1. GENERAL TLD POLICIES

The present proposal is directed to fulfilling the ideal of "the Internet for everyone". The present gTLD space has grown in an unstructured manner, which has led to conflicts over a perceived lack of space for the individual, or for ordered and stable expansion to new technologies. Personal communication services including data, voice, and custom messaging, as well as control and communication functions for consumer electronic devices, are converging upon the TCP/IP as the medium, and the Internet as the unitary platform. A key component for facilitating this convergence is a universal addressing mechanism that is ordered, has a sufficient degree of flexibility, and is extensible enough to be of use to a vast international end user base. The Sarnoff Corporation, a pioneer in the development of consumer technology infrastructure, proposes to participate in the establishment of a new .i TLD in the DNS that will provide a standard addressing platform for all developers of convergence technology. At the same time, it is necessary to distinguish the proposed TLD from existing TLDs.

Although this proposal is not for a chartered TLD per se, the naming convention and policies described below for the presently-proposed .i TLD are designed to foster the use of the .i TLD as a personal identifier for individuals and as an address for personalized Internet services which are independent of the individuals' Internet service providers. As such, the .i TLD is not designed to be a branding or naming mechanism primarily for web sites, as in the current generic TLD's. The objective of the .i TLD is to provide an ISP-invariant mechanism by which the individual registrant will be provided with the ability to obtain a unique address in order to configure digital communication and contact services that will be offered by various vendors to utilize the .i platform.  With the convergence of information delivery services and, in particular, the adoption of wireless messaging and location services, there is a need for a central invariant point of contact around which an individual may configure and coordinate his or her access to such services. Additionally, by assigning individuals a service provider invariant digital identifier - a domain name in the .i TLD - the DNS can be utilized to provide a channel for access to individual public encryption keys authenticated by the domain name registry.

The .i TLD will provide a focal point for the convergence of integrated management of individual communication and information services, such that services to be provided to Internet-enabled telephony, file sharing, remote workgroup coordination, personal communications and wireless devices such as personal digital assistants can be provided and configured via a unitary interface to routing and protocol specifications in an individual’s zone file data.  There is a present and growing demand for integrated management of individual information services which can be met with the introduction of an individual TLD of this sort. This demand provides an incentive for introduction of the TLD beyond proof-of-concept purposes.

Domain names in the proposed .i TLD are intended primarily as an identification and addressing mechanism for individual use. Such domain names will be non-transferable, and a large set of terms will be rendered unregistrable. The .i namespace is intended to grow hierarchically into a directory mechanism comparable to the Usenet newsgroup namespace. Hence, dictionary terms and geographical terms will be rendered unregistrable, along with trademarked terms subject to the pre-emption and pre-registration mechanisms set forth below.  We expect these policies to dramatically limit the motive, opportunity, and ability to engage in abusive registration practices that have been encountered in the generic TLD's.

The proposed TLD string is .i ("dot i" ). The new TLD is intended for use primarily as a personal identifier, as noted above.  As a personal identifier, addresses within the TLD are expected to find a variety of applications that are not readily characterizable as being "commercial" (as in the original charter for .com), "network oriented" (as in the original charter for .net), or "organizational" (as in the original charter for .org). Rather than to limit the perceived scope of applicability of addresses within the TLD by selecting a multiple character string, which might suggest a particular application in one or more languages, ".i" is relatively free of cognitive associations other than perhaps "Internet", "identity", "individual", or the first-person pronoun, "I".

For the proposed target applications, other TLD strings may be appropriate. However, ".i" is less likely to be confused with .id (Indonesia) or .int (International Organizations) than other logical English mnemonics for terms such as "Internet", "identity" or "individual".  It is noted that single letter TLD's have been reserved for unspecified future expansion of the Internet domain name space, and it is not clear what "expansion" is intended. For example, it would make little sense to introduce a ".com.i" in order to provide for additional .com addresses, since such use would lead to obvious confusion. The new paradigm embodied in the .i TLD proposal of assigning domain names for individual personal use as well as Internet enabled devices is the sort of application for which single letter domain names are reserved. Because the .i TLD is targeted for use by individuals, an individual TLD character reinforces the perception that the TLD is not intended as a supplemental generic TLD. Adoption of an alternative TLD string such as ".idi" (Internet Digital Identifier) or .iii, or .one, or some other string to be decided would be considered, although such a string would be less distinctive and therefore pose a greater possibility of being confused with a traditional TLD.

Three tiers of naming services are proposed as follows:

Any Internet user will be provided on request at no charge, a .i domain name of the following form:

<10-digit-numeric-string>.<two-letter-string>.i

All two-letter combinations will be reserved and unregistrable to a single user for this purpose. Ten digit numeric strings have demonstrated utility, durability and memorability as telephone numbers. Adding a user-selectable two-letter second-level domain will avoid conflicts in the unlikely event that multiple users desired the same ten digits. Users may, for example, select their initials as the two-letter string.

