.citadel New gTLD Application
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New gTLD Application Submitted to ICANN by: Citadel Domain LLC
String: citadel
Originally Posted: 13 June 2012
Application ID: 1-1848-15726
Applicant Information
- Full legal name
Citadel Domain LLC
- Address of the principal place of business
131 South Dearborn Street
Chicago Illinois 60603
US
- Phone number
3123952100
- Fax number
3122677776
- If applicable, website or URL
Primary Contact
6(a). Name
Karen Schweickart
6(b). Title
Chief IP Counsel & Assistant General Counsel
6(c). Address
6(d). Phone Number
312 558 5963
6(e). Fax Number
6(f). Email Address
Secondary Contact
7(a). Name
Paul McGrady
7(b). Title
Partner, Winston & Strawn
7(c). Address
7(d). Phone Number
3125585963
7(e). Fax Number
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Limited Liability Company
8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).
Delaware
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.
Citadel, LLC
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
11(b). Name(s) and position(s) of all officers and partners
Adam Charles Cooper President
11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares
Citadel LLC 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.
citadel
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.
Response to Q16
As the applied-for gTLD string is not an IDN and is consistent with the requirements of the Applicant Guidebook Section 2.2.1.3.2 (String Requirements), Applicant does not believe there are any known operational or rendering problems concerning the string. This answer is based upon consultation with Applicant’s selected back-end provider, Neustar, which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, Neustar analyzed the following data:
- ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and Consequences (SAC009)
- IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”
- Known software issues which Neustar has encountered during the last decade launching new gTLDs
- Character type and length
- ICANN supplemental notes to Question 16
- ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance.
- (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 content of this Answer to Question 18 set forth below which describes the plans for Applicant’s 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”). Applicant 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 Applicant on behalf of itself or an affiliate will be registered through an ICANN-accredited registrar and will be consistent with the Purpose.
Applicant is an a wholly-owned subsidiary of Citadel, LLC (“Citadel”). Citadel is a leading global financial institution with a diverse business platform that is built on a foundation of exceptional talent and technology. Citadel’s deep bench of talent embodies a culture of dedication and commitment.
As of March 1, Citadel funds have over $11 billion under management. Launched in 1990, Citadel Asset Management deploys capital through multiple investment strategies across the worldʹs major markets. Citadel Securities has provided outstanding service and execution capabilities to clients since 2004. Citadel Securities is one of the leading equity and options market-makers in the United States, and it is building a growing franchise in Europe. Applicant seeks to become the registry for the .citadel top level domain name. The new gTLD, .citadel, corresponds to the CITADEL trademark which is registered in the name of Applicant’s affiliate, KCG IP Holdings LLC (“KCG IP”), in various countries throughout the world. By way of example, see U.S. Reg. No. 3213943 for the CITADEL mark. See also European Union Reg. No. 2170009 and Chinese Reg. No. 6870932. Applicant will operate the .citadel registry under a trademark license from KCG IP. Citadel, KCG IP, Applicant and all of their affiliates are collectively referred to herein as the “Citadel Family”.
The .citadel registry will be a standard registry open only to Citadel and its affiliates. For the avoidance of a doubt, the registry will be closed to registrants who do not have a formal, written trademark license agreement from KCG IP specifically allowing the registration of a second level domain name in the .citadel registry (the “Required License”). The .citadel registry will not be a community-based registry and there will be no market for second level registrations outside of registrants which are affiliated with Applicant and which have the Required License.
The Purpose includes:
- The enhancement of the CITADEL brand through being viewed as a forward thinking institution and acting in the Internet space which is consistent with how Citadel is viewed in its industry.
- The protection of our investor base through the use of the .citadel registry to provide a safe and secure platform for the delivery of some of Citadel’s goods and services.
- The protection of the CITADEL brand within the domain name system.
18(b). How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
The registry will be closed and strictly administered by Citadel Family personnel. As such, Applicant believes that the registry will benefit the following stakeholders:
- Our employees. The 〈.citadel〉 gTLD will reinforce the CITADEL brand throughout the world. It will also provide a channel for more secure communications among our employees.
- Our clients and investors. A .Citadel registry will benefit our clients and investors and protect them from possible confusion by becoming the internet location for authentic and accurate information about the Citadel Family and our goods and services. Further, we believe that a .citadel registry will result in less cybersquatting in the second level since clients, investors and others will be able to easily locate us in the top level. We believe that this will ultimately lead to lower social costs, including lowering our need to consume the resources of the courts and various arbitration providers.
- The press and relevant governments. Since the .citadel gTLD will be a closed registry, the press and relevant governments will be able to take advantage of a single location for accurate information regarding the Citadel Family.
What is the goal of your proposed gTLD in terms of areas of speciality, service levels reputation?
Citadel is a world class, globally recognized financial institution. The addition of a .citadel registry with second level domain names that serve as an information point and email mechanism will only enhance our already solid reputation in our field.
What do you anticipate your proposed gTLD will add to the current space in terms of competition, differentiation or innovation?
