.NFL New gTLD Application

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New gTLD Application Submitted to ICANN by: NFL Reg Ops LLC

 

Application Downloaded On: 11 Sep 2015

 

String: NFL

 

Application ID: 1-1118-57681

 

Applicant Information

 

  1. Full legal name

NFL Reg Ops LLC

 

  1. Address of the principal place of business

345 Park Avenue New York, New York - 10154 US

 

  1. Phone number

+01 212 450 2000

 

  1. Fax number

+01 212 681 7599

 

  1. If applicable, website or URL

 

Primary Contact

 

6(a). Name

Christopher Niemi

 

6(b). Title

Manager, Domain Services, MarkMonitor

 

6(c). Address

 

6(d). Phone Number

+1 208 685 1857

 

6(e). Fax Number

+1 208 389 5771

 

6(f). Email Address

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

 

Secondary Contact

 

7(a). Name

David Jurenka

 

7(b). Title

Vice President, Digital Media Operations, National Football League

 

7(c). Address

 

7(d). Phone Number

(425) 894-4002

 

7(e). Fax Number

(310) 280-9032

 

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).

State of Delaware, USA

 

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.

NFL Enterprises 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

Name

Position

David J. Jurenka Vice President

Douglas P. Paoletti Secretary

Hans L. Schroeder President

 

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

Name

Position

NFL Enterprises 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

 

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

NFL

 

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.

 

 

  1. 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.

 

NFL Reg Ops LLC (“NFL Reg Ops”) foresees no known rendering issues in connection with the proposed .nfl string which it is seeking to apply for as a gTLD.  This answer is based upon consultation with NFL Reg Ops’ preferred backend provider, Neustar, 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 Neustar 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.

 

  1. 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.

 

Founded in 1920 as the American Professional Football Association, the National Football League (ʺNFLʺ) is the most popular American sports league.  The NFL consists of thirty-two Member Clubs (i.e., teams), evenly divided between the American Football Conference and the National Football Conference, and spread out across the United States as follows: Arizona Cardinals, Atlanta Falcons, Baltimore Ravens, Buffalo Bills, Carolina Panthers, Chicago Bears, Cincinnati Bengals, Cleveland Browns, Dallas Cowboys, Denver Broncos, Detroit Lions, Green Bay Packers, Houston Texans, Indianapolis Colts, Jacksonville Jaguars, Kansas City Chiefs, Miami Dolphins, Minnesota Vikings, New England Patriots, New Orleans Saints, New York Giants, New York Jets, Oakland Raiders, Philadelphia Eagles, Pittsburgh Steelers, San Diego Chargers, San Francisco 49ers, Seattle Seahawks, St. Louis Rams, Tampa Bay Buccaneers, Tennessee Titans, and Washington Redskins.  

 

Every year fans descend on stadiums in tremendous numbers to watch NFL teams compete, culminating in the annually most-watched television program in the United States - the Super Bowl. With an average attendance of over 65,000 fans during each game of the 2011-2012 season, the NFL is the best-attended domestic sports league in the world.  Indeed, NFL fansʹ devotion to the Super Bowl (even if their favorite team is not playing) has set American television viewing records in recent years.  Super Bowl XLVI in 2012 was the most-watched TV program in U.S. history with an approximate audience of 111.3M.  The 2012 Super Bowl was also telecast in more than 200 countries and territories worldwide.

 

The NFLʹs popularity does not end with the final play in any given game.  NFL fans support the League year-round wearing team-branded apparel, decorating their homes and offices with branded merchandise, reading the latest news about their favorite players and teams, and ʺdraftingʺ their favorite players to their fantasy football teams.  The market for NFL-related merchandise, ticket sales, advertising, and other products and services is now regularly valued in the billions of dollars.

 

Not surprisingly, the NFLʹs online presence is also tremendously popular.  The NFLʹs principal website, which is associated with the 〈nfl.com〉 domain name, launched in or around 1996.  During the 2011 NFL season, the NFL received an average of 70 million unique visitors per month to its website, syndicated and mobile properties.  NFL fans want the complete fan experience and the NFL seeks to provide it, whether at the stadium, at home, at the store, or on the internet.

 

The marks of the NFL have always been well-protected.  The NFL and its affiliates hold several hundred trademark registrations worldwide that contain or consist of NFL or NATIONAL FOOTBALL LEAGUE.  Additionally, the NFL and its thirty-two Member Clubs hold approximately ten thousand other trademark registrations, including U.S. federal, U.S. state, and foreign trademarks, for other related marks.  