Free numeric domain names will be limited to one domain name per individual user. Qualification for free domain names will be subject to the certification requirements discussed further below. The number of free domain names disbursed each year is proposed to be capped at about the same level as the number of paid registrations for that year. Once operational, the Registry will evaluate and adjust this offer as necessary based on financial and operating metrics.

The registry will reserve as unregistrable, a database of words taken from standard dictionary files for which such lists are available in various languages. This database will include geographic terms and will be in addition to all two-letter combinations, and any pre-empted or pre-registered terms in accordance with the trademark policies discussed below. An initial group of words, selected to identify occupations and areas of interest such as religions, hobbies, and the like, will be maintained by the registry and made available for registration by users at the third level.  For example, a doctor named John Smith may register johnsmith.doctor.i , where "doctor" is a registry-reserved second-level domain.

Additional unregistrable strings in the second level will include all 4-digit numeric sequences, such that a user not desiring to identify with any of the reserved words may register a domain name of the form <firstname-middleinitial-lastname>.NNNN.i . This is discussed below in the section on the third tier of names.

If users seek to have a customized name at the second or third level, they may request these names either during the startup period or afterwards. Dictionary words and pre-empted or pre-registered terms will remain unregistrable at the third level and higher in order to allow the .i namespace to expand hierarchically based on user demand in much the same manner as the Usenet newsgroup hierarchy. Usenet provides a model of stable namespace hierarchy growth over a long period of time.  In this manner, the .i TLD reserves room for orderly expansion, and grows into its own directory mechanism.

Users may propose new additions to the .i hierarchy. When a threshold number of user proposals have been received, for example, the "doctor.i" hierarchy may be expanded to include "neurologist.doctor.i", which will be reserved by the registry and made available for user registrations at the fourth-level. When a proposed second-level addition reaches the threshold level, the proposed addition will be published at a designated location, and automatic email notification will be sent to subscribers of the domain name alert service described below, in order to provide interested parties with an opportunity to pre-empt or pre-register the second-level domain name in view of an intellectual property claim.

As noted above, all dictionary words, two-letter combinations, and pre-empted or pre-registered terms will be unavailable for registration at the second level (or higher registrable level where appropriate). Users may propose non-reserved terms for registration as direct second-level (or higher) domain names for their exclusive use. During the startup period discussed below, domain names proposed in this manner will be registered on a lottery basis, after a predetermined "daybreak" period.

For example, John Smith may desire to register johnsmith.i . Other persons so named may also desire an opportunity to register that name. In the present name space, domain name speculation has provided one method for the economic allocation of domain names desired by more than one party. Because .i names are non-transferable, speculation is not a possibility. Instead, proposed second-level domain names will be published at a publicly accessible location, and interested parties can enter a lottery in order to receive the name. Because the list will be made publicly available for the duration of the lottery, it will also be available for inspection by trademark holders. Additionally, the registry will operate an email notification list on a free subscription basis by which parties such as attorneys or trademark watch services will be informed of new proposed SLDs prior to conclusion of the lottery.  If, prior to the end of the lottery, the registry receives a certified copy of a pre-existing trademark registration for the corresponding word mark, the lottery will be suspended, and the trademark owner will have the option of registering the SLD or pre-empting its registration. Otherwise, at the conclusion of the lottery, a registrant will be selected from the pool of parties indicating an interest.

The base registration fee may be determined by the number of participants in the lottery, in order to recover overhead costs based upon the volume of entry requests.  As more entrants enter a lottery, the final registration fee will increase. The domain name registration will be maintained by the registrar via which the lottery was entered, and the registrar will receive a proportionate share of the final registration fee for the domain name.

Users who choose not to select a special name may request a domain name of the standard format <firstname-middleinitial-lastname>.NNNN.i. All users with the same combination of first name, middle initial, and last name will be able to obtain their name because the four-digit second level domain enables distinction among individuals. To avoid confusion, the Registry will assign all standard-format names at standard-format wholesale price using this specific format with the hyphens as separators.

A structured TLD naming convention provides the benefits of a chartered TLD, in terms of minimizing potential abuse or confusion, while maintaining the goal of a TLD intended for universal personalized addresses as a platform for configurable end-user applications. The naming convention is designed to produce a domain name hierarchy that operates primarily as an addressing system rather than a "naming" system per se. Reservation of dictionary words for use in accordance with their primary meanings avoids the historical problems that have led to a "flattening" of generic TLD’s at the second level. While the domain name system was intended to grow in a tree-like manner to include higher levels, the capturing of perceived "valuable" words at the second level by individual registrants prevents a rational tree structure from being imposed upon the existing TLDs at this point in time. Hence, a "clean slate" is required to provide a TLD built around a more controlled and expansible hierarchy concept. Operation of a new TLD as described above provides an opportunity to make fuller use of the capabilities of the DNS as a hierarchical naming system, as originally envisioned. Experience in the USENET namespace demonstrates that a wide variety of information can be made accessible in a hierarchical naming system in which successive levels of the naming system are employed as words, rather than as status symbols or commodities.

