.ladbrokes New gTLD Application
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New gTLD Application Submitted to ICANN by: LADBROKES INTERNATIONAL PLC
Application Downloaded On: 07 Jul 2016
String: ladbrokes
Application ID: 1-1823-86614
Applicant Information
- Full legal name
LADBROKES INTERNATIONAL PLC
- Address of the principal place of business
57‐63 LINE WALL ROAD GIBRALTAR - 000 GI
- Phone number
+ 350 200 45375
- Fax number
+ 350 200 52027
- If applicable, website or URL
http://www.ladbrokesplc.com
Primary Contact
6(a). Name
Matthew Hill
6(b). Title
Legal Counsel
6(c). Address
6(d). Phone Number
+44 (0) 208 515 5620
6(e). Fax Number
6(f). Email Address
Secondary Contact
7(a). Name
Elaine Wilkinson
7(b). Title
Personal Assistant
7(c). Address
7(d). Phone Number
+4420 8515 5513
7(e). Fax Number
+4420 8868 8767
7(f). Email Address
Proof of Legal Establishment
8(a). Legal form of the Applicant
Public Limited Company
8(b). State the specific national or other jurisdiction that defines the type of entity identified in 8(a).
Gibraltar
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
Anthony John Carroll Sportsbook Trading Manager
Darren James Mauro Sportsbook Trading Manager
Desmond Reoch Management Consultant
Graham Weir Company Director
Hugh Carr Director of Telephone Betting
Michael Patrick O'Kane Business Director
Nicholas John Rust Company Director
Richard Jonathan Ames MD Product Group
Steve Buchanan Finance Director
11(b). Name(s) and position(s) of all officers and partners
11(c). Name(s) and position(s) of all shareholders holding at least 15% of shares
Name
Position
Ladbrokes Betting & Gaming Limited Not Applicable
11(d). For an applying entity that does not have directors, officers, partners, or shareholders: Name(s) and position(s) of all individuals having legal or executive responsibility
Applied-for gTLD string
- Provide the applied-for gTLD string. If an IDN, provide the U-label.
ladbrokes
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.
The .ladbrokes string and A-Label were developed in line with and checked against the eligibility, stability and policy criteria as stated in the ICANN Applicant Guidebook - version 2012-01-11. The results of those checks are as follows:
- The string has less than 63 characters;
- The string in ASCII is composed of three or more visually distinct characters;
- The ASCII label consists entirely of letters;
- The string is not a reserved name as shown in section 2.2.1.2.1 - Reserved Names of the ICANN Applicant Guidebook - version 2012-01-11; and
- .ladbrokes is not identical or similar to any of the top 10 invalid TLD’s responsible for the majority of DNS pollution, as referenced in the Security and Stability Advisory Committee (SSAC)’s report on this topic at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac045.pdf. It is likely that the .ladbrokes has not already been queried with meaningful frequency at the root. Therefore, it is unlikely that .ladbrokes will inherit significant invalid query traffic.
Due to the positive results of these checks, Ladbrokes International PLC does not believe that the .ladbrokes gTLD will be subject to any operational or rendering problems.
- 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.
The mission and purpose of the new restricted .ladbrokes gTLD is to benefit internet users by ensuring increased trust and confidence through the elimination of user confusion and assurance of brand authenticity.
The new .ladbrokes gTLD will operate as a restricted registry, in which Ladbrokes International plc (“Applicant”) can create and control domain spaces that promote its brand identity and authenticity. The .ladbrokes gTLD will be used by Ladbrokes plc (Ladbrokes), being the ultimate holding company of the Applicant, its group companies, affiliates and partners to provide authoritative information and services to consumers regarding the group’s betting and online gaming products in a way that promotes trust, confidence and simplicity. Second and third level domains can be used for specific betting and gaming products, as well as for marketing, with internet users assured of brand authenticity.