The current domain name space is cluttered with extraneous terms such as “.com” and crowded. In fact, Citadel has not been able to secure the registration of 〈citadel.com〉 which is currently registered to a third party in an unrelated field and is being used merely as a redirect to another URL. Further, country code domain name registrations can be difficult to register and costly to maintain. Unlike a gTLD, ccTLDs have limited appeal outside of a narrow geographic area.
We believe that a .citadel gTLD addresses both the cluttered name space as well as the currently crowded gTLD market. Further, by utilizing intuitive second level registrations, we believe that our clients and investors will be able to find pertinent information more quickly and with more confidence regarding its source.
Should consumers adopt the new gTLD naming process, we look forward to marketing our goods and services in conjunction with the .citadel TLD.
What goals does your proposed gTLD have in terms of user experience?
Our goal is to provide a single, trusted source of information about the Citadel Family and to provide a more secure channel for communication. Whether the stakeholders are our clients, investors, employees, the press or relevant governments, we believe that a .citadel registry enhances our ability to communicate with such stakeholders in a more secure, less confusing fashion.
Provide a complete description of the applicant’s intended registration policies in support of the goals above
Applicant, as registry operator, will develop a Citadel Domain Management Policy (the “Citadel Policy”) and will see to its enforcement. The Citadel Policy will be updated from time to time to reflect changes to ICANN consensus policies and changes in the law which effect the domain name space. Since the .citadel registry will be a closed registry which is available only to those with the Required License, the Citadel Policy will reflect these requirements. Lastly, the Citadel Policy will set for the various dispute policies which apply to .citadel, for example, the UDRP.
Whenever a second level domain name is registered, Applicant will check it to ensure that the proposed registrant has the Required License. If so, Applicant will check to ensure that the second level registration meets all required conventions and falls within Applicant’s acceptable registration and use criteria. Once registered, the domain name may be registered in the name of one of the companies making up the Citadel Family, but will always remain the property of Applicant and will always remain subject to the Required License. There will be no aftermarket in any .citadel domain names.
In order for a finalized decision on registration to occur, each second level string must meet the following criteria:
- It must not match any character strings reserved by ICANN
- While hyphens may be used, it must not start or end with a hyphen
- It must consist of letters, numbers, and hyphens and not other characters
- It must not correspond to any known mark of any competitors of the Citadel Family
- It must be between 3 and 63 characters long
- It must not match protected geographic terms until such time as ICANN provides a process for the registration of such terms in the Applicant’s registry
At the present time, we do not anticipate that internationalized domain names (IDN) will be registered in the .Citadel registry at the second level, although the capacity for such registrations will be supported by NeuStar, our back end services subcontractor. However, IDN registrations may occur as consumer recognition of the new gTLD space evolves. As stated before, there will be no aftermarket for second level registrations in the .citadel registry. Registrants having the Required License will not be permitted to transfer ownership or permit use to any party that does not have the Required License. All second level domain names must be used to advance the business activities of the Citadel Family and Applicant will reserve the right to cancel any second level domain name should it no longer be necessary to advance such goals.
Second level registrations must not be used to knowingly infringe the rights of another nor for any improper use which could be considered a moral or public order abuse.
Regarding RPMs, Applicant will full comply with ICANN requirements, including interfacing with the Trademark Clearinghouse. Applicant will operate a Sunrise and IP Claims service. All second level registrations and registry operations must comply with the URS and the UDRP, among other consensus policies.
Will your proposed gTLD impose any measures for protecting the privacy of confidential information of registrants or users?
Citadel is a global financial institution and as such has in place strict controls over the retention and disclosure of personal information. There will be no individual registrants of second level domain names. Further, any information posted in the WHOIS record will be that of Applicant, even if the registration is made for the benefit of another Citadel Family member company. Even so, Applicant is committed to compliance with all privacy obligations found in the ICANN Registry Agreement. Applicant will, when appropriate, audit the work of the WHOIS data escrow provider and will maintain best practices in privacy management, including compliance with any applicable ICANN consensus policies currently in place or promulgated in the future.
Describe whether and in what ways outreach and communications will help to achieve your projected benefits?
Applicant will produce internal documents used to describe the registration restrictions and processes in place for second level registrations.
18(c). What operating rules will you adopt to eliminate or minimize social costs?
The .citadel registry itself will reduce the social cost of unnecessary enforcement of the CITADEL mark in the second level. Since all registrants of second level registrations must have the Required License and will not be made available to registrants outside of the Citadel Family, social costs will be eliminated.
How will multiple applications for a particular domain be resolved, for example, by auction or on a first come first served basis?
Since registrations will be limited to members of the Citadel Family who have the Required License, there will be no market in the second level .citadel registrations and there will be no need for any resolution mechanism such as auctions.
Explain any cost benefits for registrants you intend to implement (e.g. advantageous pricing, introductory discounts, bulk registration discounts).
Since registrations will be limited to members of the Citadel Family who have the Required License, there will be no market in the second level .citadel registrations and there will be no need to devise cost benefits or discounts for any registrants.
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 10 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?
Applicant will comply with Section 2.10 of the Registry Agreement, although there will not be any need to inform of any price increases since the only registrants will be members of the Citadel Family and will have the Required License in place.