To the extent that user flexibility is provided within the naming convention in order to accommodate a large international user base and devices, the naming convention is not unreasonably constrained. In that sense, the naming convention is egalitarian and, while avoiding conflicts with pre-registered terms legitimately belonging to respective trademark owners, domain name owners are not unequally advantaged or disadvantaged relative to one another in terms of finding an appropriate choice of descriptive or expressive positions in the naming system.

Registration in the .i TLD will be open to any ICANN-Accredited Registrar. Registrars may impose their own pricing structure upon value-added services, and have the option of providing a seamless direct link to the registry-affiliated registrar for the purpose of facilitating registration of "first tier" free domain names directly with the registry-affiliated registrar, in order to avoid imposing a burden on any registrar desiring to offer direct free domain name registrations. By allowing the registrars to offer free domain names in the .i TLD without imposing overhead operating costs, registrars will have the option of offering the free domain registration service as an inducement to obtain traffic to the registrars, so that they may offer other value-added services as they deem fit.

Additionally, the transparent free domain feed-through to the registry-affiliated registrar may be employed by non-registrar entities offering configurable information services for use with the end-user’s free domain name. Providing a front-end to the free domain registration option to non-registrars will not threaten the franchise of accredited registrars, since there is no particular economic benefit to the registrars for maintaining an exclusive franchise over free domain name registrations. The Sarnoff Corporation and AtomicTangerine have received expressions of interest, for example, from consumer electronic providers desiring to use the .i TLD as a platform for direct marketing of associated services. To the extent that such vendors desire to offer services to registrants of user-selectable domain names, then new partnership opportunities for accredited registrars are a natural consequence of limiting user-selectable domain name registrations to accredited registrars.

TLD policies such as the naming convention will be enforced at the registry level by rendering the terms indicated above to be unregistrable. Additionally, all relevant policy provisions will be incorporated into a registry-registrar contract otherwise modeled after the existing NSI-registrar contract. Entry into a domain name lottery will be available via any registrar, and the selected lottery entrant will be registered via the registrar through which the selected entrant proposed the SLD or entered the lottery. The registry-registrar contract will include a provision under which the registry retains an unrestricted right to cancel or revoke a registration pursuant to a UDRP decision, court order, discovery of fraudulent contact information, or registration error as determined within the discretion of the registry. Notice of potentially fraudulent contact information, and enforcement of the registration contract provisions relating to accuracy of registration data can be initiated by third parties.

The most common form of cyber squatting is driven primarily by the ability of a domain name registrant to extract a financial windfall by registering and subsequently transferring an infringing domain name to an intellectual property holder. In order to discourage this form of cyber squatting, domain names in the .i TLD are to be non-transferable. Hence, the possibility of transferring the domain name for a profit is eliminated. After registering a domain name, the registrant has the sole options of maintaining or deleting the registration. Deleted domain name registrations will be maintained in an inoperative "hold" condition for a random period of time exceeding three months, in order to prevent arranged deletion-re-registration operations among parties who would otherwise seek to transfer a domain name. "Non-transferability" as used in this document is intended to encompass concepts relating to "non-assignability", "non-divisibility" and "non-inheritability" as well. Leasing arrangements, for example, will be prohibited in the registration contract, and the registry will not recognize (and will require registrars not to recognize) third-party claims such as might be brought by lessors, creditors, estates, and the like.

In addition to a condition of non-transferability, domain name registration contracts in the .i TLD will incorporate the Uniform Dispute Resolution Policy.

Prior to launch of the TLD, a "daybreak" period will be provided to trademark owners to pre-empt or to pre-register their trademarks in the .i TLD.

A "takedown" provision will be made available in order to discourage subsequent similar domain name registrations by parties formerly adjudged judicially or in UDRP proceedings to have registered domain names in bad faith.  Upon notice to the registry by a third party of potentially fraudulent registration data, the registry may, in its discretion, notify the domain name registrant to update or correct the registration data.  Upon further notice that such correction has not been made, the registry will retain a discretionary power to revoke the registration.

