.GUARDIAN New gTLD Application
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New gTLD Application Submitted to ICANN by: The Guardian Life Insurance Company of America
String: GUARDIAN
Originally Posted: 13 June 2012
Application ID: 1-1298-37058
Applicant Information
- Full legal name
The Guardian Life Insurance Company of America
- Address of the principal place of business
7 Hanover Square
New York New York 10004
US
- Phone number
+1 212 598 8000
- Fax number
+1 212 919 2690
- If applicable, website or URL
Primary Contact
6(a). Name
Joshua Bourne
6(b). Title
Managing Partner
6(c). Address
6(d). Phone Number
+1 202 223 9252
6(e). Fax Number
6(f). Email Address
Secondary Contact
7(a). Name
Karen Einsidler
7(b). Title
Vice President, Investment and Real Estate Counsel
7(c). Address
7(d). Phone Number
+1 212 598 8792
7(e). Fax Number
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Mutual Company
8(b). State the specific national or other jursidiction that defines the type of entity identified in 8(a).
New York, 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.
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
Deanna Marie Mulligan Director
Deborah Leigh Duncan Director
Donald Cramer Waite III Director
James Ernest Daley Director
John Arthur Somers Director
John Joseph Brennan Director
Lloyd Eugene Campbell Director
Nancy Elizabeth Cooper Director
Paul Bernard Guenther Director
Richard Edward Cavanagh Director
Robert Ernest Broatch III Director
Stephen Joseph Squeri Director
11(b). Name(s) and position(s) of all officers and partners
Barry Ivan Belfer Senior Vice President and Treasurer
Bryan Scott Tutor Chief Operating Officer, RS Investment Management
Deanna Marie Mulligan President, Chief Executive Officer
Donald Paul Sullivan, Jr. Senior Vice President and Interim Head of Agency Distribution and Park Avenue Securities
Dong Hyun Ahn Senior Vice President, Group Profit Center Officer
Douglas Scott Dolfi Chief Operating Officer
Gordon Griffith Dinsmore Senior Vice President of Berkshire Life Insurance Company of America
John Hunter Flannigan Senior Vice President and Corporate Controller
John Patrick McCarthy Executive Vice President, Guardian Subsidiary Human Resources Support
Michael Bernard Cefole Senior Vice President, Retirement Solutions
Michael Nicholas Ferik Senior Vice President, Individual Life
Michael Slipowitz Senior Vice President, Corporate Chief Actuary
Richard Carl Herbert Jones Senior Vice President and Chief Communications Officer
Robert Ernest Broatch III Executive Vice President, Chief Financial Officer, Risk and Operational Excellence
Thomas George Sorell Executive Vice President and Chief Investment Officer
Tracy Leon Rich Executive Vice President, General Counsel and Corporate Secretary
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.
GUARDIAN
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.
Guardian foresees no known rendering issues in connection with the proposed .GUARDIAN gTLD for which it is applying. This answer is based upon consultation with Guardian’s selected back-end provider, VeriSign, 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/).
Mission/Purpose
18(a). Describe the mission/purpose of your proposed gTLD.
18.1 Mission and Purpose of .GUARDIAN
The Guardian Life Insurance Company of America (“Guardian”) is one of the leading mutual life insurance companies in the United States. Founded in 1860, Guardian and its subsidiaries sell life, long-term care, disability income, group medical and dental insurance products. Guardian and its subsidiaries also offer 401(k), annuities and other financial products. Guardian operates one of the largest dental networks in the United States, covering more than six million employees and their families at 120,000 companies.
Guardian has more than 5,400 employees in the United States and a network of over 3,000 financial representatives in more than 80 agencies nationwide. Guardian’s principle products are organized into the following segments:
- Insurance Products
Life Insurance
Disability Insurance
- Employee Benefits
Group Dental
Group Disability
Group Life
Group Critical Illness
Group Vision
Worksite
Flexplan
Small Group Sales
- Investment and Retirement
Annuities
IRAs
401(k) Funding Vehicle Products
Mutual Funds
Brokerage Accounts
Investment Advice
During more than 150 years of business, people and businesses have put their trust in Guardian through innovative technology, products, and services. Through this long history of innovation, Guardian has remained true to its founding principles: putting people first, continually building on financial strength, and maintaining the highest ethical standards. It is with these core principles and history in mind that, through a unified corporate approach, Guardian intends to submit two gTLD applications for the .GUARDIAN and .GUARDIANLIFE gTLDs.
The intended future mission and purpose of the .GUARDIAN gTLD is to serve as a trusted, hierarchical, and intuitive namespace provided by Guardian, as well as its qualified subsidiaries and affiliates to use for both their customer base as well as a mechanism to oversee their diverse field force of Guardian agents, brokers, and representatives. Guardian is the designated entity to file this application and bring the .GUARDIAN gTLD to market.
Guardian will be analyzing and evaluating other .BRAND gTLD applications, as well as general market adoption, to determine short- and long-term potential best-in-class use case options to more effectively serve and enhance Guardian’s online strategy as a leading global mutual life insurance company.
