.cba New gTLD Application
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New gTLD Application Submitted to ICANN by: COMMONWEALTH BANK OF AUSTRALIA
String: cba
Originally Posted: 13 June 2012
Application ID: 1-1672-4934
Applicant Information
- Full legal name
COMMONWEALTH BANK OF AUSTRALIA
- Address of the principal place of business
Ground Floor, Tower 1
201 Sussex Street
Sydney New South Wales 1155
AU
- Phone number
+61 13 22 21
- Fax number
+61 2 91181601
- If applicable, website or URL
http:⁄⁄www.commbank.com.au
Primary Contact
6(a). Name
Catherine Anne Cobby
6(b). Title
Channel Development Manager
6(c). Address
6(d). Phone Number
+61 02 9118 1694
6(e). Fax Number
+61 02 9118 1601
6(f). Email Address
Secondary Contact
7(a). Name
Geoff Gee-Jun Kim
7(b). Title
Intranet Manager
7(c). Address
7(d). Phone Number
+61 2 9118 1697
7(e). Fax Number
+61 2 91181601
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).
Australia
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.
Australian_Securities_Exchange;ASX:CBA
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
Andrew Max Mohl Board of Director
Brian James Long Board of Director
Colin Robert Galbraith Board of Director
David John Turner Chairman
Fergus Denis Ryan Board of Director
Harrison Hurst Young Board of Director
Ian Mark Narev Managing Director and CEO
Jane Sharman Hemstritch Board of Director
John Anthony Anderson Board of Director
Lorna Karen Inman Board of Director
Sarah Carolyn Hailes Kay Board of Director
11(b). Name(s) and position(s) of all officers and partners
11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares
11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility
Applied-for gTLD string
- Provide the applied-for gTLD string. If an IDN, provide the U-label.
cba
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 .cba 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
- .cba 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 .cba has not already been queried with meaningful frequency at the root. Therefore, it is unlikely that .cba will inherit significant invalid query traffic.
Due to the positive results of these checks, Commonwealth Bank of Australia does not believe that the .cba 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 .CBA gTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST AND CONFIDENCE THROUGH THE ELIMINATION OF USER CONFUSION AND ASSURANCE OF BRAND AUTHENTICITY.
The new .cba gTLD will operate as a restricted registry, in which the Commonwealth Bank of Australia (CBA) can create and control domain spaces that promote its brand identity and authenticity. In this regard, .cba will be used by CBA to provide information, services and resources to customers in a way that promotes trust, confidence and utility. The .cba gTLD will provide an authoritative internet space for CBA, its affiliates and partners that are associated with the CBA brand. Second and third level domain names can then be utilised for online banking, specific product and services websites and for communication and marketing purposes, with internet users assured of brand authenticity.
CBA is Australia’s leading provider of integrated financial products and services including retail, premium, business and institutional banking, funds management, superannuation, insurance, investments and stockbroking. As Australia’s largest retail bank, CBA has leading domestic market shares in retail deposits, home loans, personal loans, credit cards and discount stockbroking. In 2011, CBA was in the top 10 largest banks in the world by market capitalisation and was ranked equal 12th in Global Finance’s World’s 50 Safest Banks based on long-term credit ratings. CBA is listed on the Australian Stock Exchange (ASX) with a market capitalisation of approximately AUD70 billion, revenue in the 2011 financial year of AUD46 billion and over 52,000 employees. CBA is the stock code for CBA’s listing on the ASX and the acronym “CBA” is commonly used by the media and customers to refer to the company. CBA is Australia’s leading online bank with over five million online banking customers. NetBank, CBA’s online banking website and application, is consistently in the top 10 most visited Australian websites. Also, all email correspondence to customers (including email notifications from the internet banking application) is currently issued on cba.com.au email addresses. In this regard, consumer trust, brand reputation and continuous innovation are paramount considerations in all its activities. As well as strengthening CBA’s position as Australia’s leading online bank, the .cba gTLD will enhance consumer trust and confidence in CBA’s online brands by providing a more secure and authentic online banking environment. These goals will be complemented by CBA’s separate applications for the new .commbank and .netbank gTLDs.