The "takedown" policy, although not specifically intended encompassing personality rights, will be extended to prohibit impersonation, which will have the incidental effect of covering personality and identity rights as follows. For instance, where a party, including a private party, demonstrates a legitimate right to a non-standard format name (i.e. customized) of the form <firstname> <lastname> (i.e. a birth certificate or other official documentation of identity), and complains of a domain name registration incorporating <firstname><lastname>, the registrant will be contacted in order to make a similar showing. If the registrant can provide no similar showing, the domain name registration will be deleted. Deletion is favored in this aspect of the takedown policy in recognition of the fact that many individuals may have the same <firstname><lastname>, and the registry is not in a position to decide the ‘worthiest’ among them on the basis of a single third-party complaint. A cost recovery fee will be required of the complainant to discourage frivolous, repetitive, or harassing claims against the registrant. Where a registrant’s rights under a <firstname><lastname> term have been established, the registry will maintain a record of such establishment and will not entertain further complaints of this nature against the registrant. Such complaints would then be required to be submitted to the UDRP or litigation.

It is noted that the primary tier of domain names available in the .i TLD will consist of the form <10-digit-number>.<2 letters>.i . Registration of 10 digit numbers will not raise any intellectual property issues, as numeric sequences per se are not registrable as trademarks.  SLD's retained for use in the naming hierarchy will consist of dictionary words and geographical terms intended to be used in accordance with their primary generic meanings, and should also raise few intellectual property concerns. User-registered SLD's will be subject to the provisions of the UDRP and the "takedown" provision for repeated attempts to register minor variations of a domain name adjudged to violate a third party's rights.

Pre-screening of domain name registrations would require registry judgment to be applied in order to filter suspected trademark infringement.  To the extent that the registry constructs a list of trademarks for screening domain name registrations, then such a list may be under- or over- inclusive, leading to registry liability. To the extent that the registry makes a priori judgments concerning potential trademark infringement, then the registry may be liable for erring in such judgment. Hence, pre-screening is not a viable option.

Interested trademark owners will be provided with a "daybreak" period of 90 days in which they will be able to pre-empt registration of domain names corresponding to registered trademarks.  During the "daybreak" period, the .i TLD registry will provide holders of registered trademarks with two options as follows:

1. Pre-emption - This option will be provided on a cost-recovery basis for trademark owners who do not desire to use their name in the .i TLD, but desire to prevent the use of their mark by others. Trademark owners may provide a certified copy of a trademark registered upon the Principal Register of the U.S. Trademark Office (or other national equivalent thereof) issued more than one year prior to the commencement of the "daybreak" period. The registered mark must be for a word mark, exclusive of any graphical representations such as logos or specific typefaces.  Terms subject to pre-emption will be rendered unregistrable to any party.
2. Pre-registration - Trademark owners desiring to register their name in the .i TLD will be provided with the opportunity to do so during the "daybreak" period, subject to submission of a certified copy of a trademark registered upon the Principal Register of the U.S. Trademark Office (or other national equivalent thereof) issued more than one year prior to the commencement of the "daybreak" period. The fee for pre-registration will be the same as that for normal registration, with the addition of a one-time processing and handling fee.

Because the registry is not in a position to decide the "worthiest" among multiple owners of a trademark (e.g. Delta Airlines, Delta Faucets, or innumerable fraternities and sororities using the term "delta"), pre-registration will be provided to trademark owners on a first-come, first-served basis. A holder of a duplicate trademark in a pre-empted domain name will be allowed to obtain pre-registration upon submission of an application subsequent to the pre-emption. Subsequent pre-emption applications to a pre-registered domain name will be denied. This policy will allow for legitimate holders of a multiply-registered trademark to exercise their right to use the trademark without impairing the interest of other holders of that trademark in preventing unauthorized use.

Other trademark owners will remain with their remedies at law and under the UDRP.

One of the realities of pre-emption based on registered trademarks is that the set of all trademarks is not static, and trademarks are not permanent. Any Pre-Empted domain name may be removed from the set of Pre-Empted names upon a showing that the corresponding trademark registration has been cancelled, revoked, or judicially rendered invalid.

Domain names in the .i TLD are designated for use as personal identifiers, and are non-transferable.  Therefore, there is no incentive for registering large numbers of such domain names for speculative purposes. The domain name registration contract will require domain name registrants to provide and reasonably maintain accurate contact information.  Additionally domain name registrants will be required to receive and respond to any registry inquiry into the accuracy of the contact information. When the registry receives notice of  potentially inaccurate contact information, the registry will contact the registrant via a required registrant email address, and the registrant will be deemed to have received notice when the registry transmits a request for clarification of the contact information. Failure of the domain name registrant to respond to such notice within a reasonable period of time will result in revocation of the domain name registration. A record will be maintained of confirmed contact information, and to minimize the potential for harassment, no more than one confirmation request annually will be initiated by a third-party complaint.