Ladbrokesis a leading international betting and gaming company. Ladbrokes, officially founded in 1902, is the market leader in retail bookmaking in the UK, Ireland, Belgium and Spain with over 2,700 betting shops. Ladbrokes, listed on the London Stock Exchange, has a market capitalisation of approximately GBP 1.4B, 2011 group revenue of GBP 980M and 16,000 employees worldwide. Ladbrokes offers thousands of innovative betting markets on a daily basis through internet, mobile and telephone betting. The group’s principal online betting and gaming service, ladbrokes.com, has nearly 800,000 active customers. Ladbrokes offers betting and gaming products to customers internationally via 13 tailored websites in nine different languages, supporting 17 currencies. The site incorporates the highest levels of security, which underpin an integrated array of uninterrupted sports betting and gaming services available 24 hours a day, 365 days of the year. In this regard, consumer trust and continuous innovation are paramount considerations in all Ladbrokes’ group’s activities. The new .ladbrokes gTLD will offer customers an authentic and unparalleled betting and gaming experience online, strengthen Ladbrokes’ online presence and reputation and help to realise its vision of becoming a fully e-enabled international betting and gaming business.
Since the inception of the current domain name system, business activities conducted on the internet are constantly changing and evolving with increased complexity. The volume of commercial transactions over the internet is constantly growing and bringing benefits of simplicity and lowered transaction costs to businesses and consumers. The .ladbrokes gTLD will facilitate greater trust and assurance from internet users connecting with Ladbrokes online, whilst still allowing convenient and efficient interaction.
The Applicant’s mission and purpose of the proposed new gTLD share ICANN’s initiatives to promote public interest. The Applicant is committed to contribute towards achieving such initiatives in line with ICANN’s Affirmation of Commitments, which include:
-consumer trust: the .ladbrokes gTLD will be operated in a centralised manner with a restrictive registration policy. Registration of domain names will only be available to Ladbrokes and its group entities, at this stage, which will provide added consumer trust that .ladbrokes domain names are trustworthy. As .ladbrokes domain names are subject to registration standards, policies and procedures under the Applicant’s control, this eliminates the possibility of malicious conduct within the .ladbrokes domain space;
-competition: the proposed new gTLD is not intended to instigate competition and consumer choice at the level of registration of domain names among prospective registrants. Instead it is anticipated to contribute to ICANN’s initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in the .ladbrokes gTLD will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and
-consumer choice: theproposed new gTLD will enable user-driven improvements and innovations assisting the Applicant’s marketing efforts through its ability to create new second and third level domain names on demand. These names will provide the consumers with more choices for interacting with Ladbrokes. As the Applicant has effective control over the registration and use of domain names under .ladbrokes domain space, this will also contribute towards general service innovations on the internet.
Given the restricted nature of the .ladbrokes gTLD, the projected number of registrations is likely to be limited. It is anticipated that about 100 domain names will be registered in the first year. However, over the next few years, the number of registrations is likely to increase to about 200 domain names as Ladbrokes implements new betting products, services and marketing campaigns.
As the new .ladbrokes gTLD expands and evolves, the Applicant will continue to comply with all operational, technical and policy requirements, as well as maintaining consumer trust and the stability of the internet. The Applicant will keep ICANN reasonably informed of any material developments relating to .ladbrokes gTLD including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.
The Applicant intends to create relevant domain names including betting and gaming products, services or geographic names at the second or third level domain names. In accordance with registration policy and the proposed measures for protection of geographic names as outlined in response to Question 22, the Applicant will use geographic names to localise its websites in countries in which it operates. The use of geographic names is intended to:
-connect internet users with relevant information as applicable to the territory; and
-comply with required rules and regulations in the national territory.
The Applicant will also utilise Internationalized Domain Names (IDNs) at the second level, initially including languages using the Latin Script, Chinese and Russian. IDNs will allow internet users to engage with .ladbrokes in their native language, creating a more positive user experience and encouraging diversity. As the use of the .ladbrokes gTLD evolves, it is anticipated that the use of IDNs, including additional languages, will increase within .ladbrokes domain space.
Ladbrokes is a well-recognised international brand with its “Ladbrokes” trademarks registered in 16 countries and territories, including UK, European Community, China and India, for classes including: Entertainment including internet betting, gaming and gambling services (41); Computer Software for betting, gambling and gaming machines (9); Printed matter including lottery tickets and game cards (16).
Ladbrokes has an extensive domain portfolio including existing domain names with an exact match to the “Ladbrokes” trademark and the applied-for .ladbrokes string in the following spaces.