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. .cba will facilitate greater trust and assurance from internet users connecting with CBA online, whilst still allowing convenient and efficient interaction.
CBA’s mission and purpose of the gTLD share ICANN’s initiatives to promote public interest. CBA is committed to contribute towards achieving such initiatives in line with ICANN’s Affirmation of Commitments, which includes:
- consumer trust: .cba will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to CBA and its affiliate entities, at this stage, which will provide added consumer trust and confidence that .cba domain names are completely secure, authentic and trustworthy. As .cba domain names are subject to registration standards, policies and procedures under CBA’s control, this eliminates the possibility of malicious conduct within .cba;
- competition: .cba 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 .cba 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: .cba will enable user-driven improvements and innovations assisting CBA’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 CBA. As CBA has effective control over the registration and use of domain names under .cba, this will also contribute towards general service innovations on the internet.
Given the restricted nature of .cba, the projected number of registration is likely to be limited. It is anticipated that about 10 domain names will be registered in the first year. However, over the next few years the number of registrations is likely to increase to around 50 domain names as CBA implements new products, services and marketing campaigns.
As the .cba gTLD expands, CBA will continue to comply with all operational, technical and policy requirements, as well as maintaining consumer trust and the stability of the internet. CBA will keep ICANN reasonably informed of any material developments relating to .cba including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.
CBA intends to create relevant domain names for online banking, products, services and geographic names at the second or third level. In accordance with registration policies and the proposed measures for protection of geographic names as outlined in response to Question 22, CBA will use geographic names to localise its websites in countries in which it operates. The use of geographic names is intended to:
- connect internet users with relevant information as applicable to the territory; and
- comply with required rules and regulations in the national territory.
CBA does not intend to utilise Internationalized Domain Names (IDNs) at the second level at this stage. However, CBA may wish to use IDNs in the future to allow internet users to engage with .cba in their native language, creating a more positive user experience and encouraging diversity.
CBA is a well-recognised brand in the Asia-Pacific region, particularly in Australia, with its “CBA”, “Commonwealth Bank of Australia” and “CBA Group” trademarks registered in Australia for Insurance and financial services including banking and stockbroking (Class 36).
CBA has existing domain names with an exact match to its “CBA” trademark and the applied-for .cba string in the following spaces:
- gTLDs: cba.asia & cba.mobi
- ccTLDs: cba.com.au, cba.cm, cba.co & cba.vn
CBA also has 7 gTLDS and 5 ccTLDs containing the “CBA” trademark. Additionally, CBA currently uses .cba as a TLD for internal intranet sites, for example commnet.cba and peoplesoft.cba. Recently, CBA was successful in securing Sunrise application for the .xxx domain space based on existing trademark registration.
CBA believes that the .cba gTLD is unlikely to cause confusion with either a generic term or any existing TLDs. CBA trademarks are a leading banking brand with significant reputation in the Asia-Pacific and particularly Australia. CBA has used the term CBA in conjunction with its retail banking businesses for almost 100 years. As such, the CBA brand is well known for its integrated banking and financial services.
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 .cba gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. CBA also seeks to foster its online reputation and provide an authoritative internet space through which CBA is able to communicate with its customers directly and effectively. The .cba domain space will strengthen CBA’s online brand reputation by enhancing security and providing authentic and memorable domain names that are relevant to customers. The ability to create domain names on demand related to specific marketing campaigns, 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 .cba gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .cba gTLD will simplify how internet users interact with CBA by providing a distinctive domain space. Internet users will be able to directly navigate to the .cba gTLD site, saving time and resources searching for an official site. 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. This is particularly important to a bank such as CBA where consumer trust in its online brand depends on CBA’s ability to provide safe, secure and authentic internet banking websites and applications. CBA can address these vulnerabilities by maintaining complete control over the domain names registered under the .cba domain space. The new .cba gTLD will allow CBA to create domain names that are authentic, unique and clearly identifiable to customers as a CBA website or application. Further, providing shorter and more memorable domain names for customers will reduce the likelihood of customers being deceived by phishing websites. Together with consumer trust and confidence, internet users will be able to rely on the authoritativeness of the domain names under .cba domain space, which will differentiate interaction between internet users and CBA.
