.bbt New gTLD Application
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New gTLD Application Submitted to ICANN by: BB&T Corporation
String: bbt
Originally Posted: 13 June 2012
Application ID: 1-1860-74210
Applicant Information
- Full legal name
BB&T Corporation
- Address of the principal place of business
200 West Second Street
Winston Salem North Carolina 27101
US
- Phone number
001 800 226 5228
- Fax number
001 919 791 3356
- If applicable, website or URL
http:⁄⁄www.bbt.com⁄
Primary Contact
6(a). Name
Christopher James Barry
6(b). Title
AVP Strategy Analyst
6(c). Address
6(d). Phone Number
001 919 745 5328
6(e). Fax Number
001 919 791 3356
6(f). Email Address
Secondary Contact
7(a). Name
Rachel Floars
7(b). Title
Senior Vice President EDC Risk Manager
7(c). Address
7(d). Phone Number
001 252 246 4708
7(e). Fax Number
001 252 246 4222
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).
United States of America, State of North Carolina
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.
New_York_Stock_Exchange;NYSE: BBT
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
Leon Wilson Operations Division Manager
11(b). Name(s) and position(s) of all officers and partners
Chris Henson Chief Operations Officer
Daryl Bible Chief Financial Officer
Kelly King Chairman & CEO
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.
bbt
14(a). If an IDN, provide the A-label (beginning with "xn--").
14(b). If an IDN, provide the meaning or restatement of the string in English, that is, a description of the literal meaning of the string in the opinion of the applicant.
14(c). If an IDN, provide the language of the label (in English).
14(c). If an IDN, provide the language of the label (as referenced by ISO-639-1).
14(d). If an IDN, provide the script of the label (in English).
14(d). If an IDN, provide the script of the label (as referenced by ISO 15924).
14(e). If an IDN, list all code points contained in the U-label according to Unicode form.
15(a). If an IDN, Attach IDN Tables for the proposed registry.
Attachments are not displayed on this form.
15(b). Describe the process used for development of the IDN tables submitted, including consultations and sources used.
15(c). List any variant strings to the applied-for gTLD string according to the relevant IDN tables.
- Describe the applicant's efforts to ensure that there are no known operational or rendering problems concerning the applied-for gTLD string. If such issues are known, describe steps that will be taken to mitigate these issues in software and other applications.
The .bbt string and A-Label were developed in line with and checked against the eligibility, stability and policy criteria as stated in the ICANN Applicant Guidebook - version 2012-01-11. The results of those checks are as follows:
- The string has less than 63 characters;
- The string in ASCII is composed of three or more visually distinct characters;
- The ASCII label consists entirely of letters;
- The string is not a reserved name as shown in section 2.2.1.2.1 - Reserved Names of the ICANN Applicant Guidebook
- version 2012-01-11; and
- .bbt is not identical or similar to any of the top 10 invalid TLD’s responsible for the majority of DNS pollution, as referenced in the Security and Stability Advisory Committee (SSAC)’s report on this topic at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac045.pdf. It is likely that the .bbt has not already been queried with meaningful frequency at the root. Therefore, it is unlikely that .bbt will inherit significant invalid query traffic.
Due to the positive results of these checks, BB&T Corporation does not believe that the .bbt gTLD will be subject to any operational or rendering problems.
- (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.
THE MISSION AND PURPOSE OF THE NEW RESTRICTED .BBT GTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST, CONVENIENCE AND SECURITY.
The .bbt gTLD will create a new generation gTLD serving the interests of end users by providing an authoritative internet space where information, services and resources of the brand will be closely controlled by BB&T Corporation (BB&T). The majority of the anticipated domain name registrations in the .bbt gTLD will be used in the promotion and communication of the BB&T brand and its financial services. A subset of domain names has the potential to be created and used for communicative and marketing purposes, with internet users assured of brand authenticity.