-gTLDs: ladbrokes.asia, ladbrokes.biz, ladbrokes.com, ladbrokes.info, ladbrokes.mobi, ladbrokes.net and ladbrokes.xxx
-ccTLDs: ladbrokes.cn, ladbrokes.co.uk, ladbrokes.com.br, ladbrokes.eu, ladbrokes.fr, ladbrokes.hk, ladbrokes.ie, ladbrokes.it and ladbrokes.jp
Ladbrokes also has 440 domain names containing the “Ladbrokes” trademark.
The Applicant believes that the .ladbrokes gTLD is unlikely to cause confusion with either a generic term or any existing TLDs. Ladbrokes trademarks are a leading international brand with significant reputation around the world. Ladbrokes has used the term Ladbrokes in conjunction with its betting and gaming businesses for almost 110 years. As such, the Ladbrokes brand is synonymous with premium betting and online gaming.
18B. How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
18(B)I. WHAT IS THE GOAL OF YOUR PROPOSED gTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?
The key goals of the proposed new .ladbrokes gTLD are in line with ICANN’s Affirmation of Commitments: to promote consumer trust, competition and consumer choice. The Applicant also seeks to foster its online reputation and provide an authoritative internet space through which Ladbrokes is able to communicate with its customers directly and effectively. The new .ladbrokes gTLD will allow the Applicant to control its own internet space internationally and tailor its specialty betting and gaming products and services to meet users’ local preferences and changing interests. This will increase awareness of the Ladbrokes brand and improve the company’s online reputation. The ability to create domain names on demand related to specialty products and service and specific marketing supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.
18(B)II. WHAT DO YOU ANTICIPATE YOUR PROPOSED gTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?
It is anticipated that the proposed .ladbrokes gTLD will make positive contributions to the wider internet community by providing:
DIFFERENTIATION (INCREASED TRUST):
The .ladbrokes gTLD will simplify how internet users interact with Ladbrokes by providing a distinctive domain space. Internet users will be able to directly navigate to the .ladbrokes gTLD site, saving time and resources searching for an official site. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. Consumer protection and trust are vital to Ladbrokes’ high-traffic online betting and gaming websites. The Applicant can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .ladbrokes domain space. The new .ladbrokes gTLD will provide an authentic online betting and gaming site with enhanced security and increased customer protection, which in turn will improve customer trust in the Ladbrokes online brand. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names under .ladbrokes domain space, which will differentiate interaction between internet users and Ladbrokes.
COMPETITION:
The differentiation of .ladbrokes gTLD as a trusted site for Ladbrokes will drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Internet users will be encouraged to interact with domain names under .ladbrokes domain space. As a result, .ladbrokes will have a flow on effect to enable increased competition. Therefore, the benefits of the proposed .ladbrokes will be distributed not only to its direct customers, but to the internet community at large forcing improved services and competitive pricing in the market place.
INNOVATION:
With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses and organisations establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name. This problem is amplified for organisations such as Ladbrokes which work across many different jurisdictions and geographical markets and have difficulty in establishing a coherent online presence. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. The new .ladbrokes gTLD will overcome these limitations by creating an innovative global platform through which Ladbrokes can offer betting and gaming products and services to customers across the world. The Applicant has the ability to create second or third level domain names on demand, including the use of specialised betting products and services, geographic names and IDNs, which are relevant to its customer base. The Applicant will be able to combine its use of the domain space with innovative user focused marketing and services to address the currently unmet needs in the existing domain name system providing greater consumer choice.
18(B)III. WHAT GOALS DOES YOUR PROPOSED gTLD HAVE IN TERMS OF USER EXPERIENCE?
The proposed .ladbrokes will provide a positive user experience, which meets the changing and growing needs of the global internet community. The Applicant will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorised by the Applicant. Therefore, the .ladbrokes gTLD will:
- provide a secure and authentic online betting and gaming domain space, increasing customer protection and trust in the Ladbrokes brand;
- strengthen brand reputation and user confidence by eliminating user confusion;
- create second level domain names for innovative betting and gaming products and services tailored to customer preferences;
- provide an easy and intuitive reference and access point for internet users with improved searchability;
- direct internet users to relevant information in a timely manner by creating domain names on demand;
- use IDNs to enable customer to interact directly in their native language;
- use geographic names to localise its websites to connect with internet users in the relevant regions and to comply with local laws;
- enhance security and minimise security risks by implementing necessary technical and policy measures; and
- prevent potential abuses in the registration process reducing overall costs to businesses and users.