The total number of domain names registered to any one individual will be subject to a reasonable maximum limit. Domain name registrations in excess of the limit may be granted upon a showing of reasonable cause.

The U.S. Lanham Act specifically exempts registrars from cybersquatting liability, provided that the registration authority provides a registration certificate for allowing a court to effect control of a disputed domain name and that the domain name registration cannot be altered as set forth in 15 U.S.C. §1125(d)(2)(D)(i-ii)). The .i TLD registry will maintain domain name registration status in a non-modifiable condition pursuant to notice of such legal action, and shall require any authorized .i TLD registrars to likewise comply with such notification. Additionally, The .i TLD registry and/or its authorized registrars will surrender control of any judicially disputed domain name to the court having jurisdiction over the dispute, and will comply with any order of such court in maintaining or transferring the disputed domain name registration.

There is no known finite list of "famous trademarks". U.S. dilution law has established a judicial definition of a "famous" mark, which relies upon evaluation of several subjective factors. Merely determining whether a single mark is "famous" requires considerable fact-finding during litigation, and there is no known objective mechanism for identifying famous marks in the absence of a judicial determination. Presumably, any holder of a famous mark will be able to meet the criteria for obtaining pre-emption and/or pre-registration during the "daybreak" period, which merely requires ownership of a registered mark.

All domain name registrants will be required to provide accurate registration information including the registrant's name, postal address, telephone number, and nameserver addresses, and to certify that the information is correct. A Whois central directory shall be maintained by which the registrant's contact can be obtained in response to a manual query identifying any particular domain name.  Additionally, the Whois directory will indicate the total number of domain names registered to that individual. Registrars will have the option of maintaining Whois data in a registry-queriable database, in order to preserve the registrar’s rights to the customer data, or of offloading their Whois data to a registry-maintained database, if the registrar opts not to be burdened by maintaining the data. This registrar option will be reflected in a differential wholesale pricing schedule. A single central publicly-queriable Whois database will thus be made available at the registry level, subject to the following operational qualifications. Registrars, while required to provide the registry with Whois access, will not be allowed to provide public access to Whois data. Such access will be provided exclusively at the registry level in order to maintain control over the disclosures of personal information, and to provide a standard comprehensive interface.

Experience with Whois data in the .com, .net, and .org TLD's indicates that Whois directory information is commonly abused by mass advertisers using mail, telephone and email addresses for the distribution of commercial solicitations.  Unfettered automated access to Whois data has been identified by ICANN as contributing to a "threat to the stable operation of the registration system" (see ICANN Amicus Curiae Memorandum in Register.com, Inc v. Verio Inc., 22 September 2000, Section A). Additionally, Whois information is abused by persons with criminal intent. Hence, the information provided in response to a public query of the central Whois interface maintained by the registry will be restricted to the name of the registrant and an indication of the number, but not the identity, of the .i domain names registered to that registrant. Further information will be made available for legitimate purposes as discussed below.

The privacy concerns of users must be balanced with the legitimate needs of trademark owners to enforce their rights under the ACPA and UDRP provisions that deem registration "pattern" evidence to be relevant to legitimate claims. It should be emphasized that the .i TLD non-transferability policy and naming convention restriction renders cybersquatting to be of minimal concern in the .i TLD, relative to gTLD’s with unrestricted naming conventions.

In order to maintain an appropriate balance, complete registration information in the .i TLD will be made available upon presentation of a legitimate inquiry indicating the name, address, and bar registration number of an attorney making the request and identifying the trademark sought to be enforced.  This information will be logged in connection with the IP address of the server from which the request is made, and results will be sent via email to provide an additional point of contact traceable to the requester.  Queries may be conducted by any key field of the registration data. In the event that a threshold frequency of Whois inquiries are logged from particular servers, or sent to particular email addresses further inquiries will be blocked pending verification of the bona fide purposes for which the Whois data is sought. Registered attorneys, once verified, will be excluded from the limitation mechanism, subject to their acknowledgment and certification that the data is being made available to them for trademark enforcement purposes, and is not licensed for any other use. Request information will be transmitted to the domain registrant when the inquiry is made, for such purposes as enforcement of any relevant restraining order and to provide a balance of information provided to the various parties and for registrant enforcement of attorney certification. This limitation to authorize attorneys, as officers of the judicial system, provides unfettered legitimate access, while reducing abuse.

This proposal is at once more limited and more extensive than current Whois policies. The data provided to anonymous public queries is more limited, but the data provided in response to a facially legitimate query is more extensive. The notice and exchange mechanism of query information should reduce the incidence of abuse or mass appropriation of Whois data for illicit purposes, and provide a reasonable compromise between the legitimate concerns of Internet users and those authorized to enforce trademarks.