 

Unfortunately, with such high demand and a correspondingly large market, there is an ever-present risk of unscrupulous third-parties who will try to unlawfully benefit from the NFL and NFL fans.  The NFL works tirelessly to prevent the sale of fraudulent NFL game tickets, counterfeit NFL merchandise and other related illegal activities.  The NFL devotes significant resources to policing for counterfeits and taking enforcement actions against counterfeiters, often joining forces with law enforcement. For example, the U.S. Department of Immigration and Customs Enforcement (ʺICEʺ) recently partnered with the NFL and seized roughly $4.8 million in counterfeit merchandise, while the Ontario and Los Angeles international airports intercepted almost 11,000 fake NFL jerseys between September 2011 and January 2012 alone.  Because many counterfeit ticket, video, and merchandise operations are occurring online, secure and authentic web transactions are becoming increasingly important to the NFL.  The NFLʹs Vice President of Legal Affairs recently explained that counterfeiting websites ʺmimic the look and feel of official NFL team websites in order to dupe consumers into believing they are buying legitimate goods from authorized retailers.ʺ  Similarly, unauthorized distribution of NFL game content, whether live or previously recorded, threatens the value of professional football to the NFL, broadcasters, digital media companies, business partners, and fans.  As an NFL representative testified to the US House of Representatives Judiciary Committee, ʺ[e]very year the NFL invests substantially more time and resources dedicated to combating online piracy.ʺ

 

NFL Reg Ops LLC (ʺNFL Reg Opsʺ), the applicant, is an Affiliate of the NFL.  We anticipate that the .nfl gTLD may provide an opportunity to create a more secure and authentic online experience for NFL fans, to introduce more Internet users to the sport of American football, and to protect the NFLʹs intellectual property rights.  Whether purchasing game tickets, checking the latest scores and news, playing NFL-sponsored fantasy football with friends, buying NFL merchandise, watching NFL footage, or anything else fans seek to do in support of the NFL, we hope that an .nfl gTLD will immediately, clearly, and effectively let fans know that they are on an authentic and trustworthy NFL domain.  

 

This .nfl gTLD application is a logical progression in the NFLʹs history of online innovation.  Seeing an opportunity to enhance its online presence and build relationships with fans, advertisers, and other businesses, the NFL took over operation of NFL.com from third-party producers in 2007.  The Senior Vice President of NFL Digital Media and Media Strategy explained: ʺIn a rapidly changing digital landscape, bringing NFL.com in-house provides us greater control of our valuable content and enables us to strategically build the site as a media asset.  Fans can look forward to an even more entertaining, interactive and informative site built upon the expertise of the NFL and its other in-house media outlets such as NFL Network and NFL Films.ʺ  The .nfl gTLD has the potential to integrate marketing, fan interaction, ticket sales, news, merchandise, and other services into a simple .nfl domain that communicates an assurance of a secure and authentic NFL experience.  Similarly, it is possible that, over time, consumers may come to recognize and rely on an .nfl gTLD as a signpost of security and authenticity.  Further, we hope that our decision to allow only NFL Reg Ops, its Affiliates and the NFLʹs Member Clubs to register and use .nfl domains may hasten recognition of the .nfl gTLD as an indication of security and authenticity.

 

We also look forward to the possibility that the .nfl gTLD may create new opportunities for each of the NFLʹs thirty-two Member Clubs, expand the reach of the NFL outside the United States, and generate innovative ways for the NFL to expand its charitable activities.  An .nfl gTLD that is open only to a limited number of Registrants-specifically, NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs-may embody a simple and unique way to integrate team websites with that of the NFL, while still maintaining the highest NFL standards for content and security.  Similarly, .nfl may enable the NFL to eventually reach foreign audiences more easily with the most relevant news, statistics, merchandise, and advertising in their own languages, potentially with domain names in their own language scripts.  Finally, we hope that it will provide a new opportunity for the NFL to continue charitable and social campaigns to foster community citizenship and philanthropy.  

 

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

 

How do you expect that your proposed gTLD will benefit registrants, internet users, and others?

 

We expect that the proposed .nfl gTLD will benefit Internet users and others by providing a more secure and authentic experience for fans and others who use NFL-related websites.  We plan  that NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs will be the only registrants of .nfl domain names.  As explained in the section above, we expect the .nfl gTLD to benefit a variety of NFL and fan interests.

 

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

 

The goal of the proposed .nfl gTLD tracks its area of specialty:  To have an opportunity to create a more secure and authentic online experience for NFL fans, to introduce more Internet users to American football, and to protect the NFLʹs intellectual property rights.   The opportunity to combine many, if not all, existing NFL websites under a single, branded gTLD may assist us in providing a more satisfying, secure, and authentic online experience to NFL fans and NFL partners.  It is our goal that the service levels and reputation of the .nfl gTLD be of the highest level - commensurate with the goodwill and reputation of the world-famous NFL brand.    

 

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

 

Worldwide, there are no sports teams or leagues currently utilizing team or league specific TLDs.  The introduction of an .nfl gTLD clearly changes the status quo.  An .nfl registry has the potential to give fans, Internet users, and business partners a new and unique portal dedicated to all of the different NFL online offerings, all in a more secure online environment to communicate to users that the online NFL experience is safe and authentic.

 

An .nfl gTLD also adds differentiation to the current space because we anticipate that the only registrants and users of the .nfl gTLD will be NFL Reg Ops, its Affiliates, and the NFLʹs thirty-two Member Clubs. Restricting registration and use of the .nfl gTLD may also provide a new platform for innovation.  For instance, it may allow us to create a simple and user-friendly second-level domain name hierarchy for fans, Affiliates, and others to easily reach team, ticket, advertising, news, live content, charitable, merchandise, and interactive pages.  And, of course, an .nfl gTLD will enable the NFL to continue its history of innovation and unique user experiences in ways not yet known.

