therefore, the Applicant is of the opinion that there are no particular operational or rendering problems to be expected in relation to the applied-for gTLD string.
- (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.
According to the Applicant, the American Automobile Association, Inc. (the “AAA”), the mission and purpose of the .aaa TLD are manifold, as will be further explained below.
The Applicant is an independent, not for-profit organization and with some 53.3 million members the largest automobile club in the world. It gained a reputation in the United States and beyond for its excellent services and products that strictly focus on the needs of its members. The Applicant is commonly referred to by its acronym “AAA”, which also became the Applicant’s key brand. With the .aaa TLD, the AAA would like to create an additional platform for its services and products offered as well as a trusted and secure environment for the communication with its member organizations, its individual members and between these stakeholders. The most important purposes of the .aaa TLD can be summarized as follows:
- Securing, protecting and operating the Applicant’s key brand (“AAA”) as a gTLD to the benefit of its stakeholders referred to below;
- Reflect the “AAA” brand at the top level of the DNS’ hierarchy, next to the existing gTLDs and ccTLDs;
- Provide stakeholders of the Applicant with a recognizable and trusted identifier on the Internet. Such stakeholders include, but are not limited to:
- the regional clubs of the Applicant;
- the local clubs of the Applicant;
- certain organizations associated with the Applicant, e.g. vintage car clubs;
- members of the Applicant; and
- directors and officers of the Applicant and its subsidiaries, including its employees.
- business partners and other strategic partners as identified by the Applicant
- Provide such stakeholders with a secure and safe Internet environment, under the control of the Applicant, in which they are able to obtain information, products and services from and communicate with the Applicant and where they are able to obtain genuine information provided by the AAA and its approved stakeholders.
18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
The AAA intends to organize the registry operation for the .aaain such a manner that it will minimize the likelihood of having multiple applications or registration requests for a particular domain name.
According to the AAA, this can be achieved in any of the following ways, which likely needs to be further refined following ICANN’s award and delegation of the .aaa gTLD to the Applicant:
- From the Applicant’s perspective, .aaa may bring a high degree of recognition and specialization to the currently existing name space. Where in most cases the specific connotation that has been initially given to the gTLDs (or even ccTLDs) has disappeared, the .aaa top-level domain is currently intended to be unambiguous as regards:
- the identity of the AAA as the Registry Operator;
- the source of the content, products and services offered under the .aaa gTLD;
- the affiliation between the Registry Operator and the TLD; and
- in term, and at the discretion of the AAA, the affiliation between the Registry Operator and any third party that is authorized by the
- the AAA to register and⁄or use one or more domain name registrations in the .aaa TLD.
- As mentioned in the vision and mission statement above, the key reasons why Applicant is applying for .aaa include but are not limited to:
- Securing and protecting the “AAA” brand as a generic top-level domain;
The Applicant holds various registered trademarks for the AAA and its derivations. An important reason for which the AAA submits this application for the .aaa gTLD is that it wants to prevent third parties from securing the TLD that is identical to the AAA’s highly distinctive and reputable brand;
- Reflecting the Applicant’s key brand “AAA” at the top-level of the DNS’ hierarchy;
- Safety, security and peace of mind;
4.Providing a platform for the community of the Applicant’s member organizations and about 53.3 million individual members.
- The Applicant intends to implement the following policies and procedures with respect to the registration of domain names in the .aaa top-level domain:
(i) reservation and registration of domain names in the name of the AAA. It is likely that this will be the scenario that the AAA will put in place during the first months or even years of operation of the .aaa gTLD.
These names may include, but are not limited to:
- descriptive names, referring to the services and products offered by the Applicant to its members;
- descriptive names, referring to the regional and local clubs of the Applicant and to organizations associated with the Applicant;
- potentially also names relating to other stakeholders of the AAA, to be determined by the AAA following ICANN’s award and delegation of the .aaa gTLD to the Applicant;
(ii) launch of the TLD: if and when implemented by the Registry Operator, this is likely going to be a gradual process, whereby selected third parties that meet certain criteria, which the AAA will be entitled to set at its own discretion, may register domain names in the .aaa gTLD. These processes may include the following:
- Sunrise: allow physical persons, organizations and entities that meet the eligibility requirements determined by the AAA at that point in time to choose and, where allowed by the AAA, to register the domain names that are identical to their trademarks;
- Land rush and general availability: other available domain names may be registered by physical persons, organizations and entities that meet the eligibility requirements and domain name registration terms and conditions in force at that point in time to choose the domain names in accordance with the applicable terms and conditions.
