.travelers New gTLD Application

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New gTLD Application Submitted to ICANN by: Travelers TLD, LLC

Application Downloaded On: 14 Aug 2014

String: travelers

Application ID: 1-1841-77153

Applicant Information

1. Full legal name

Travelers TLD, LLC

2. Address of the principal place of business

One Tower Square Hartford, Connecticut - 06183 US

3. Phone number

+01 860 277 5150

4. Fax number

+01 860 277 5147

5. If applicable, website or URL

Primary Contact

6(a). Name

Gretchen Olive

6(b). Title

Director of Policy & Industry Affairs

6(c). Address

6(d). Phone Number

01 3026365401

6(e). Fax Number

01 3026365454

6(f). Email Address

This email address is being protected from spambots. You need JavaScript enabled to view it.

Secondary Contact

7(a). Name

Brian Jay Winterfeldt

7(b). Title

Partner, Steptoe & Johnson LLP

7(c). Address

7(d). Phone Number

+1 202 429 6260

7(e). Fax Number

+12024293902

7(f). Email Address

This email address is being protected from spambots. You need JavaScript enabled to view it.

Proof of Legal Establishment

8(a). Legal form of the Applicant

Limited liability company

8(b). State the specific national or other jurisdiction that defines the type of entity identified in 8(a).

Delaware, United States of America

8(c). Attach evidence of the applicant's establishment.

Attachments are not displayed on this form.

9(a). If applying company is publicly traded, provide the exchange and symbol.

9(b). If the applying entity is a subsidiary, provide the parent company.

9(c). If the applying entity is a joint venture, list all joint venture partners.

Applicant Background

11(a). Name(s) and position(s) of all directors

Name

Position

Julie Anne Trowbridge Dillman Director

Paul Edward Munson Director

11(b). Name(s) and position(s) of all officers and partners

Name

Position

David Mark Bearl Director-Treasury

Julie Anne Trowbridge Dillman President

Larry J. Mills Assistant Treasurer

Maryellen Prudhomme Assistant Secretary

Sheila M. Brown Vice President-Finance & Treasurer

Todd Douglas Ellingson Assistant Treasurer

Wendy Constance Skjerven Secretary

11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares

Name

Position

The Travelers Indemnity Company 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

13. Provide the applied-for gTLD string. If an IDN, provide the U-label.

travelers

14A. If applying for an IDN, provide the A-label (beginning with "xn--").

14B. 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.

14C1. If an IDN, provide the language of the label (in English).

14C2. If an IDN, provide the language of the label (as referenced by ISO-639-1).

14D1. If an IDN, provide the script of the label (in English).

14D2. If an IDN, provide the script of the label (as referenced by ISO 15924).

14E. If an IDN, list all code points contained in the U-label according to Unicode form.

15A. If an IDN, upload IDN tables for the proposed registry.  An IDN table must include:

the applied-for gTLD string relevant to the tables,

the script or language designator (as defined in BCP 47),

table version number,

effective date (DD Month YYYY), and

contact name, email address, and phone number.

Submission of IDN tables in a standards-based format is encouraged.

15B. Describe the process used for development of the IDN tables submitted, including consultations and sources used.

15C. List any variants to the applied-for gTLD string according to the relevant IDN tables.

16. 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.

Applicant anticipates the introduction of this TLD without operational or rendering problems. Based on a decade of experience launching and operating new TLDs, Afilias, the back-end provider of registry services for this TLD, is confident the launch and operation of this TLD 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 this TLD;

 - 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 this TLD

17. OPTIONAL.

Provide a representation of the label according to the International Phonetic Alphabet (http://www.langsci.ucl.ac.uk/ipa/).

18A. Describe the mission/purpose of your proposed gTLD.

Travelers offers a wide variety of insurance and surety products, as well as risk management services, to numerous types of businesses, organizations and individuals. Our products are distributed primarily through U.S. independent insurance agents and brokers. We have an expanding market presence internationally with business operations in Canada, U.K., Ireland and a joint venture in Brazil with JMalucelli.

