.ALLSTATE New gTLD Application
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New gTLD Application Submitted to ICANN by: Allstate Fire and Casualty Insurance Company
String: ALLSTATE
Originally Posted: 13 June 2012
Application ID: 1-1191-71962
Applicant Information
- Full legal name
Allstate Fire and Casualty Insurance Company
- Address of the principal place of business
3075 Sanders Road
Suite H1A
Northbrook Illinois 60062-7127
US
- Phone number
+1 847 402 5000
- Fax number
+1 847 326 7524
- If applicable, website or URL
Primary Contact
6(a). Name
Ms. Megan Pavich
6(b). Title
Senior Attorney
6(c). Address
6(d). Phone Number
847 402 7996
6(e). Fax Number
6(f). Email Address
Secondary Contact
7(a). Name
Ms. Cynthia Caitlin Dean
7(b). Title
Domain Portfolio Manager, eBusiness & Direct Marketing
7(c). Address
7(d). Phone Number
+1 847 402 2795
7(e). Fax Number
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Corporation
8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).
Illinois
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.
Allstate Insurance Holdings, L.L.C., a subsidiary of The Allstate 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
Samuel Henry Pilch Director
Steven Paul Sorenson Director
Thomas Matthew Goldstein Director
11(b). Name(s) and position(s) of all officers and partners
David Scott Harper Senior Vice President
Floyd Michael Yager Senior Vice President
James Jonske Vice President
Jeffrey J. McRae Senior Vice President and Assistant Treasurer
Jennifer Mary Hager Assistant Secretary
Judith Pepple Greffin Executive Vice President and Chief Investment Officer
Laurie Pellouchoud Vice President
Mario Rizzo Senior Vice President and Treasurer
Mark Lynn Thompson Vice President
Mary J. McGinn Senior Vice President and Secretary
Michael A. LaMonica Senior Vice President
Richard Clayton Crist, Jr. Senior Vice President and Chief Privacy Officer
Richard J. Law Senior Vice President
Richard Paul Yocius Vice President
Samuel Henry Pilch Senior Group Vice President, Controller and Chief Financial Officer
Steven Carl Verney Senior Vice President and Assistant Treasurer
Steven Paul Sorenson Chairman of the Board and President
Teresa J. Dalenta Senior Vice President and Chief Risk Officer
11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares
Allstate Insurance Holdings, L.L.C. 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.
ALLSTATE
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.
Q.16 – Mitigation
Allstate Fire and Casualty Insurance Company anticipates the introduction of this .ALLSTATE gTLD without operational or rendering problems. Based on a decade of experience launching and operating new TLDs, Afilias Limited (ʺAfiliasʺ) the back-end provider of registry services for the. ALLSTATE gTLD, is confident the launch and operation of this gTLD presents no known challenges. The rationale for this opinion includes:
----The string is not complex and is represented in standard ASCII characters and follows relevant technical, operational and policy standards;
----The string length is within lengths currently supported in the root and by ubiquitous Internet programs such as web browsers and mail applications;
----There are no new standards required for the introduction of the .ALLSTATE gTLD;
----No onerous requirements are being made on registrars, registrants or Internet users, and;
----The existing secure, stable and reliable Afilias SRS, DNS, WHOIS and supporting systems and staff are amply provisioned and prepared to meet the needs of the .ALLSTATE gTLD.
- (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 .ALLSTATE
The content of this Answer to Question 18 set forth below describing the plans for Allstate Fire and Casualty Insurance Company’s (“AFCIC”) registry constitutes the “purpose” of the registry as that term is used in Paragraph 1.b. of Specification 9 of the Draft New gTLD Registry Agreement found in Module 5 of the Applicant Guidebook dated January 11, 2012 (“the Purpose”). AFCIC will publish its Charter and its policies, guidelines, and other supporting documentation related to the implementation of the registry consistent with the Purpose, all prior to launch. All second-level domain names registered by AFCIC on behalf of itself or an affiliate will be registered through an ICANN-accredited registrar and will be consistent with the Purpose.
The .ALLSTATE gTLD registry will be a standard, not a community-based, registry. The .ALLSTATE gTLD registry will be a standard registry restricted to AFCIC and its qualified subsidiaries, affiliates, or business partners having the Required License (as defined below). For the avoidance of a doubt, the registry will be closed to registrants who do not have a formal, written trademark license agreement from AFCIC’s affiliate, Allstate Insurance Company, specifically allowing the registration of a second-level domain name in the .ALLSTATE gTLD registry (the “Required License”). There will be no market for second-level registrations outside of registrants that are affiliated with AFCIC and⁄or that have the Required License.