BB&T, headquartered in Winston-Salem, North Carolina, is one of the largest financial services holding companies in the US with $174.6 billion in assets and market capitalization of $17.5 billion as of Dec. 31, 2011. Founded in 1872, BB&T offers a full range of consumer and commercial banking, securities brokerage, asset management, mortgage and insurance products. The companyʹs more than 30,000 associates operate approximately 1,800 financial centers in 12 states and Washington, D.C. A Fortune 500 company, BB&T is a member of the S&P 500 Index and is listed on the New York Stock Exchange under the ticker symbol BBT. Since 1995, BB&T has distinguished itself among the nationʹs top performers -- the best of the best -- through the acquisition of more than 35 community banks and thrifts, more than 90 insurance agencies and 32 non-bank financial services companies. BB&T is consistently recognized for outstanding client satisfaction by J.D. Power and Associates, the U.S. Small Business Association, Greenwich Associates and others. BB&T’s operating strategy is to ensure that local decisions are made locally so that client service is more responsive, reliable empathic and competent, thereby distinguishing BB&T from other financial holding companies. In this regard, consumer trust and continuous innovation are paramount considerations in BB&T’s application for .bbt.
Business activities are increasingly conducted over the internet, allowing for greater levels of interaction between businesses and customers. As a result, both businesses and end users benefit from ease of interaction and a wider range of choices with lower transaction costs. However, the development in this arena in the current domain name system has exposed both businesses and consumers to increased criminal activities over the internet, including data breach, hacking and phishing. These sophisticated criminal activities cause reputational damage to businesses as internet users lose consumer confidence and trust with the businesses targeted by such criminal activities. With the .bbt gTLD under the complete control of BB&T, such risks will be mitigated. This will enhance BB&T’s ability to communicate securely with its clients as a bank and facilitate greater trust and assurance from internet users connecting with BB&T, whilst still allowing convenient and efficient interaction.
BB&T’s mission and purpose of the proposed new gTLD share ICANN’s initiatives to promote public interest. BB&T is committed to contribute towards achieving such initiatives in line with ICANN’s Affirmation of Commitments, which includes:
- consumer trust: the .bbt gTLD registry will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to BB&T, at this stage, which will provide added consumer trust that .bbt domain names are trustworthy. As .bbt domain names are subject to registration standards, policies and procedures under BB&T’s control, this eliminates the possibility of malicious conduct within the .bbt domain space;
- competition: the .bbt gTLD is not intended to instigate competition and consumer choice at the level of registration of domain names among prospective registrants. Instead it is anticipated to contribute to ICANN’s initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in the .bbt gTLD will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and
- consumer choice: the .bbt gTLD will enable user-driven improvements and innovations assisting BB&T’s marketing efforts through its ability to create new second and third level domain names on demand. These names will provide the consumers with more choices for interacting with BB&T. As BB&T has effective control over the registration and use of domain names under the .bbt domain space, this will also contribute towards general service innovations on the internet.
Given the restricted nature of the .bbt gTLD, the projected number of registrations is likely to be limited. It is anticipated that between 5 and 500 domain names will be registered in the first few years. However, the number of registrations is likely to increase as BB&T develops and implements new ways of doing business online and new methods of communicating with its online users such as creating product and service related domain names.
As the new .bbt gTLD expands and evolves, BB&T will continue to comply with all operational, technical and policy requirements, as well as maintaining consumer trust and the stability of the internet. BB&T will keep ICANN reasonably informed of any material developments relating to .bbt including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.
BB&T does not intend to use geographic names and⁄or Internationalized Domain Names (IDNs) in the second level at this stage. However, BB&T may use geographic names or IDNs at a later stage to:
- localise its websites in the States that BB&T operates in to connect internet users with relevant information applicable to their location; and
- comply with required rules and regulations in the relevant States.
Such use of geographic names will be will be in accordance with the registration policy and the proposed measures for protection of geographic names as outlined in response to Question 22.
BB&T is a well-recognised US brand with its trademarks such as “BBT”, “BB&T”, “BB&T Online” and “BBT.com” registered in its main country of operation, US, in the Insurance and financial (Class 36) for financial services.
Further, BB&T has 5 existing domain names with an exact match to the applied-for .bbt string and BB&T’s “BBT” trademark in spaces such as bbt.com and bbt.us. BB&T also has over 130 existing domain names containing the “BBT” trademark in spaces including bbtbanks.info, bbtcard.net, bbtbanking.org and bbtmarketing.us.
