.STAPLES New gTLD Application
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New gTLD Application Submitted to ICANN by: Staples, Inc.
Application Downloaded On: 12 Feb 2016
String: STAPLES
Application ID: 1-1954-61706
Applicant Information
- Full legal name
Staples, Inc.
- Address of the principal place of business
500 Staples Drive Framingham, Massachusetts - 01720 US
- Phone number
+1 508 253 3334
- Fax number
+1 508 253 7805
- If applicable, website or URL
http://www.staples.com/
Primary Contact
6(a). Name
Michael Dowd
6(b). Title
Senior Counsel, Global Technology, Security and Privacy
6(c). Address
6(d). Phone Number
+1 508 253 0914
6(e). Fax Number
+1 508 253 7805
6(f). Email Address
Secondary Contact
7(a). Name
Eileen White
7(b). Title
Director Global ecommerce Strategy
7(c). Address
7(d). Phone Number
+1 508 253 6812
7(e). Fax Number
+1 508 253 8946
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Staples, Inc.
8(b). State the specific national or other jurisdiction that defines the type of entity identified in 8(a).
State of 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.
New_York_Stock_Exchange / SPLS
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
Arthur M. Blank Director
Basil L. Anderson Director
Carol Meyrowitz Director
Elizabeth A. Smith Director
Justin King Director
Mary Elizabeth Burton Director
Paul Walsh Director
Robert C. Nakasone Director
Robert E. Sulentic Director
Ronald L. Sargent Chairman of the Board
Rowland T. Moriarty Director
Vijay Vishwanath Director
11(b). Name(s) and position(s) of all officers and partners
Name
Position
Christine T. Komola Senior Vice President and Corporate Controller
Cynthia Pevehouse Senior Vice President, General Counsel & Secretary
Demos Parneros President-U.S. Stores
John J. Mahoney Vice Chairman and Chief Financial Officer
Joseph G. Doody President-Staples North American Delivery
Michael A. Miles, Jr. President and Chief Operating Officer
Ronald L. Sargent Chief Executive Officer
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.
STAPLES
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.
- 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.
Staples, Inc. foresees no known rendering issues in connection with the proposed .STAPLES gTLD for which it is applying. This answer is based upon consultation with Staples’ selected back-end provider, Neustar, Inc., which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, the following data points were analyzed:
-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 Verisign has encountered during the last decade launching new gTLDs;
-Character type and length;
-ICANN supplemental notes to Question 16; and
-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/).
18A. Describe the mission/purpose of your proposed gTLD.
18.1 Mission and Purpose of .STAPLES
Staples, Inc. (“Staples”) is the worldʹs largest office products company and a trusted source for office solutions. Staples provides products, services and expertise in the categories of office supplies, technology, furniture, Copy & Print, and cleaning and breakroom. In 2011, Staples had annual total sales of $25 billion and ranked second in the world in eCommerce sales. Staples customers include small and medium businesses as well as Fortune 100 companies. Staples has a presence in more than 26 countries throughout North and South America, Europe, Asia and Australia. Staples’ headquarters is located outside of Boston, Massachusetts. The preservation of the Staples brand is of paramount importance to Staples in all aspects of its operations, including on the Internet.
Staples content is accessible in the .COM gTLD, as well as in many ccTLDs.
The intended future mission and purpose of the .STAPLES gTLD is to serve as a trusted, hierarchical, and intuitive namespace provided by Staples for Staples’ customers and Internet users in general.
Although ICANN has not specifically recognized a .BRAND gTLD specification in the current version of the Applicant Guidebook, it is widely anticipated within the brand-owner community that this will become a specialty subset of gTLDs. The .STAPLES gTLD is intended to be one of those .BRAND gTLDs, with the goal of protecting Staples’ online presence and identity, expanding its marketing and promotion efforts, providing a secure channel for online products and services, and offering a platform through which to consolidate many of the intellectual property activities of Staples.
Staples intends to initially limit registration and use of domain names within the .STAPLES gTLD to Staples and its qualified subsidiaries and affiliates. This initial limited use will allow Staples to establish its operations and achieve full sustainability. This limited distribution, coupled with the other requirements set forth in Specification 9 of the template Registry Agreement, is intended to exempt Staples from its annual Code of Conduct Compliance requirements.
After Stage 3 (see below), Staples will evaluate whether opportunities exist to carry out the business strategy for the .STAPLES gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to parties other than Staples and its qualified subsidiaries and affiliates.
Staples currently plans a four-stage rollout for the .STAPLES gTLD:
Stage 1
The initial stage of implementation of the gTLD will involve Staples registering a limited number of .STAPLES second-level domain names.