The Allstate Corporation and their affiliated companies (collectively, “the Allstate Family” or “Allstate”) comprise a leading insurance group that provides insurance products for autos, apartments, homes, recreational vehicles, motorcycles, boats, personal property, lives and businesses across the country (http:⁄⁄www.allstate.com⁄about.aspx). Allstate is the largest publicly-held personal lines property and casualty insurance group in America with 12,000 agents and operations throughout the United States, Canada, and in the UK. Affiliates of Allstate include, but are not limited to Esurance and Answer Financial.
Recognizing the potential dynamic evolution of a .ALLSTATE gTLD as a trusted brand namespace, Allstate Fire and Casualty Insurance Company, (“AFCIC”) is filing this application to bring the .ALLSTATE gTLD to the Internet. AFCIC is a large insurer writing property and casualty insurance in virtually all states of the United States. Although AFCIC is committed to moving forward with a .ALLSTATE gTLD application, it has not, at the time of filing this application, been able to fully vet and analyze all potential use case options.
The intended future mission of the .ALLSTATE gTLD is to serve as a trusted, hierarchical, and intuitive namespace for AFCIC and potentially its qualified subsidiaries, affiliates, or business partners having the Required License, all with the goal of advancing Allstate’s business interests and ability to effectively compete globally.
AFCIC intends to initially limit registration and use of domain names within the .ALLSTATE gTLD to qualified member companies within Allstate. This initial limited use will allow AFCIC to establish its operations and achieve full sustainability. This limited distribution, coupled with its Purpose and the other requirements set forth in Specification 9 of the Draft New gTLD Registry Agreement, is intended to exempt AFCIC from any annual Code of Conduct Compliance requirements.
AFCIC will be analyzing and evaluating other .BRAND gTLD applications as well as general market adoption to determine meaningful use case options to most effectively serve and enhance Allstate’s online strategy as a leading insurance provider with operations in a variety of segments.
AFCIC currently plans a three-stage rollout for the .ALLSTATE gTLD:
- Stage One
The initial stage of implementation of the gTLD will involve Allstate registering a limited number of .ALLSTATE second-level domain names. This initial use will provide Allstate’s IT and security personnel the time to ensure seamless and secure access using the .ALLSTATE gTLD domain names and interoperability with various software and Web-based applications. This stage will also allow the appropriate Allstate staff to coordinate with the internal and external staff responsible for the application, delegation, and setup phases of the .ALLSTATE gTLD to ensure a proper transition from delegation to full operation.
- Stage Two
Once all testing has been successfully completed, AFCIC may begin allocating domain names in .ALLSTATE for more widespread corporate use. During this same period of time, AFCIC will begin evaluating strategies to potentially migrate traffic away from Allstate’s current patchwork network of second-level domain names, which are registered in a variety of gTLDs and ccTLDs, to .ALLSTATE.
It is in Stage Two that AFCIC will evaluate expanding the operations of the .ALLSTATE gTLD to permit registration by third parties such as licensees or other strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other licensed business partners, this expansion is currently planned to take place during Stage Three, and likely after the first three years of operation.
However, any expansion would be consistent with the Purpose and conditioned upon a review of Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with AFCIC’s business model.
- Stage Three
Depending upon the analysis of the evaluations undertaken in Stage Two, AFCIC may begin to implement the permanent migration of Internet traffic away from the gTLDs in which Allstate’s domain names are currently registered, and toward the new gTLD. It is in this stage that AFCIC also may implement its decision to extend registration rights to third parties such as licensees or other strategic partners having the Required License, consistent with the Purpose and in 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 Allstate’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that AFCIC will have full control over the number of registrations in the .ALLSTATE gTLD namespace, AFCIC is confident that the number of domain name registrations will not exceed 10,000 in the first year, nor will registrations exceed 50,000 at the end of Year 5.
Based on its experience to the end of Year 5, and based on its experience with any expansion implemented in Stage Three, AFCIC will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees and other third parties, such as customers of Allstate. It is anticipated by Allstate 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 allow registrations by such third parties will take into account this experience as well as the technical analysis of potential expansion and Allstate’s future business strategies, which in part are identified in the relevant annual report and investor filings, see http:⁄⁄www.allstateinvestors.com⁄.
Utilizing current projections based upon Allstate’s existing businesses, future business plans, current domain name portfolio, and other strategic factors, AFCIC estimates second-level domain name registrations to be in line with the projections set forth in the financial template provided in Answer 46.
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?
AFCIC believes that a proposed .ALLSTATE gTLD has the potential to offer a variety of benefits to Internet users and consumers, such as establishing a trusted source of information and an online marketplace for the millions of consumers searching for insurance product information through Allstate’s online content; for investors and third parties seeking information; and for the general Internet user population.