Company Overview

• Second-largest writer of commercial U.S. property casualty insurance*
• Third-largest writer of U.S. personal insurance through independent agents*
• Serves millions of customers
• Total assets of approximately $105 billion, shareholders’ equity of $24 billion and total revenue of $25 billion, as of December 31, 2011.
• A component of the Dow Jones Industrial Average
• Traded on the NYSE under the symbol “TRV”
• More than 30,000 employees
• Representatives in every U.S. state, Canada, Ireland and the U.K.
• Represented by approximately 13,000 independent agencies and brokerages countrywide

* SNL Statutory Filings.  Based on 2010 direct written premium.

We will initially conduct consumer marketing, technical research along with monitoring of market trends and consumer behavior to determine the most effective and secure way for Travelers to market and provide its insurance and financial services through the TLD.  During this initial research period, Travelers will not use the TLD to provide any information or services to the public, but reserves the right to use the TLD for internal purposes, including consumer and security-related testing of the TLD for later public use.  After the research is completed, Travelers reserves the right to continue to use the TLD only for internal purposes; or if an adequately secure public use is desired and proven viable, to expand use of the TLD accordingly.

The proposed .travelers gTLD is a restricted TLD that would, if ever used with the public, serve the purpose of enhancing and expanding Travelers’ ability to one or more of the following:

• create a connected digital presence and brand experience for clients and business partners;
• deliver product and service marketing⁄advertising;
• facilitate secure interaction and communication with individuals and entities with whom Travelers has a business relationship;
• improve business operations;
• simplify Internet user navigation to information about Travelers products and services; and⁄or
• demonstrate market leadership in protecting client privacy and confidential information online; and meet future client expectations and competitive market demands.

18B. How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

1. What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

• The goal of the proposed .travelers gTLD in terms of specialty, service levels and reputation are:

o Specialty – Travelers is an insurance company.  Travelers provides policyholders protection against financial losses resulting from a variety of hazards they may experience. In the course of its business with policyholders and agents, personal and confidential information is collected and shared between authorized parties.  To further demonstrate Travelers commitment in the area of data confidentiality and privacy within the insurance industry, if the TLD is used with the public, Travelers intends to utilize the .travelers  gTLD to create a restricted, exclusively-controlled online environment for clients and⁄or agents with the goal of further securing the collection and⁄or transmission of personal and⁄or other confidential data required for insurance policy-management, claims processing and⁄or other insurance-related activities.  

o Service levels – Due to the global nature and scope of Travelers’ business, hundreds of thousands of interactions between policyholders, affiliated agents and Travelers staff and systems occur every day.  Many exchanges occur offline and require manual follow-up.  One of the goals of the proposed .travelers gTLD, if used with the public, is to create a restricted, exclusively-controlled online environment for clients and agents which will increase client confidence and⁄or trust in conducting business online.  Through greater use of online tools by clients, Travelers expects to further streamline business processes, reduce turn-around times, provide more personalized service and⁄or improve overall client service delivery and⁄or satisfaction.

o Reputation – Travelers has a reputation of stellar client service, innovation and market leadership, particularly in the online environment. With the online channel growing in importance, one of the goals of the proposed .travelers gTLD, if used with the public, is to position Travelers to meet future client expectations and⁄or competitive market demands to ensure it can continue to grow its reputation in the insurance industry and in the global marketplace.

The TLD, if used with the public, will further strive to be known for ensuring only Travelers or its affiliates register and control domain names in the TLD, that those domain names are securely used for Travelers-related purposes, that the Whois is thick and reliable, and that the Registry is responsive to legal rights owners.  When Internet users visit a website within the TLD, they should know that Travelers will be the entity providing its world-renowned services, and that they can expect the highest level of online service and security.  In all, Travelers will strive to be known as an exemplary and model domain name services citizen through the use of the TLD.