Depending on the terms and conditions in force at the time of launch of the TLD, these domain names may or may not be registered in the name of the entity wishing to register a domain name or in the name of the Registry Operator of the TLD (i.e., the AAA). In any case, the AAA reserves the right to impose additional and other restrictions from time to time at its sole discretion;
- Given the fact that the Applicant is a company that is established in the United States, it is subject to national privacy and data protection rules and practices. In particular, given the fact that certain data protection authorities have issued strict guidelines, the AAA will at all times be obliged to carefully consider and, where applicable, implement these policies, and this prior to and during the operation of the .aaa gTLD.
- At this stage, the AAA has not developed concrete and tangible plans in order to expand its online activities from its many active domain names. However, the AAA has different ways in order to make existing and future members, visitors and stakeholders aware of the (gradual) development of a new online environment under the .aaaTLD, including but not limited to:
- Direct and indirect marketing and branding initiatives;
- By way of brochures and advertisements in newspapers, magazines, its own membership magazine etc.;
- Internet advertising campaigns, including paid search, pay-per-click advertising, etc.;
- Having Internet traffic to the its various active domain names resolving into domain names registered in the .aaa TLD, which builds awareness with Internet users that the .aaa gTLD exists;
- Email marketing campaigns;
- etc.
18(c). What operating rules will you adopt to eliminate or minimize social costs?
In line with the AAA’s mission and purpose for the .aaa gTLD, it is important for the AAA to safeguard and protect its AAA trademark at the top level of the DNS’ hierarchy. The AAA has built up a reputation as a leading and independent provider servicing the needs of its members and wants to avoid the unduly exploitation of that reputation in the domain name space by third parties. The protection mechanisms the AAA intends to put in place do therefore not only extend to the actual registration, delegation and use of the TLD, but also to the domain names that are registered therein, and how these domain names are used.
Considering the fact that the actual award and delegation of the .aaa gTLD to the AAA is subject to the successful evaluation of our application, we have not yet defined in detail but have begun discussion of the following:
- the types of domain names that will be registered;
- who will be entitled to select which domain names will be registered
- who will be entitled to register such domain names;
- who will be entitled to use such domain names, and;
- which types of use will be allowed or recommended.
As we believe that the development and implementation of one or more business cases could likely take a couple of months or even years, we have only focused on a number of high-level characteristics of our plans in relation to the operation of the .aaa gTLD.
By all means, it is in the AAA’s vested interest to, on the one hand, make the most of this initiative, promote the interests of its members (be it legal entities or individuals), and mitigate risks for its brand, the reputation of the AAA and for its members, whilst also reducing the (social) costs for others.
In this context, we will devise policies that encompass and comprise the following features:
At least during the initial months or even years following the delegation of the .aaa gTLD to the Applicant, this extension is likely going to be a so-called “single registrant TLD” as contemplated by ICANN in Article 4.5 of the template Registry Operator Agreement (“Transition of Registry upon Termination of Agreement”). For the avoidance of doubt, a “single registrant TLD” is a TLD where “(i) all domain name registrations in the TLD are registered to, and maintained by, Registry Operator for its own exclusive use, and (ii) Registry Operator does not sell, distribute or transfer control or use of any registrations in the TLD to any third party that is not an Affiliate of Registry Operator.”
Therefore, parties who are not the AAA or – insofar and to the extent the AAA deems appropriate – an Affiliate (such as e.g. the Applicant`s regional and local clubs, the Applicant’s individual members or authorized third parties who perform services or offer products to the benefit of the Applicant’s members) will not be entitled to register domain names in the .aaa gTLD.