BB&T believes that the .bbt gTLD is unlikely to cause confusion with either a generic term or any existing TLDs. BB&T trademarks are a well-established and is a reputable brand in the retail banking sector in the US with BB&T having used the term BB&T and BBT in conjunction with its community banking and other businesses.
18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
18(b)i. WHAT IS THE GOAL OF YOUR PROPOSED GTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?
The key goals of the proposed new .bbt gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. In an ever changing internet business environment, BB&T seeks to foster its online reputation and enhance its long term growth efforts by taking advantage of the opportunities provided by the tools and technology available in such an environment. Further, with the proposed .bbt gTLD, BB&T seeks to provide an authoritative internet space through which BB&T is able to communicate with its customers directly and effectively. The ability to create domain names on demand related to specific marketing, specialty service and product development supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.
18(b)ii. WHAT DO YOU ANTICIPATE YOUR PROPOSED GTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?
It is anticipated that the proposed .bbt gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .bbt gTLD will simplify how internet users interact with BB&T by providing a distinctive domain space. Internet users will be able to directly navigate to the .bbt gTLD site, saving time and resources searching for an official site. BB&T seeks to use the .bbt domain space as a communication platform to interact with its users and to promote its sales and marketing programmes. BB&T plans to provide its users an enhanced and seamless integrated experience using the proposed .bbt gTLD along with its existing online domains, social media sites, standard marketing tools and communications methods. The .bbt gTLD will provide BB&T with the opportunity to offer targeted sales and personalised offers to its existing and prospective clients. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. BB&T can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .bbt domain space to provide a more secure integrated communications experience to its users. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under the .bbt domain space, which will enhance interaction between internet users and BB&T.
COMPETITION:
The differentiation of the .bbt gTLD as a trusted site for BB&T will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. The .bbt domain names will foster innovation and provide BB&T with new ways of doing business online. Internet users will be encouraged to interact with domain names under the .bbt domain space. As a result, .bbt will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .bbt gTLD will be distributed not only to its direct customers, but to the internet community at large by improving service and competition in the market place.
INNOVATION:
With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. With the .bbt gTLD, BB&T has the ability to create second or third level domain names which are relevant to its customer base, services and products specific to its financial services. BB&T will be able to combine its use of the domain space with innovative personalised user focused marketing and services to address the currently unmet needs in the existing domain name system, thereby providing greater consumer choice to its current and prospect clients.
18(b)iii. WHAT GOALS DOES YOUR PROPOSED GTLD HAVE IN TERMS OF USER EXPERIENCE?
The proposed .bbt gTLD will provide a positive user experience, which meets the changing and growing needs of the global internet community. BB&T will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorised by BB&T. Therefore, the .bbt gTLD will:
- provide an easy and intuitive reference and access point for internet users;
- provide BB&T opportunities to offer targeted sales and personalised services to its current and prospective clients;
- enhance BB&T’s communications platform for its internet users;
- represent BB&T’s online authenticity thus promoting user confidence;
- direct internet users to relevant information in a timely manner by creating domain names on demand thereby establishing a seamless integrated online experience for BB&T’s users;
- enhance security and minimise security risks by implementing necessary technical and policy measures;
- strengthen BB&T’s online brand reputation as a bank and promote user confidence amongst its users by mitigating cybercrime risks and eliminating user confusion; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.
The .bbt gTLD should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .bbt gTLD will reduce potential abuses in the registration processes and overall costs to internet users. The registration and use of domain names within the .bbt gTLD will be restricted to BB&T only for its internal business use. Therefore, user confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the public interest.
18(b)iv. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE
The proposed registration policy is attached in response to Question 28.
Only BB&T will be eligible to register domain names in .bbt at this stage. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures.
18(b)v. 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 part of a heavily regulated industry, BB&T is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user’s confidential information, including the Electronic Communications Privacy Act 1986 (US) and Controlling the assault of non-solicited pornography and marketing (Can-Spam) Act (2003) (US). BB&T also complies with all relevant Federal and State requirements and standards for the financial industry in the US including Regulation P of Section 216 of the Code of Federal Regulations in US and regulations from the Securities and Exchange Commission, Office of Foreign Assets Control, Financial Industry Regulatory Authority, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, Federal Financial Institutions Examinations Council and the Federal Reserve System in the US.