Clearly, the use of a domain name incident to commercial activity infringing a trademark is also subject to enforcement by traditional means, since financial transactions incident to such commercial activity are traceable by other means. Where the injury to the trademark owner consists of a bare domain name registration, it should be recognized that such a hypothetical or potential injury is of lesser concern than actual economic harm. Again, no financial enrichment of the cybersquatter is possible due to the non-transfer provisions of the .i TLD.

The Uniform Dispute Resolution Policy as currently implemented and as may be revised, will be incorporated in all domain name registration contracts in the .i TLD. Additionally, subsequent similar domain names registered to a party determined to have registered domain names in bad faith will be subject to a "takedown" provision of the user registration contract.

In addition to implementation of the Uniform Dispute Resolution Policy, domain names in the .i TLD will be subject to a "takedown" provision. The current UDRP does not prevent a bad faith registrant from subsequently registering other minor variations of the same domain name. In the event that a party has formerly been found, under the UDRP or judicially, to have registered certain domain names in bad faith, then any subsequent similar domain name registrations to that party will be deleted or transferred upon notice of such prior decision by the complaining party in the prior dispute.

Directly-proposed SLD's will be subject to a publication and lottery procedure, which will provide interested intellectual property owners or watch services to be apprised of SLD proposals which may be of concern to intellectual property owners in advance of registration of a domain name. This procedure provides a mechanism of preventing disputes, rather than merely resolving them.

As noted above, limited Whois information will be made available on the terms discussed above. Of course, because domain names in the .i TLD are intended to be used as personal identifiers, the registrant should be available for contact via the domain name itself. Requests for Whois data beyond a predetermined threshold level will be subject to verification, and an exchange of data between the requesting party and the domain name registrant.

Whois data will be required to be maintained by trusted third parties for database restoration and integrity purposes in accordance with standard good practices. Access to escrowed registrar-maintained data can only be made for cause.

Not counting the registrations during the "daybreak" period, the .i registry will deal exclusively with accredited registrars as its wholesale customers. As such, the registry’s billing and collection operations will be geared towards the comparatively fewer registrars rather than the vast number of registrants. The registrars will retail to the end-users, the registrants, and follow their respective billing and collection polices.

The registrar intends to adopt existing industry standards for the billing and collection of domain name fees from the registrars as detailed in the NSI-Registrar License and Agreement.  Specifically, the terms of the agreement between the Proposed Registry and each of its Registrars shall require the Registrar to have in place a performance bond, letter of credit or equivalent instrument from a surety acceptable to the Registry (the "Surety Instrument"), in the amount of US $100,000. The terms of the Surety Instrument shall indemnify and hold harmless the Registry and its employees, directors, officers, representatives, agents, and affiliates from all costs and damages (including reasonable attorneys’ fees) which it may suffer by reason of Registrar’s failure to indemnify the Registry by making payment(s) up to the full amount of the bond within ten (10) days of the Registry’s having notified the surety of its claim(s) of damages, having identified the basis for any claim. The Registry shall not be entitled to payment under the Surety Instrument until such time as it has certified that it has incurred expenses for which it is entitled to reimbursement. Registrar privileges with the Registry will be suspended temporarily for any Registrar whose bills are outstanding more than 10 days until such time as adequate payment has been made.

The registry will generate revenues by charging a yearly fee for Second Tier and Third Tier (please see section E3 above) domain names registered under the TLD. After the initial startup period, the registrars will be charged for new domain name registrations as follows:

· $2.00 per year per Third Tier standard-form domain name

· $4.00 per year per Second Tier customized second-level (or higher) domain name

During the startup period, domain names will be registered on a lottery basis. The base registration fee may be determined by the number of participants in the lottery, in order to recover overhead costs based upon the volume of entry requests.  As more entrants enter a lottery, the final registration fee will increase. The domain name registration will be maintained by the registrar via which the lottery was entered, and the registrar will receive a proportionate share of the final registration fee for the domain name.

Furthermore, by providing a free personally selected alphanumeric domain name to anyone who wants to use our services, we are revolutionizing the price structure of the domain name registry business, prompting the development of value-added packages in combination with service providers and information appliance manufacturers for the benefit of the consumer.

Not applicable.

A "gold rush" mentality is not anticipated to apply to the .i TLD, hence there are no particular restrictions on registration of first tier domain names envisioned during the initial public period of registrations (aside from the pre-emption and pre-registration periods prior to opening the .i TLD to public registration). Incentives for a speculative rush to register will be limited by the following considerations:

1. There are expected to be no economic incentive for registering a large number of non-transferable domain names.
2. The use of a lottery period for user-proposed SLDs limits the rate at which new SLD's can be introduced.
3. The lottery provides an advance notice mechanism.
4. Dictionary words and geographic terms are excluded from registrability.
5. Pre-emption and pre-registration options will be provided to holders of registered trademarks as set forth above.