1. What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

Travelers intends to operate the proposed .travelers gTLD as a restricted TLD and, as such, domain names will not be commercially offered for registration⁄use by the general public.  Thus, Travelers and⁄or its affiliates will have exclusive ownership and control over all second-level registrations within the TLD and their use.   As a result, we believe the proposed .travelers gTLD will add to the current names space in three (3) areas:

• Competition – As technology advances, so do client expectations of companies online.  They expect that companies will utilize the latest and greatest technology and online practices to improve the user experience, protect their information and deliver quality service.  Travelers anticipates that the proposed .travelers gTLD, if used with the public, will likely enable Travelers to communicate, interact and protect data in ways and under conditions not possible under the existing namespace, and thus, enabling them to meet future client expectations and⁄or competitive market demands. These innovations relating to Travelers providing online goods and services will likely incentivize existing and new top-level domains and competing goods and service companies that operate on existing and new top-level domains to also improve the security and⁄or quality of the goods and services they provide online and⁄or to accelerate the introduction of new goods and services in order to continue attracting new customers.  Thus, the entry of the TLD, if used with the public, will benefit consumers by increasing the likelihood of the successful introduction of new and innovative online goods and services.

• Differentiation – While today companies like Travelers can register brand strings at the second-level (e.g., travelers.com), the proliferation of cybersquatting and typosquatting has placed a great burden on consumers to carefully tread online because there is no guarantee on the face of the domain name string that what looks like a branded website is indeed an authorized website of the brand owner.  The proposed .travelers gTLD, if used with the public, will enable Travelers to utilize a branded TLD to distinguish on the face of the domain name alone whether the site is an authorized Travelers site because the gTLD will be a restricted, exclusively-controlled online environment where only authorized Travelers web properties and e-mail will exist and operate online.

• Innovation - The proposed .travelers gTLD, if used with the public, as a restricted TLD, will provide Travelers with a new platform on which to build future innovation of its online brand presence.

One of the most important issues for Travelersʹ customers and clients is security.  The TLD, if used with the public, will allow Travelers more control over its online presence and thus the opportunity to provide information, goods and services to its clients and customers in a more secure and technologically advanced way and⁄or allow Travelers to implement technical advances that may not have been available before in a less secure environment.  

With the TLD, Travelers can test the use of the TLD with consumers to facilitate their desired Web experience and to ensure that it meets the highest possible security standard.  This innovation will promote competition in the Internet space and⁄or provide higher levels of service to all users and customers.  Moreover, the TLD will be innovative in that it will allow more people to have greater access to a dedicated and secure top-level domain dedicated to Travelers goods and services.  The TLD will also allow Travelers to continue to work more securely work in communities where access to financial services is limited by making it easier to access its banking and financial services in a trustworthy way.

1. What goals does your proposed gTLD have in terms of user experience?

• Travelers operates in an industry that has been the target of cybersquatting, typosquatting, phishing, pharming and identity theft scams due to the personal and confidential data that is utilized and stored to provide insurance and financial-related products and services to consumers.  This malicious online conduct has lessened the trust and confidence of consumers to share information and transact business online.  Thus, the proposed .travelers gTLD, if used with the public, has the following user experience goals:

o Enhance and better define Travelers global branding footprint to ensure Internet users understand the connection and avail themselves of the benefits of the many related products and services offered by Travelers across markets;

o Create a simplified manner in which clients, prospects, agents, employees, directors, and⁄or investors can interact with Travelers in the online digital space;

o Foster trust and  confidence in online interactions by customers, prospects , agents, employees, directors and⁄or investors with Travelers by reducing the risk of Internet users being misled about, believing and⁄or acting on erroneous information about Travelers, its affiliates and⁄or its products and services presented online by unauthorized 3rd parties; and

o Simplify online navigation to Travelers products, services and affiliate information.

1. Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

DOMAIN NAME REGISTRATION POLICY

CLOSED TLD

The .travelers gTLD is a restricted TLD established by and for the exclusive use of Travelers and its affiliates for the purpose of, if it is used with the public, enhancing and expanding Travelers’ ability to:

• create a connected digital presence and brand experience for clients and business partners;
• deliver product and service marketing⁄advertising;
• facilitate secure interaction and communication with individuals and entities with whom Travelers has a business relationship;
• improve business operations;
• simplify Internet user navigation to information about Travelers products and services;
• demonstrate market leadership in protecting client privacy and confidential information online; and
• meet future client expectations and competitive market demands.