In addition, .ALLSTATE will provide AFCIC and potentially its qualified subsidiaries, affiliates, and business partners having the Required License with short and memorable Internet addresses and increased ability to navigate to information about Allstate insurance policies and services, while minimizing the cost and need for defensive registrations because domain names within the .ALLSTATE gTLD will only be allocated by AFCIC to its affiliate company, Allstate Insurance Company, as well as potentially qualified Allstate subsidiaries and affiliates, and business partners having the Required License.
AFCIC also intends to use .ALLSTATE to develop a potential platform for the secure access to, research of, purchase of, payment for, and distribution of Allstate insurance policies and information to consumers, in order to minimize the potential for deceptive practices or infringing content. Also, consumers may benefit from lower incidents of phishing and malware 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 .ALLSTATE gTLD.
Currently, Allstate operates a number of corporate websites using a combination of second-level and top-level domain names. A representative sampling of Allstate websites that incorporate geographical identifiers into domain names include:
-AllstateNorthernIreland.eu
-AllstateAuto.co.uk
-AllstateAgent.ca
-AllstateArizona.com
-AllstateAutoInsuranceMiami.com
-AllstateBoston.com
-AllstateMN.com
-AllstateMS.com
-AllstateNYC.com
-AllstateSeattle.com
-AllstateTX.com
-AllstateSanFrancisco.com
AFCIC believes that a .ALLSTATE gTLD can provide a single, online source identifying function for its current and future customers around the world, instead of the current mix-and-match approach that Allstate is forced to resort to as it expands into different markets.
18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
The primary mission of the .ALLSTATE gTLD is to provide a trusted, hierarchical, and intuitive online marketplace to aggregate Allstate content and other offers and services. As Allstate continues to expand, the desire is to pursue and develop opportunities to market and distribute its online content and products to consumers on various platforms, including the Internet and mobile devices, among others. Given that customers increasingly demand access to Allstate information, products, and services through a variety of channels, which include domain names, AFCIC believes that a .ALLSTATE gTLD has the potential to provide an innovative, virtual avenue to content that will deepen and broaden Allstate’s relationship with consumers.
Most importantly, AFCIC will be able to help ensure access to Allstate products and online content in a namespace less affected by piracy, cybersquatting, and other malicious activities.
Providing consumers with a trusted experience is a paramount goal to AFCIC and Allstate, and a .ALLSTATE gTLD will be used to further that goal. Given the high saturation of insurance-related sites, including many that offer misleading or outright incorrect information to users, and even sites that defraud users, the .ALLSTATE extension offers assurance that current and prospective Allstate policyholders are receiving authorized and up-to-date information, all in the global public interest.
While insurance providers, such as Allstate, fight never-ending battles to protect their valuable intellectual property from fraud and piracy on the Internet, a .ALLSTATE gTLD offers consumers a safer and more intuitive means of accessing authorized content from Allstate.
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 .ALLSTATE gTLD are differentiation and innovation. The success of the gTLD will not be measured by the number of domain names registered. Instead, it will be measured by the level of consumer recognition of and trust that is placed in the .ALLSTATE gTLD.
Using this benchmark, AFCIC strives to build consumer recognition and trust that rises to the level of that found in the .EDU and .GOV gTLDs.
As noted above, Allstate leverages emerging technologies to deliver insurance and financial products and services to its consumers in the United States and internationally. The .ALLSTATE gTLD has the potential to aid this online strategy, if potential consumer benefits that ICANN experts have forecasted become a reality.
18.2.3 What goals does your proposed gTLD have in terms of user experience?
AFCIC believes that the .ALLSTATE gTLD will provide a single, trusted ecosystem experience for the millions of current and prospective policyholders worldwide who seek information about insurance. In addition to providing consumers with short, memorable, and intuitive domain names, AFCIC hopes to have robust safeguards to minimize any fraudulent activity within the .ALLSTATE gTLD.
In looking at potential sources of such safeguards and goals for the TLD, AFCIC reviewed the work of ICANN’s High Security Zone TLD Advisory Group (HSTLD AG). This was a multi-disciplinary advisory group originally created to help ICANN address and minimize potential malicious conduct within the New gTLD Program. AFCIC specifically found value in and supported the stated goal of HSTLD AG “to bring together community representatives to evaluate the viability of a voluntary program, supporting control standards and incentives that could potentially be adopted to provide an enhanced level of trust and security over the baseline registration-authority controls.ʺ
The initial use of the .ALLSTATE gTLD will involve AFCIC registering a conservative number of second-level domain names in the first year. This initial use will provide Allstate’s IT and security personnel the ability to run a number of assessments for seamless and secure access to the website, and interoperability with various software and Web⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, AFCIC plans to begin allocating domain names for internal corporate use and may redirect new .ALLSTATE 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, and will be in line with Allstate’s marketing strategy and technology needs.