Guardian intends to initially limit registration and use of domain names within the .GUARDIAN gTLD to Guardian and its qualified subsidiaries and affiliates. This initial limited use will allow Guardian 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 Guardian from its annual Code of Conduct Compliance requirements.
After Stage 3 (see below), Guardian will evaluate whether opportunities exist to carry out the business strategy for the .GUARDIAN gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to Guardian agencies, brokers and consumer base.
Guardian currently plans a four-stage rollout for the .GUARDIAN gTLD:
- Stage 1
The initial stage of implementation of the gTLD will involve Guardian registering a limited number of .GUARDIAN second-level domain names.
This initial use will provide Guardian’s IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .GUARDIAN 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 Guardian staff to coordinate with the internal and external staff responsible for the delegation, and setup phases of the .GUARDIAN gTLD to ensure a proper transition from delegation to full operation.
- Stage 2
Once all testing has been successfully completed, Guardian will begin allocating domain names in the .GUARDIAN gTLD for more widespread internal corporate use. During this same period of time, Guardian 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 gTLDs, to Guardian’s new gTLDs.
It is in Stage 2 that Guardian will evaluate expanding the operations of the gTLD to permit registration by other registrants, such as licensees and 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 Guardian’s business model.
- Stage 3
Depending on the analysis of the evaluations undertaken in Stage 2, Guardian may begin to implement the permanent migration of Internet traffic away from the TLDs in which Guardian’s domain names are currently registered, and toward the .GUARDIAN gTLD. It is in this stage that Guardian also may implement its decision to extend registration rights to licensees and 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 Guardian’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Guardian will have full control over the number of registrations in the .GUARDIAN gTLD namespace, Guardian 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 in the initial three stages, and based on its experience with any expansion implemented in Stage 3, Guardian will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, including customers of Guardian – specifically, individuals who use products or services provided by Guardian, its subsidiaries, agents, representatives, or the like. It is anticipated by Guardian 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⁄affiliate, and licensee use will take into account this experience as well as the technical analysis of potential expansion.
The potential use of the .GUARDIAN gTLD by Guardian and its various business segments will also be driven by Guardian’s future business strategies as identified in its annual report, see http:⁄⁄www.guardianlife.com⁄AboutGuardian⁄FinancialHighlights⁄AnnualReport⁄index.htm.
Utilizing current projections based upon Guardian’s existing businesses, future business plans, current domain name portfolio, and other strategic factors, Guardian estimates that second-level domain name registrations will be in line with the projections set forth in the financial template provided in response to Question 46 of this application.
18(b). 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?
Guardian believes that the proposed .GUARDIAN gTLD has the potential to offer the following benefits to Internet users and consumers:
-Establish a trusted source of information for the millions of consumers who use Guardian’s products, for investors and third parties seeking information, and for the general Internet user population; and
-Provide Guardian and its qualified subsidiaries and affiliates with short and memorable Internet addresses; provide increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.; and
-Minimize the cost and need for defensive registrations because domain names will only be allocated by Guardian within the .GUARDIAN gTLD to Guardian and its qualified subsidiaries and affiliates; and
-Develop a potential platform for secure access to Guardian products and information to consumers, in order to minimize the potential for fraudulent activity; and
-Through the adoption of new gTLDs by the wider Internet user community, consumers may benefit from a lower incidence of phishing and malware often associated with mistypes of domain names in the .COM space that are owned by cybersquatters, since consumers will be navigating to domain names in the .GUARDIAN gTLD.
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 .GUARDIAN gTLD is to provide a trusted, hierarchical, and intuitive virtual platform to deliver content and information about Guardianʹs business, focus, and products. As Guardian continues to grow, it is the company’s desire to pursue and develop new opportunities to market its online content and products to consumers, in the U.S. and internationally, on a variety of platforms, including the Internet and mobile devices. Given that customers are increasingly requesting access to Guardian and its products through a variety of channels, including via domain names, Guardian believes that the .GUARDIAN gTLD has the potential to provide an innovative, virtual avenue to Guardian products that will deepen and broaden the companyʹs relationship with consumers.
Most importantly, Guardian will be able to provide access to its products and online content in a namespace void of piracy, cybersquatting, and other malicious activities. Providing consumers with a safe experience is paramount to Guardian and the .GUARDIAN gTLD will be used to further that goal. The .GUARDIAN gTLD would offer consumers a safe and intuitive means of accessing authorized content from Guardian 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 the .GUARDIAN gTLD are differentiation and innovation. The success of .GUARDIAN will not be measured by the number of domain names registered, but rather by the levels of consumer recognition and trust that are placed in the gTLD. Using this as a benchmark, Guardian will continue to strive to increase these until they rise to the levels of those found in the .EDU and .GOV gTLDs. More specifically, Guardian will be able to communicate to Internet users that the .GUARDIAN namespace provides a safe place to find trustworthy information about insurance and financial services.