Registration within the .travelers TLD is limited to authorized employees of Travelers who are authorized in writing by the Travelers’ CIO or General Counsel or their designee to register domain names on behalf of Travelers for the purpose outlined above.  Travelers, however, reserves the right to sell, distribute, or transfer control or use of any domain name registrations in the TLD to any third party that is an Affiliate of Applicant under the control of Applicant for uses as specified by Applicant.  Affiliate will be defined for the purposes of this application as (i) a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, Applicant, and (ii) “control” (including the terms “controlled by” and “under common control with”) means the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of a person or entity regarding the use of a domain name within the TLD, whether through the ownership of securities, as trustee or executor, by serving as an employee or a member of a board of directors or equivalent governing body, by contract, by credit arrangement or otherwise.

REGISTRATION PROCESS

In its registration agreement, Registrar shall require authorized Travelers’ employees, otherwise known as Registered Name Holder to:

• consent to the use, copying, distribution, publication, modification and other processing of Registered Name Holderʹs Personal Data by Travelers and its designees and agents in a manner consistent with ICANN’s consensus policies;
• submit to rights protection proceedings, such as the Uniform Rapid Suspension System (URS),  provided for under ICANN’s New gTLD policies;
• submit to proceedings commenced under ICANNʹs Uniform Domain Name Dispute Resolution Policy (ʺUDRPʺ);
• immediately correct and update the registration information for the Registered Name during the registration term for the Registered Name;
• agree to be bound by the terms and conditions of the initial launch of the Registry TLD, including without limitation the sunrise period and the land rush period, and the Sunrise Dispute Resolution Policy; and
• acknowledge and agree that Travelers reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the Registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Travelers as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by Travelers or any Registrar in connection with a domain name registration. Travelers also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.

RESTRICTIONS ON REGISTERED NAMES

In addition to complying with ICANN standards, policies, procedures, and practices limiting domain names that may be registered, Registrar agrees to comply with applicable statutes and regulations limiting the domain names that may be registered.

1. 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.

The proposed .travelers gTLD will be a restricted TLD where Travelers will have exclusive control.  Corporate contact information will be clearly listed in the WHOIS record for each registration within the TLD.  Thus, there are no measures that need to be proposed to protect the privacy or confidential registration information of registrants⁄users of the TLD.  However, Travelers is investing in the proposed .travelers gTLD, if used with the public, to further demonstrate its commitment and market leadership with regard to privacy of consumer data (as evidenced by its current data privacy policy, below), as Travelers believes the utilization of the proposed new gTLD could position the company to more fully meet online challenges that may threaten the security of customer data in the future.  Travelers maintains its privacy policy online at https:⁄⁄www.travelers.com⁄w3c⁄legal⁄privacypolicy.html. Any changes to it during the life of the TLD will apply to any user information obtained by the TLD.

Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Prior to using the proposed .travelers gTLD for product and service marketing⁄advertising, interaction and communication with individuals and entities with whom Travelers has a business relationship, and⁄or implementing new online navigation strategies, among other purposes, if the TLD is ever used with the public, Travelers anticipates conducting a multi-faceted outreach that will likely involve multiple communication channels, including but not limited to TV, radio, mobile, print, social media, direct mail, online advertising and marketing via our active, client and affiliate-facing websites and⁄or other public relations activities to:

• Further communicate Travelers’ commitment to online consumer safety and data privacy;
• Inform the market of Travelers’ ownership and planned use of the proposed .travelers gTLD;
• Clearly define the expected benefits to clients, prospective clients, affiliates and Internet users at large.  

Future outreach and communications activities may be carried out as needed to reaffirm and clarify the above.  Travelers recognizes outreach and communication are important to building trust and confidence in the legitimacy of the TLD.

18C. 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)? What other steps will you take to minimize negative consequences/costs imposed upon consumers?

1. How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first serve basis?

• There will not be multiple applications for a particular domain in the proposed .travelers TLD because this will be a restricted TLD where only authorized individuals will be able to seek registrations on behalf of Travelers and potentially its affiliates.

1. Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

• This question is not applicable to a restricted TLD, like the proposed .travelers TLD.

1. 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.

• The proposed .travelers TLD will be a self-funded, restricted TLD available only to Travelers and potentially its affiliates.  Thus, there will be no per domain name registration cost incurred by any party for this TLD and thus, no price changes and⁄or escalations for which registrants will need to be notified.