This initial use will provide Staples’ IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .STAPLES gTLD domain names, interoperability with various software and Web-based applications, and unbroken and secure use of all names. This initial allocation will also allow the appropriate Staples staff to coordinate with the internal and external staff responsible for the delegation and setup phases of the .STAPLES gTLD to ensure a proper transition from delegation to full operation.
Stage 2
Once all testing has been successfully completed, Staples will begin allocating domain names in .STAPLES for more widespread internal corporate use. During this same period of time, Staples will begin evaluating strategies to potentially migrate traffic away from its current patchwork network of second-level domain names, which are registered in a variety of TLDs, to Staples’ new gTLD.
It is in Stage 2 that Staples will evaluate expanding the operations of the gTLD to permit registration by other registrants, such as licensees and⁄or strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other parties, this expansion is currently planned to take place during Stage 3. However, any expansion would be conditioned upon a review of Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Staples’ business model.
Stage 3
Depending on the analysis of the evaluations undertaken in Stage 2, Staples may implement the permanent migration of Internet traffic away from the TLDs in which Staples’ domain names are currently registered, and toward the .STAPLES gTLD. It is in this stage that Staples also may implement its decision to extend registration rights to licensees and⁄or strategic partners, depending upon compliance with Specification 9 as noted above. The dates of such expansion are subject to change depending upon business, strategic, and industry factors at the time.
After consideration of the following factors: analysis of Staples’ existing domain name portfolio, internal analysis of marketing initiatives, and the fact that Staples will have full control over the number of registrations in the .STAPLES gTLD namespace, Staples is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.
Stage 4
Based on its experience with any expansion implemented in Stage 3, Staples will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, potentially including customers of Staples. It is anticipated by Staples that changes to the domain name industry, and particularly the impact of .BRAND gTLDs, will take at least five years to be realized and assessed. Any decision to expand the gTLDs beyond corporate, qualified subsidiary and affiliate, and licensee use will take into account this experience as well as the technical analysis of potential expansion. The potential use of the .STAPLES gTLD by these or other business segments will primarily be driven by Staplesʹ future business strategies.
Utilizing current projections based upon Staplesʹ existing businesses, future business plans, current domain name portfolio, and other strategic factors, Staples estimates that second-level domain name registrations will be in line with the projections set forth in the financial template provided in the answer to Question 46 of this application.
18B. How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
Staples believes that the proposed .STAPLES gTLD has the potential to offer numerous benefits to Internet users and consumers, and to establish a trusted online marketplace for the millions of customers using Staples’ online resources to learn about Staplesʹ brands and purchase Staples’ products and solutions.
In addition, the .STAPLES gTLD will provide Staples and its qualified subsidiaries and affiliates with short and memorable Internet addresses and increased ability to navigate to information about Staples products and solutions, while minimizing the cost and need for defensive registrations because domain names within the .STAPLES gTLD will only be allocated by Staples to itself as well as its qualified subsidiaries and affiliates.
Currently, Staples operates a number of corporate websites using a combination of second-level and top-level domain names. A representative sampling of Staples websites that incorporate geographical identifiers into domain names include:
Staples.ca
Staples.cn
Staples.co.uk
Staples.fr
Staples believes that a .STAPLES gTLD is intended to provide an online single-source identifying function for its global customers, instead of the present approach Staples must currently resort to as it expands into different markets around the world, which consists of registering the domain names that are available, rather than those that may be the most intuitive.
18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
The primary mission and purpose of the .STAPLES gTLD is to provide a trusted, hierarchical, and intuitive online marketplace in which to aggregate Staples content and other offers and services. As the technology for delivering such content and services evolves, Staples has continued to pursue and expand upon new opportunities to distribute content to consumers, in the U.S. and internationally, on a variety of platforms, including the Internet and mobile devices, among others. Staples believes that the .STAPLES gTLD has the potential to provide an innovative, virtual avenue that will deepen and broaden its relationship with online audiences.
Most importantly, the gTLD is intended to provide access to Staples’ products and online content in a namespace devoid of piracy, cybersquatting, and other malicious activities. Providing consumers with a trusted experience is paramount to Staples. The .STAPLES gTLD will be used to further that goal. Given the high saturation of brand and informational websites, including many that offer misleading or outright incorrect information to users, the .STAPLES gTLD could help ensure that current and prospective Staples customers are receiving authorized and up-to-date information.
While public companies such as Staples fight a constant battle to protect their brand and image online, the .STAPLES gTLD is intended to offer consumers a safe and intuitive means of accessing authorized content from Staples and its qualified subsidiaries and affiliates.
18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
As a branded gTLD, the primary driving factors behind .STAPLES are differentiation and innovation. The success of .STAPLES will not be measured by the number of domain names registered. Instead, it will be measured by the level of consumer recognition and trust that is placed in the gTLD.
Using this benchmark, Staples will strive to build consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.