 

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

 

We want NFL fans, our Affiliates, and business partners, as well as general Internet users, to expect that they can rely on and trust NFL websites.  Accordingly, we hope that the .nfl gTLD will provide the opportunity to create a more secure and authentic online experience for NFL fans, to introduce more Internet users to American football, and to protect the NFLʹs intellectual property rights.   These goals would apply regardless of whether an Internet user is trying to purchase tickets or merchandise, seeking NFL news, checking the standings of his⁄her fantasy football team, or watching videos of his⁄her favorite games.  

 

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

 

NFL Reg Ops intends to adopt and carry out policies for the registration and use of .nfl domain names.  We will revise and update these policies (a) in accordance with our interests and those of our Affiliates and the NFL Member Clubs; and (b) as needed to comply with requirements of ICANN Consensus Policies and Temporary Policies.  These policies cover eligibility requirements for registration and use of .nfl domain names, what .nfl domains may be registered, and how .nfl domains may be used.  

 

As stated previously, it is anticipated that only the Applicant, its Affiliates, and the thirty-two NFL Member Clubs (the ʺEligible .nfl Registrantsʺ) will be permitted to register and use .nfl domain names.  Before any .nfl domain name is registered, we will confirm that the potential registrant is one of the Eligible .nfl Registrants.    

 

All .nfl domain names will be registered in the name of the Eligible .nfl Registrant.  No .nfl domain name will be transferred, assigned, or licensed to any third party that is not an Eligible .nfl Registrant.

 

Further, we will ensure that each .nfl domain name meets the following criteria:

 

  1.  It is not the label ʺEXAMPLEʺ - either at the second level or any other level in which we may allow registrations.
  2.  All domain names must be at least three characters long, unless we reach a specific agreement with a government and country-code manager to use a two-character domain or our proposal to allow registration and use of such names based on implementation of measures to avoid confusion with the corresponding country codes is approved.  
  3.  No .nfl domain name may be longer than 63 characters.
  4.  All .nfl domain names shall consist only of the letters a-z, the digits 0-9, and a hyphen.
  5.  .nfl domain names shall not start or end with a hyphen, but must start and end with an alphanumeric character.
  6.  Hyphens will not be included in the third and fourth position unless they represent valid internationalized domain names in their ASCII encoding (tagging).
  7.  No protected country or territory name shall be used, as contained in the internationally recognized lists set forth in Specification 5 to the New gTLD Registry Agreement, unless the NFL reaches agreement with the applicable government(s) or pursuant to review and approval by ICANNʹs Governmental Advisory Committee and ICANN.
  8.  No domain name can match any ICANN-reserved strings.

 

The .nfl registry will support Internationalized Domain Names (ʺIDNʺ) at the second level.

 

All .nfl domain names shall be used solely for purposes that are, in our judgment and discretion, consistent with our business interests.  No .nfl domain name shall be used in a way that knowingly infringes any third-party intellectual property rights.

 

All WHOIS data for all .nfl will be complete and accurate.

 

  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.

 

NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs, recognize that privacy is an important issue to users of existing NFL websites and potential future .nfl websites.  NFL Reg Ops is a corporation organized in the United States, and will comply with all applicable data collection and privacy laws.  Moreover, we intend to fully comply with the Personal Data obligations outlined in Section 2.17 of the new gTLD Registry Agreement.  

 

Privacy protection measures may potentially include: (1) use of appropriate levels of encryption; (2) compliance with the EU Safe Harbor framework as set forth by the United States Department of Commerce regarding the collection, use, and retention of data from the European Union (see http:⁄⁄www.export.gov⁄safeharbor⁄); (3) regular testing procedures; (4) opt-in opportunities to receive third party offers; (5) restricted access to personal information to those who need it to do their jobs; and, among others, (6) the ability for website users to correct, update, or remove personal data.

 

Also, describe whether and in what ways outreach and communications will help to achieve your projected benefits.

 

We anticipate that we will conduct outreach and communications in a way and scale consistent with the objectives, standards and policies described in this gTLD application.

 

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?

 

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 imposed upon consumers?

 

We believe that our operation of a TLD registry that is limited to NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs is unlikely to have any social costs and negative consequences.  We expect that our decision to limit the .nfl registry to a small and well-defined set of registrants will eliminate or minimize any social costs and negative consequences that may exist in a more open registry.

 

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

 

Because only NFL Reg Ops, its Affiliates, and the thirty-two NFL Member Clubs will be permitted to register and use .nfl domains, we do not expect that there will be multiple applications for specific domain names.  As such, there will not be multiple applications for which any resolution will be necessary.

 

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

 

We anticipate that domains within the .nfl registry will not be sold or marketed to the general internet community.  Because of this limited universe of registrants, we do not intend to implement any registration incentives.

 

  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.

 

We are committed to the registration terms contained in the Registry Agreement, including Section 2.10.  Because we do not anticipate selling domains within the .nfl registry, we currently do not intend to make contractual commitments regarding length of registration or price escalations.