As noted above, a lottery system will be used to allocate user-selected domain names during an initial period of operation of the .i TLD. The lottery system will provide a check on the rate and volume of domain name registrations during the initial period.  Because the introduction of new TLD's is a new process, and demand is difficult to forecast, the lottery period will be phased out when requests for initiating a lottery have reached 10% of the peak value recorded during the first six months of operation. After the lottery has been phased out, the pool of perceived "premium" names, if any, and hence the opportunities for cybersquatting will be greatly reduced.

The domain name system, as originally developed, was merely intended as a mnemonic addressing system for resources on the Internet.  The domain name system was also intended to be expansible according to a tree-like structured hierarchy.  Prior to commercial activity on the Internet, the domain name system was a mere utilitarian convenience.

For better or for worse, domain names in the generic TLDs have taken on a significance well beyond any original expectation. Because second-level domain names were made freely registrable and transferable, several unintended consequences resulted.  First, the domain name space "flattened" out at the second level. This flattening prevents hierarchical expansion of the domain name space.  Therefore, the number of domain name registrations has increased in order to accommodate horizontal growth of the space, rather than ordered hierarchical growth. All common words and all significant geographic terms are registered to various individuals or companies.  Hence, the "genie" cannot be put back into the bottle in order to provide a structured addressing hierarchy in the existing generic TLDs.

A second result of unrestricted registrability and transferability is that domain names became commodities independent of their utilitarian purpose. Vast numbers of domain names are registered as commodities for auction, sale, or other unintended economic use, and many of those domain names are, in fact, unused as addresses for actual Internet resources.  Domain name warehousing contributes to further unstructured lateral expansion of the domain name space, because those desiring to actually use the Internet must register yet more domain names beyond those that are being held as commodities or collectors items, simply to employ the Internet for the purpose of communication.

A third result of unrestricted registrability has been an increased expense of intellectual property holders seeking to police and enforce rights in their trademarks. Dr. Jon Postel opined that the trademark problem was unsolvable. It is certain that there will always continue to be disputes over intellectual property, and it is necessary to have reasonable means for resolving them. More importantly, it is desirable in the introduction of new TLDs to learn from the past and to develop policies which reduce the opportunity for conflict, rather than to focus upon enhanced policing and enforcement mechanisms after the fact. The naming policies detailed in this application, including the principle that domain names are largely non-transferable, are designed to minimize the unsolvable problem identified by Dr. Postel.

The result of the economic, legal, and policy battles over domain names is that an important principle of the Internet has been lost - that the Internet is not intended specifically for commerce, or indeed for any other specific narrow purpose. The Internet is merely a medium - a conduit for interconnecting digital devices and thereby for connecting people. The Internet's potential for becoming the medium of connection among individuals should not be obscured or limited by lack of access or contention over what is, after all, merely an addressing system for that medium. The unintended consequences of unstructured development of the gTLD address space has allowed the addressing system to become a source of contention and conflict at the user level, and indeed within the Internet community itself. The addressing system for such a wonderful medium of connecting and drawing together people should not be an issue for driving them apart. The domain name system is simply an addressing mechanism, and it should be managed as such.

The .i TLD is intended to provide a clean slate for the development of a structured addressing system which is hierarchically expansible. Rather than to charter specific uses for the .i TLD, an ordered naming convention will be applied, so that there is room for expansion and reduced opportunities for conflict. The .i TLD will create a suitable name space to allow individuals to register a service provider-independent point of contact for configuring Internet-enabled applications to be offered by various vendors, and as an addressing mechanism for Internet-enabled devices. In contrast to the generic top-level domains, wherein domain names are primarily considered to constitute an online "identity", the .i TLD is intended to provide a cyberspace point of contact with an individual's pre-existing offline identity, and to allow them to reflect their identity in the addressing system. However, by structuring the individualization options within the addressing system in accordance with the .i TLD conventions and policies, room for growth is increased while room for conflict is decreased. As a mnemonic address, a domain name is intended to be memorable, although not necessarily "guessable", such as is desired within the commodified existing gTLD's.

Significant aspects of the policies that will promote egalitarian access, structured growth, and reduced conflict within the .i TLD are (a) non-transferability of domain names, (b) non-registrability of terms essential to building a semantic hierarchy, (c) pre-emptive measures for guarding against misappropriation of intellectual property, and (d) a lottery system for customized domain name assignment during startup. These policies, described above in further detail, address specific lessons learned from experience in the gTLDs, and correct for key problems which have led to contention among Internet users and in the Internet community, have distorted the growth of the domain name system, and have prevented orderly population of the domain name space. Just as the goal of the ICANN process is to introduce new TLD's in a measured and responsible manner, it is equally important within the .i TLD to introduce new domain names in a measured and responsible manner in order to create a stable and rational addressing hierarchy.