18.2.3 What goals does your proposed gTLD have in terms of user experience?
Guardian believes that the .GUARDIAN gTLD will provide a single, trusted ecosystem experience for the millions of consumers worldwide who use the company’s products, as well as for those seeking information provided by Guardian, such as individuals and families, business owners, employers, and brokers. In addition to providing consumers with short, memorable, and intuitive domain names, the .GUARDIAN gTLD will indicate to consumers that the domains and content are owned and controlled by Guardian and its qualified subsidiaries and affiliates, thus demonstrating to users that they are safe from potential infringing, pirated, or harmful content relating to personal and business finances.
The initial use of the .GUARDIAN gTLD will be primarily defensive in nature, with Guardian registering a limited number of second-level domain names. This initial use will provide Guardian’s IT and security personnel with the ability to run a number of tests to ensure seamless and secure access to the Guardian website, and interoperability with various software and web⁄mobile-based applications. Once the appropriate security and stability issues have been satisfactorily addressed, Guardian will likely begin allocating domain names for internal corporate use and may redirect new .GUARDIAN 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.
During this same period of time, Guardian will continue to evaluate potential strategies for use of the .GUARDIAN gTLD in other ways that will advance Guardian’s corporate mission and goals.
18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.
Guardian currently intends for the .GUARDIAN gTLD to be exclusively used by Guardian and its qualified subsidiaries and affiliates. Because of this condition, any registration and use requirements are more appropriately vested in the corporate agreements between Guardian and its qualified subsidiaries and affiliates and not in a domain name registration agreement.
Notwithstanding this, Guardian will 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 potential partner 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 leading financial products company, Guardian recognizes that this is an evolving area of law in which there is no international standard. However, due to the fact that, initially, every domain name will be registered to Guardian or its qualified subsidiaries and affiliates, the company has a vested interest in ensuring that accurate and current domain name information is readily available in connection with each .GUARDIAN domain name. For the .GUARDIAN gTLD, all private and confidential information will be protected.
Guardian will ensure that the operation of the .GUARDIAN gTLD will be consistent with Guardian’s Privacy Policies, available here:
http:⁄⁄www.guardianlife.com⁄PrivacyPolicy⁄index.htm
In addition, Guardian 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.
Guardian sees the potential for the .GUARDIAN gTLD to play a large role in the company’s future online strategy. While the extent of likely benefits is currently uncertain due to questions of consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace, all of which may influence the communication, marketing and use strategies of the gTLD, Guardian anticipates a phased-in approach to using and promoting the gTLD, as described above.
As a first step, Guardian plans to start using .GUARDIAN domains initially as redirects to existing .COM domains. Subsequently, Guardian expects to initiate a targeted, pilot rollout using select gTLD domains as primary addresses and, after careful analysis and study of this rollout, Guardian may engage in a broader initiative, should the results be satisfactory and in accordance with the company’s overall strategic goals. The actual usage of .GUARDIAN domain names will dictate what public communications and consumer outreach is done to encourage navigation to the .GUARDIAN gTLD, including advertising, media outreach, in-store communications, email campaigns, etc.
18(c). What operating rules will you adopt to eliminate or minimize social costs?
18.3 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)?
Guardian’s proposed operating rules to initially limit registration to Guardian and its qualified subsidiaries and affiliates will provide a trusted online environment for consumers to access Guardian online content, and will minimize social costs by default. This verified ecosystem will also provide consumers with a single, trusted source for Guardian’s products with a substantially lower risk of fraud, misdirection, infringement, or scams that consumers are plagued with in .COM and other open gTLDs.
Guardian does not anticipate consumer vulnerabilities; therefore, one way in which social costs will be eliminated is that trademark and brand owners will not need to defensively register second-level domains in the .GUARDIAN gTLD. In fact, Guardian’s expectation is that the usage of a .GUARDIAN gTLD will eliminate many of the vulnerabilities that Guardian consumers face in the wider Internet today.
18.3.1 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?
Guardian believes that the proposed operation of the .GUARDIAN 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.
18.3.2 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come⁄first-serve basis?
Guardian does not envision multiple applicants for the same domain name, as domain names will initially only be registered to Guardian and its qualified subsidiaries and affiliates.
18.3.3 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
Guardian does not envision the implementation of any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the mission and purpose of the .GUARDIAN gTLD as a trusted online source identifier. Moreover, it is the current intention of Guardian to initially provide domain name registrations to itself and its qualified subsidiaries and affiliates at no cost, though the company reserves the right to re-evaluate this decision and may choose to impose a nominal fee in the future. Any potential registrant fees imposed upon licensees and strategic partners will be made in the future if this class of registrants are permitted to register domain names in the .GUARDIAN gTLD.
18.3.4 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.
Guardian is committed to providing the domain name registration periods set forth in the Registry Agreement. However, as noted above, as a branded gTLD, the registration of the domain name is conditioned upon separate subsidiary or affiliate relationships with Guardian. 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 Guardian providing domain name registrations to itself and its qualified subsidiaries and affiliates at no cost.
Guardian 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, Guardian and its qualified subsidiaries and affiliates, as the initial intended sole registrants within the .GUARDIAN gTLD, will only be registering domain names on an annual basis. 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, e.g. no multi-year registration or deferred revenue.