18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
The .ALLSTATE gTLD is initially intended to be exclusively used by AFCIC, its affiliate, Allstate Insurance Company, and potentially other subsidiaries and affiliates. Should business partners eventually be allowed to register second-level domain names, each will have the Required License, which will terminate in the event of a misuse. The termination of the Required License will result in the deletion of any second-level domain name(s) registered to any such business partner. Because of this intended use, any registration and use requirements are more appropriately vested in these corporate⁄affiliate agreements and in the Required License (if any), not in a domain name registration agreement itself.
While Allstate is fully supportive of, and committed to, ICANN’s bottom-up, consensus-driven model, the Allstate mark ALLSTATE is a valuable brand whose protection is of paramount importance. Therefore, any registration and use requirements (e.g., trademark quality control provisions) must, necessarily, vest in these other agreements.
Notwithstanding these concerns, AFCIC 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 registrant 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 business with operations in the U.S., Europe, and elsewhere, Allstate recognizes firsthand that this is an evolving area of law in which there is no single international standard. However, due to the fact that every domain name will be registered initially to AFCIC or potentially a qualified subsidiary or affiliate, AFCIC has a vested interest in ensuring that accurate and current domain name information is readily available in connection with each .ALLSTATE domain name.
Allstate employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information within its premises and on its websites. AFCIC will take similar precautions to protect registrant and user data associated with the .ALLSTATE gTLD.
AFCIC will ensure that the operation of the .ALLSTATE gTLD will be consistent with relevant local and national laws governing privacy rights protection, as they are interpreted and applied, and has obtained a similar warranty from its back-end services provider.
In addition, AFCIC intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language which has been included in the Draft New gTLD Registry Agreement and which has been successfully utilized by existing ICANN gTLD Registry Operators.
The Draft New gTLD 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.
Allstate sees the potential for this gTLD to serve as a component of Allstate’s future online strategic initiative. However, there remain a number of unanswered questions concerning consumer recognition and adoption of new gTLDs in the marketplace that first must be fully answered to Allstate’s satisfaction.
Allstate plans to start using these domain names primarily as redirects to existing .COM domains. After careful analysis and study of a targeted pilot rollout using the new .ALLSTATE domains as addresses, Allstate may plan to engage in a broader, strategic initiative, should the results be positive. The actual usage of .ALLSTATE domain names will dictate what public communications and consumer outreach may be done to encourage navigation to the .ALLSTATE gTLD. This is not limited to, but may include, advertising, media outreach, in-store communications, and email campaigns. However, there is currently no specific plan or budget for such communications given the uncertainty of consumer adoption of new gTLDs in the marketplace.
18(c). What operating rules will you adopt to eliminate or minimize social costs?
18.3.1 What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?
AFCIC’s proposed operating rules to limit registration as described herein will provide a number of benefits, as well as a trusted online environment for consumers of Allstate content and other information and services. Trademark and brand ownersʹ costs will be mitigated, since there will be no need to defensively register second-level domains in .ALLSTATE.
In addition, this verified ecosystem will provide consumers with a single, trusted source for Allstate content with a substantially lower risk of exposure to phishing, fraud and⁄or other Internet scams, thus reducing the level of consumer vulnerability.
18.3.2 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
AFCIC believes that the proposed operation of the .ALLSTATE gTLD as set forth in this application has no known negative consequences or direct cost implications to consumers.
On the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to consumers given the trusted nature of the .ALLSTATE gTLD namespace, as described in detail above.
18.3.3 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Given the restrictions on registrations noted above, AFCIC does not envision multiple applicants for the same domain name.
18.3.4 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
AFCIC does not envision any pricing, introductory discounts, or bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the Purpose of the .ALLSTATE gTLD. There is no anticipated market for second-level registrations in the .ALLSTATE gTLD.
Moreover, it is the current intention of AFCIC to provide domain name registrations to Allstate Insurance Company, and qualified subsidiaries and affiliates as well as business partners having the Required License, at cost or at no cost, though AFCIC reserves the right to reevaluate any pricing decision and may choose to impose additional fees in the future. Any registrant fees imposed in the future will be consistent with the Purpose as well as the Draft New gTLD Registry Agreement and ICANN Consensus Policies.
18.3.5 Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
AFCIC is committed to providing the domain name registration periods set forth in the Registry Agreement. However, as noted above, the registration and use of a .ALLSTATE domain name is restricted.
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 AFCIC providing domain name registrations at cost or at no cost.
AFCIC acknowledges that the current Draft New gTLD 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, the selection of the number of years for which a particular second-level domain name is registered is a decision of the registrant and not the registrar. Given that all second-level registrations will be consistent with the Purpose and restricted as set forth above, AFCIC intends to only register 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, e.g., no multi-year registrations or deferred revenue.