The AAA believes this to be in line with two of the main elements in its vision and mission statement, namely:
- Protecting and safeguarding the AAA brand and its reputation, by keeping full control over the entire operation of the .aaa registry and every domain name registered therein; and
- Guaranteeing to AAA’s key stakeholders who are interacting with the AAA and between each other by using domain name registrations in .aaa that they are in fact interacting with the members of the AAA community or, as the case may be, with a third party authorized by that community.
Consequently, there will be no (social) costs for non-eligible (third) parties, given the fact that they will be unable to register domain names in the .aaa gTLD in the first place.
However, even if only the AAA (and, as the case may be, AAA Affiliates or stakeholders, that is, its local and regional clubs, individual members and possibly third parties who perform services or offer products to the benefit of the Applicant’s members) will be entitled to register domain names, this does not exclude the hypothesis that disputes may arise with one or more third parties as regards domain names that are registered in the .aaa gTLD.
In order to avoid these risks, the AAA intends to implement the following policies and processes:
First, the domain names to be registered by the AAA and, as the case may be, its Affiliates (that is, its local and regional clubs, members and possibly third parties who perform services or offer products to the benefit of the Applicant’s members), will likely relate to the following:
- registered trademarks of the AAA;
- names of the regional and local clubs of the AAA;
- names of the individual members of the AAA;
- names of organizations associated with the Applicant, e.g. vintage car clubs;
- third parties who perform services or offer products to the benefit of the Applicant’s members;
- names of departments within the AAA;
- names of foundations and social initiatives supported by the AAA;
- names of events (e.g. motorsports events) organized by the AAA;
- etc.
Furthermore, the AAA envisages registering a fair number of generic words that are directly or indirectly related to the services and products offered to and the activities organized by the various members of the AAA.
Prior to effectively registering such domain names in the .aaa gTLD, the AAA will require its legal and intellectual property department to review the list of these domain names on a regular basis in order to satisfy itself that they will not infringe the rights of third parties.
In any case, the AAA will claim to have a legitimate interest in these domain names, as they are merely descriptive of the activities, products or services of the AAA offered to its members. So even if one or more of these domain names would be protected by a registered trademark, held by a third party, it is likely that a claim under the Uniform Dispute Resolution Policy or Uniform Rapid Suspension policy will fail.
As regards the names referred to in Specification 5 to the template Registry Operator Agreement, AAA will follow the processes and procedures established by ICANN and the Governmental Advisory Committee.
If the AAA would determine, at its sole discretion, that it will gradually allow certain categories of stakeholders to register domain names in the .aaa gTLD in their own name, the AAA will devise policies to that effect.
However, AAA will at all times be entitled to restrict, limit or expand:
- the category or categories of stakeholders who will be entitled to register one or more domain names in the .AAA gTLD, including their criteria for qualification, however in any case excluding stakeholders who are not a member of the AAA or do not have a sufficient link to the AAA community;
- the choice of domain name(s) registered in the .aaa gTLD by and per such eligible stakeholder (category);
- the use made by an and per eligible stakeholder of a domain name registered in the .aaa gTLD;
- the transfer of domain names registered in .aaa;
- etc.
The AAA shall reserve the right to subject the registration or use of a domain name to internal approval processes and procedures, at each and every step of the domain name life cycle.
Given the fact that the AAA may release such available domain names post launch in a highly controlled manner, this also reduces the likelihood that two or more applicants qualify for the registration of the same domain name in the .aaa top-level domain.
As a method of last resort, and subject to the actual domain name registration policy adopted by the Applicant and in force at the time of registration, domain names will be allocated on a first-come, first-served basis.
In any event, the AAA reserves the right to change or restrict any policies, procedures and practices at any point in time if it is of the opinion that there would be a risk that the reputation of the AAA brand would be damaged.
The Applicant intends to make the .aaa top-level domain available to qualifying domain name registrants at no cost to them; if the Applicant ⁄ Registry Operator would be required to charge a fee for the registration of domain names under the .aaa TLD, the fee will be set at a cost-recovery or arm’s length basis, to be determined at that time by the Registry.
If the AAA will be required to or would decide to increase the fees for the registration of domain names, such increases will keep pace with the cost-recovery or arm’s length character referred to above.