COMPETITION:
The differentiation of .cba gTLD as a trusted site for CBA will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Internet users will be encouraged to interact with domain names under .cba domain space. As a result, .cba will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .cba will be distributed not only to its direct customers, but to the internet community at large forcing improved services and competitive pricing 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 and organisations 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, particularly in relation to suitable domains for specific marketing campaigns. 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. Online brand coherence is particularly important for banks and financial services providers such as CBA where consumer trust and protection is critical in the era of new technologies. The .cba gTLD will provide more convenient and innovative transaction opportunities for customers accessing CBA online banking on mobile devices. CBA has the ability to create second or third level domain names including the use of online and mobile banking and innovative new products and services on demand which are relevant to its customer base. CBA will be able to combine its use of the domain space with innovative user focused marketing and services to address the currently unmet needs in the existing domain name system providing greater consumer choice.
18(B)III. WHAT GOALS DOES YOUR PROPOSED gTLD HAVE IN TERMS OF USER EXPERIENCE?
The proposed .cba will provide a positive user experience, which meets the changing and growing needs of the global internet community. CBA 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 CBA. Therefore, .cba gTLD will:
- strengthen brand reputation and user confidence by enhancing security and eliminating user confusion;
- provide greater online trust and confidence for customers when accessing authentic and secure internet banking websites and applications under the .cba domain space;
- provide an easy and intuitive reference and access point for internet users;
- provide shorter, memorable and relevant domain names for customers, reducing the likelihood of customers being deceived by phishing websites;
- direct internet users to relevant information in a timely manner by creating domain names on demand;
- enhance security and minimise security risks by implementing necessary technical and policy measures; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.
The .cba 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 .cba gTLD will reduce potential abuses in the registration processes and overall costs to internet users. 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 affiliate entities of CBA will be eligible to register domain names in .cba 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.
CBA 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 Privacy Act 1998 (Australia), which has specific laws governing credit providers such as CBA, and the National Privacy Principles (Australia).
CBA also has implemented its own privacy policy to demonstrate its commitment to the protection of user privacy and confidential information. CBA values customers’ trust highly and aims to manage and build customers’ wealth over a long period of time. The protection of customers’ personal information is a vital part of this relationship. CBA’s privacy policy provides that CBA will protect customers personal information in accordance with the Privacy Act and the National Privacy Principles and will only use customers’ personal information to:
- administer relationships with customers;
- provide customers with the products and services they request;
- provide information on products and services offered by CBA, its affiliates or external providers for which CBA acts as an agent;
- assist customers with queries;
- monitor and evaluate products and services;
- gather and aggregate information for statistical, prudential, actuarial and research purposes;
- comply with its legal obligations;
- take measures to detect and prevent fraud and credit loss; and
- predict the borrowing behaviour of its customers generally.
As the .cba gTLD will only be available to affiliate entities of CBA, 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. CBA 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, CBA 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.
CBA will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both CBA and its users interacting with CBA online. 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 .cba gTLD. CBA already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include the use of:
- CBA’s internal Computer Emergency Response Team (CERT), which co-ordinates early detection and handling of IT security incidents;
- eDiscovery and Digitial Forensic services;
- Security Information and Event Management (SIEM);
- Data Leakage Protection (DLP);
- User Access Verification (UAV);
- Solution Delivery Lifecycle (SDLC);
- Supplier Governance Framework including ISO27001⁄2-based ISMS reviews and site reviews; and
- Security Architecture and Design.
CBA 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 .cba 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 at time of implementation to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity.
During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users will 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 internal users (affiliate entities) at this stage and no third parties will be able to register domain names under .cba domain space. Therefore, it is not anticipated that third party trademark owners will incur costs in relation to the .cba gTLD. The affiliate entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. CBA 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 .cba 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 CBA and affiliate entities are intended to be the registrants under the .cba 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.