The .ladbrokes gTLD should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .ladbrokes gTLD will reduce potential abuses in the registration processes and overall costs to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN’s core values in benefiting the public interest.
18(B)IV. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.
The proposed registration policy is attached in response to Question 28.
Only affiliate entities of the Applicant will be eligible to register domain names in .ladbrokes at this stage. The domain name registration processes will address the requirements mandated by ICANN, including rights abuse prevention measures.
18(B)V. 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 Applicant is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user’s confidential information, including the Data Protection Act 1998 (UK).
The Applicant has also implemented its own privacy policy to demonstrate its commitment to the protection of user privacy and confidential information. The Applicant understands the need to protect the privacy and confidentiality of users’ personal and sensitive information and takes its obligations very seriously. Ladbrokes’ Privacy Policy covers the collection, use, storage and disclosure of users’ personal information. Ladbrokes’ Privacy Policy provides that Ladbrokes will not pass on or sell users’ personal information to any third parties and will only use personal information to:
- provide products and services to customers;
- send information about products and services that may be of interest to customers, unless a customer has opted-out of receiving communications; and
- disclose information to Ladbrokes’ professional advisers only where necessary for the administration of the website and related business, or if required to disclose such information by law.
As the .ladbrokes gTLD will only be available to affiliate entities of the Applicant, initially, the amount of personal data that will be collected for the purposes of operating the gTLD and made publicly available in the WHOIS database will be very limited. The Applicant will provide a publicly available and searchable WHOIS look up facility, where information about the domain name status, registrant information including administrative and technical contact details can be found in accordance with Specification 4 of the Registry Agreement. In order to prevent misuse of the WHOIS look up facility, the Applicant will utilise measures including a requirement where any person submitting a WHOIS database query is required to read and agree to the terms and conditions in accordance with the registration policy. This will include the terms of use that the WHOIS database is provided for information purposes only and that the user agrees not to use the information for any other purposes such as allowing or enabling the transmission of unsolicited commercial advertising or other communication.
The Applicant will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both Ladbrokes and its users interacting with Ladbrokes online. DNSSEC provides additional security by validating information in the transmission, therefore it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .ladbrokes gTLD. Ladbrokes already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorised access. Such measures include the use of firewalls and Secure Sockets Layer for data protection.
The Applicant will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .ladbrokes domain space.
18(B)VI. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.
The proposed new gTLD will be publicised by a media plan to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity.
During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users will be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to utilise the trusted site will contribute towards minimising malicious abuses and protecting internet users.
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?
As a restricted gTLD, registration will only be open to internal users (affiliate entities) at this stage and no third parties will be able to register domain names under .ladbrokes domain space. Therefore, it is not anticipated that third party trademark owners will incur costs in relation to the .ladbrokes gTLD. The affiliate entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. The Applicant will utilise the services of the proposed Trademark Clearinghouse to ensure that domain names registered and the use of those domain names, do not infringe any registered third party intellectual property rights.
No unaffiliated third party will be permitted to register domain names at this stage. It is estimated that time and money spent by consumers who have been targeted by malicious abuse in utilising services on the internet will reduce over time as a result of the new, trusted .ladbrokes gTLD.
18(C)I. HOW WILL MULTIPLE APPLICATIONS FOR A PARTICULAR DOMAIN NAME BE RESOLVED, FOR EXAMPLE, BY AUCTION OR ON A FIRST-COME⁄FIRST-SERVE BASIS?
The initial use of the proposed new gTLD will be restricted to internal business use and Ladbrokes and affiliate entities are intended to be the registrants under the .ladbrokes gTLD. Therefore conflicts between multiple applications are not anticipated to occur.
18(C)II. EXPLAIN ANY COST BENEFITS FOR REGISTRANTS YOU INTEND TO IMPLEMENT (E.G., ADVANTAGEOUS PRICING, INTRODUCTORY DISCOUNTS, BULK REGISTRATION DISCOUNTS).
This gTLD will be used for internal purposes only, at this stage, so pricing incentives are not applicable or relevant.
18(C)III. 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 PLAN.
This gTLD will be used for internal purposes only, at this stage, so pricing incentives or pricing increases are not applicable or relevant as no additional fees are to be charged.