Privacy is of fundamental concern to BB&T’s customers as the interaction between BB&T and its internet users may involve monetary transactions. As such BB&T has a strong interest in ensuring a high level of privacy protection for its customers. BB&T has also implemented its own privacy policies and controls to demonstrate its commitment to the protection of user privacy and confidential information.
BB&T currently operates 3 privacy policies, which are all available on its website, to ensure that its users are informed of the types of information that it collects and how such information is used:
Online Information Practices: BB&T only collects personally identifiable information over its website if a user has provided such information via its online contact forms, online applications, or online banking.
(i) BB&T Corporation Consumer Privacy: As a financial institution in the US, federal law allows BB&T to share personally identifiable information to the extent that a user limits such sharing. BB&T only shares such information where it is required to run its everyday business.
(ii) BB&T Complete Client Protection: provides information on the advanced technologies used by BB&T to safeguard personal and financial information of its users relevant to BB&T’s various services.
As the .bbt gTLD will only be available to BB&T, initially, the amount of personal data that will be collected for the purposes of operating the gTLD and made publicly available in the WHOIS database will be very limited. BB&T will provide a publicly available and searchable WHOIS look up facility, where information about the domain name status, registrant information including administrative and technical contact details can be found in accordance with Specification 4 of the Registry Agreement. In order to prevent misuse of the WHOIS look up facility, BB&T will utilise measures including a requirement where any person submitting a WHOIS database query is required to read and agree to the terms and conditions in accordance with the registration policy. This will include the terms of use that the WHOIS database is provided for information purposes only and that the user agrees not to use the information for any other purposes such as allowing or enabling the transmission of unsolicited commercial advertising or other communication.
BB&T will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both BB&T and its users interacting with BB&T. DNSSEC provides additional security by validating information in the transmission, therefore it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .bbt gTLD. BB&T already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include:
- use of Secure Sockets Layer (SSL) data encryption;
- use of various encryption methodologies;
- use of user identifiers (UID);
- use of passwords; and
- employment of multifactor and out of band authentication methods.
BB&T will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .bbt domain space.
18(b)vi. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
The proposed new gTLD will be publicised by a media plan to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity.
BB&T plans to implement the .bbt gTLD in its marketing promotions and via a multi-channel communications campaign directed towards its existing clients to alert them of the new .bbt domain space.
During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users may be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilise the trusted site will contribute towards minimising malicious abuses and protecting internet users.
18(c). What operating rules will you adopt to eliminate or minimize social costs?
As a restricted gTLD, registration will only be open to BB&T at this stage and no third parties will be able to register domain names under the .bbt domain space. Therefore, it is not anticipated that third party trademark owners will incur costs in relation to the .bbt gTLD. Any affiliate entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. BB&T will utilise the services of the proposed Trademark Clearinghouse to ensure that domain names registered and the use of those domain names, do not infringe any registered third party intellectual property rights.
No unaffiliated third party will be permitted to register domain names at this stage. It is estimated that time and money spent by consumers who have been targeted by malicious abuse in utilising services on the internet will reduce over time as a result of the new, trusted .bbt gTLD.
18(c)i. HOW WILL MULTIPLE APPLICATIONS FOR A PARTICULAR DOMAIN NAME BE RESOLVED, FOR EXAMPLE, BY AUCTION OR ON A FIRST-COME⁄FIRST-SERVE BASIS?
The initial use of the proposed new gTLD will be restricted to internal business use and BB&T is intended to be the only registrant under the .bbt gTLD. Therefore conflicts between multiple applications are not anticipated to occur.
18(c)ii. EXPLAIN ANY COST BENEFITS FOR REGISTRANTS YOU INTEND TO IMPLEMENT (E.G., ADVANTAGEOUS PRICING, INTRODUCTORY DISCOUNTS, BULK REGISTRATION DISCOUNTS).
This gTLD will be used for internal purposes only, at this stage, so pricing incentives are not applicable or relevant.
18(c)iii. 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 PLAN.
This gTLD will be used for internal purposes only, at this stage, so pricing incentives or pricing increases are not applicable or relevant as no additional fees are to be charged.