As noted above, Staples is the largest office products company in the world, and is ranked second in the world in eCommerce sales. The .STAPLES gTLD has the potential to serve as a cornerstone of Staplesʹ online strategy, if the potential benefits that ICANN has projected become a reality.
18.2.3 What goals does your proposed gTLD have in terms of user experience?
Staples believes that the .STAPLES gTLD is intended to provide a single, trusted ecosystem experience for the millions of consumers worldwide that access its online content for information as well as commerce. In addition to providing consumers with short, memorable, and intuitive domain names, Staples will substantially lower the risk of users encountering infringing or pirated content within the .STAPLES gTLD.
The initial use of the .STAPLES gTLD will involve Staples registering a conservative number of second-level domain names. This initial use will provide Staples’ IT and security personnel the ability to run a number of tests to ensure seamless and secure access to the Staples websites, and interoperability with various software and Web-⁄mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Staples plans to begin allocating domain names for internal corporate use and may redirect new .STAPLES domain names to pre-existing content. This phased rollout will likely take place over a multi-year period, but is subject to change depending upon a range of external factors, and will be in line with Staples’ marketing strategy and technology needs.
18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
The .STAPLES gTLD is currently intended to be exclusively used by Staples and its qualified subsidiaries and affiliates. Because of this condition precedent, any registration and use requirements are more appropriately vested in these corporate⁄affiliate agreements and not in a domain name registration agreement.
While Staples will make all reasonable efforts to comply with ICANN’s policies and procedures, the Staples mark is a valuable brand and well-known, the protection of which is of paramount importance; therefore, any registration and use requirements (e.g., trademark quality control provisions) must vest in these other agreements.
Notwithstanding these concerns, Staples will make all reasonable efforts to incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each subsidiary and affiliate will execute.
18.2.5 Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.
As a global company with over 25 years of operating history, Staples recognizes first hand that this is an evolving area of law in which there are no international standards. Staples respects the privacy of its customers and other consumers. The company employs a variety of physical, electronic, contractual, and managerial safeguards to protect personal and confidential information in its properties and on its websites. Staples will take similar precautions to protect registrant and user data in its possession that is associated with the .STAPLES gTLD.
In addition, Staples intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators.
The template Registry Agreement states, “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (“Personal Data”) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.ʺ
18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.
Staples sees the potential for this gTLD to serve as a component of its future online strategic initiative; however, there remain a number of unanswered questions concerning consumer recognition and adoption of new gTLDs in the marketplace that first must be fully answered to Staples’ satisfaction.
Staples plans to start using these domain names primarily as redirects to existing .COM domains. After careful analysis and study of a targeted pilot rollout using the new .STAPLES domains as addresses, Staples may plan to engage in a broader, strategic initiative, should the results be positive. The actual usage of .STAPLES domain names will dictate what public communications and consumer outreach may be done to encourage navigation to the .STAPLES gTLD. This is not limited to, but may include, advertising, media outreach, and email campaigns.
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?
18.3.1 What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?
Staples’ proposed operating rules to initially limit registration to Staples and its qualified subsidiaries and affiliates will provide a number of benefits, as well as a trusted online environment for consumers of Staples content and other information and services. Trademark and brand ownersʹ costs will be mitigated, since there will be no need to defensively register second-level domains in .STAPLES. In addition, this verified ecosystem will provide consumers with a single, trusted source for Staples content with a substantially lower risk of exposure to phishing, fraud, and⁄or other Internet scams, thus reducing the level of consumer vulnerability.
18.3.2 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
Staples believes that the proposed operation of the .STAPLES gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to consumers.
18.3.3 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Staples does not envision multiple applicants for the same domain name, as domain names will only be allocated to Staples and its qualified subsidiaries and affiliates, at least for the first three years of operation.
18.3.4 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
Staples does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the mission and purpose of the .STAPLES gTLD as a trusted online source identifier for Staples and its qualified subsidiaries and affiliates. Moreover, it is the current intention of Staples to provide domain name registrations to Staples and its qualified subsidiaries and affiliates, at no cost, though the company reserves the right to reevaluate this decision and may choose to impose a nominal fee in the future.
18.3.5 Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
Staples is committed to providing the domain name registration periods set forth in the Registry Agreement. However, as noted above, the registration and use of a .STAPLES domain name is conditional upon a separate affiliate relationship with Staples.
Therefore, providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate. Additionally, as noted above, the current business model envisions Staples providing domain name registrations at no cost.
Staples acknowledges that the current template Registry Agreement requires that the Registry Operator “shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar.” However, Staples and its qualified subsidiaries and affiliates, as the sole registrants within the .STAPLES gTLD, intend to only register domain names on an annual basis through a single registrar.
This is done to better account for costs on an annual basis as well as to provide for more concise financial statements in Question 46 of this application (e.g., no multi-year registration or deferred revenue).