The .i TLD is not intended as an "alternative" to the traditional TLDs, and hence is not intended to provide competition for registrations in the traditional TLDs.  Because the .i TLD will be open for registration services offered by any ICANN-Accredited Registrar, competition for registration services will be maintained. However, the real area of competition will be among the providers of Internet-enabled applications and devices that will utilize the structured addressing mechanism provided by the .i TLD. It is in this area - freeing the individual from restrictions or service limitations imposed by the individual's access providers, and providing portability of access – where competition is sought to be enhanced.

While structured hierarchies have been available in nationally-identified TLDs, there are currently no TLDs which are available as an independent platform for commercial delivery of individual services. Competitive commercial promotion of individual services in the .i TLD hierarchy will stimulate user adoption of the .i TLD. Also, some nationally-identified TLDs have been commercially promoted on the basis of coincidental resemblance to meaningful use-prescriptive connotations (e.g. .tv, .md, .tm , and others). The single letter "i" is susceptible to broadly-prescriptive associations with "internet", "individual", and "identity, but does not also bear a geographic connotation. The .i TLD can thus be promoted as a global resource for individuals and internet-enabled devices.

The Sarnoff Corporation is a natural candidate for oversight responsibility in the .i TLD. The Sarnoff Corporation is not a consumer product company or service provider. Instead, the Sarnoff Corporation has a legacy as a leading and trusted developer of enabling platform technologies by which third party developers may enter new frontiers. The Sarnoff Corporation's neutrality among commercial developers utilizing Sarnoff developments, and commitment to expanding opportunities for competitive commercialization of new technologies are widely known. The objective of this proposal is to open new frontiers in the development and delivery of individualized personal services on a global scale and egalitarian basis. The Sarnoff Corporation possesses the technical depth and experience in collaborative development of new technologies to make the ideal of "the Internet for everyone" a reality.

Concepts to be proved in the introduction of the .i TLD include the feasibility of using the domain name system as an interface to applications that have not been traditionally associated with the DNS. Presently, domain names are primarily viewed as "web sites", and a limited number of protocols are employed by Internet users. The .i TLD is positioned as a central point of contact for individuals, rather than as passive sources of information or as "branding" opportunities for web sites.

Success or lack of success of the .i TLD should be evaluated according to its adoption by providers of configurable services that are intended to utilize the .i platform. The .i TLD is not intended as a commercial end in and of itself, but is intended as an enabling gateway to the growth of a market in the provision of Internet-enabled personal communication and information services. Hence, the .i TLD is not intended to "enhance the management of the DNS" so much as to enhance the utility of the Internet for individuals. After more than a decade and a half of operation, management of the DNS is a known technical function that, apart from political and intellectual property concerns, raises few issues. However, the Internet as a communication medium is capable of many further uses, and for providing individuals with a means of coordinating their communication options. The .i TLD is intended to provide a platform for further growth in the utility of the Internet for individual users.

The current .i TLD proposal includes policy provisions directed toward minimizing opportunities for abusive registration, domain speculation, and intellectual property infringement. Hence, the current proposal provides a limited test bed for evaluating the usefulness of "daybreak" or pre-emption policies, the use of a prior notification mechanism, and the use of a lottery system for allocating domain names for attaining these ends. In the first instance, there is limited incentive for cyber squatting in the .i TLD. Testing the utility of such pre-emptive policies in an environment having very little opportunity for abusive registration in the first instance will provide an indication of the practical considerations that will be more critical when such policies are sought to be implemented in less narrowly targeted, generic TLDs.

The .i TLD proposal will also demonstrate the potential of using a naming convention policy to effectively achieve the aims of a "chartered" TLD, while making registration of domain names within the TLD universally and readily accessible to individuals on a tiered basis of customization, with due regard for the legitimate concerns of intellectual property owners and registrants respectively.

The .i TLD will demonstrate the utility of a hierarchically organized addressing convention which is not artificially "flattened" at the second level, as in the presently-existing generic TLDs.

The .i TLD will demonstrate the utility of a registry-operated free domain registration system, which will allow third party technology and consumer product providers with the ability to bundle their promotional offerings of Internet-enabled devices with registration of the required addressing mechanism for such devices. The .i TLD will demonstrate this capability without drawing revenue from enhanced addressing services available from ICANN Accredited Registrars on a retail basis. An additional market opening is the possibility for partner relationships between consumer product developers and Internet registrars for new offerings of bundled technology/customizable registration packages.

By signing this application through its representative, the Applicant attests that the information contained in this Description of TLD Policies, and all referenced supporting documents, are true and accurate to the best of Applicant's knowledge.