.drive Domain

18.a. Mission/Purpose of the Proposed gTLD

Charleston Road Registry is an American company, wholly owned by Google, which was established to provide registry operator services to the Internet public. Google is an American multinational public corporation and global technology leader focused on improving the ways its hundreds of millions of users connect with information. Since its formation, Google has been developing technology that can improve upon existing ways of doing business on the Internet. Google provides a variety of services and tools for Internet users and advertisers of all sizes, from simple search features and local ads to enterprise-scale business applications and global advertising solutions. These tools make it easier for people to make use of the world's information and enable entrepreneurs and publishers around the world to grow their businesses.

In line with Google's general mission, Charleston Road Registry's mission is to help make information universally accessible and useful by extending the utility of the DNS while enhancing the performance, security, and stability of the Internet for users worldwide. Charleston Road Registry aspires to create unique web spaces where users can learn about Google products, services and information in a targeted manner and in ways never before seen on the Internet. Its business objective is to manage Google's gTLD portfolio and Google's registry operator business. As discussed further in the responses to questions 23 and 31, Charleston Road Registry intends to outsource all critical registry functions to Google Registry Services.

The sole purpose of the proposed gTLD, .drive, is to provide a dedicated Internet space where Google can continue to innovate on its Google Docs offerings. The mission of the proposed gTLD is to provide a tailored domain space in which to enact second-level domains that relate to the management and customization of an individual's, group's, or enterpriseʹs Google Docs account. Second-level domains in the proposed gTLD, .drive, will link to Googleʹs suite of document applications and other content hosted on a userʹs drive account. All registered domains will automatically be delegated to Google DNS servers, which will in turn provide authoritative DNS responses pointing the userʹs web browsers to the Drive service. The mission of the proposed gTLD is to simplify the Google user experience. Users will be able to manage a unique second-level domain (e.g., myname.drive, myorganization.drive) which will be used to host short and simple URLs that point to the userʹs account. This mission will enhance consumer choice by providing new availability in the second-level domain space, creating new layers of organization on the Internet, improving the Google user experience, and signaling the kind of content available in the domain.

The proposed gTLD will also provide Charleston Road Registry with the means to meet its business objectives.×

18.b. Benefits to Registrants, Internet Users, and Others

18.b.i.1. Specialty

Charleston Road Registry intends to apply for an exemption to ICANN's Registry Operator Code of Conduct and operate the proposed gTLD with Google as the sole registrar and registrant. The proposed gTLD will specifically align with Google Docs, an existing Google product, and will provide users with improved capabilities that meet their diverse needs.

The proposed gTLD will provide dedicated second-level domain space for the management of a userʹs Google Docs account. This specialization introduces a new gTLD environment that will generate new Google Docs namespace, and provide for streamlined, internal Google management of the introduction and phase out of new or retiring products and/or services within the domain.

This specialization offers Internet users Google services that will enhance their current and future experience with Google Docs. Google will manage a process whereby users will be able to make use of unique vanity names in the gTLD; such second-level domains will only point to the Google offering. This provides users with a distinctive namespace as they develop and implement a unique, customized vision for their use of Google Docs. Google strives to offer its customers leading edge tools that will not only enable them to better personalize their respective second-level domain experience, but also spur further creativity and generate new options on the Internet.

As the Internet is ever changing, these services will evolve to meet users' needs to the benefit of the Internet public. Google seeks to continuously provide tools that solve problems faced by Internet users, and, in partnership with Charleston Road Registry, the proposed gTLD will open the opportunity for Google to provide these customer-centric solutions.

18.b.i.2. Service Levels

Through its association with Google, Charleston Road Registry is uniquely positioned to enable and support the proposed gTLD by providing its service reliability and speed of delivery as a part of its services. Google brings unique expertise and a proven record of excellence in infrastructure operations: Google now runs the largest DNS system in the world, has industry-leading uptime on its services, such as web search, and offers enterprise services on which governments and businesses depend.

Charleston Road Registry's service level goal for the proposed gTLD is to ensure that Google, as the proposed sole registrant, is supported in delivering the high level of quality, speed, and service to users for which it is known. Indeed, two of Google's core principles in providing Internet search and related goods and services are "focus on the user and all else will follow" and "fast is better than slow."

In focusing on the user, Google strives to provide the best user experience possible. Google will continue to operate under this principle when designing new offerings and providing goods and services within the proposed gTLD.

Google keeps speed in mind with each new product it releases, from faster mobile applications to improved Web browsers designed for rapid search and navigation. Google continues to devote its resources to improving speed and efficiency. In managing the proposed gTLD, Google expects to keep its service reliability and speed to this standard through direct management of all technical infrastructure related to DNS resolution other than the operation of the root servers.

Charleston Road Registry is committed to using the most technologically advanced, secure, and reliable registry services for all of the domain names within the gTLD so as to not compromise the service levels, security, and stability of the gTLD to users across the globe.

18.b.i.3. Reputation

Google has a proven record of providing high-quality, secure online services. Charleston Road Registry seeks to enhance Google's reputation for excellence, superior quality, and high level of security and become known as an exemplary domain name services provider.

When Internet users visit a domain name in the proposed gTLD environment, they will be able to reliably expect and experience the high level of security and quality on which Google's reputation has been built.

The registry will be structured so that Google registers and manages domain names in the .drive gTLD, that those domain names are used for only Google Docs-related purposes, and that the registry is responsive to legal rights owners (if applicable).

As noted, Charleston Road Registry intends to apply for an exemption to ICANN's Registry Operator Code of Conduct and operate the proposed gTLD with Google as the sole registrar and registrant. This facilitates Google's ability to further enhance the brand and reputation of the Google offering.

In addition, Charleston Road Registry's operation of the new gTLD will provide the opportunity for users to build and/or bolster their unique brands or tailor unique user identities in association with the proposed gTLD and Google Docs.

18.b.ii.1. Competition

Charleston Road Registry supports the advancement of registry operators as a whole and the diffusion of gTLDs amongst diverse stakeholders to generate increased competition for the benefit of the Internet public. Increased competition will result in more competitive prices for consumers, generate efficiencies and increase productivity in enterprises, and spur innovation in the gTLD space.

Google will have with the opportunity to differentiate and innovate upon its Google Docs products and services through its use of the gTLD.

The proposed gTLD, .drive, will provide a new mechanism for the creation and management of a Google Docs account. Charleston Road Registry anticipates the .drive gTLD will help grow the volume of document management accounts on the Internet, thereby increasing competition among all entities that provide document management services.

The proposed gTLD will promote competition in the gTLD space by inciting competitors to respond with improved gTLD operations, greater range and higher quality products and services integrated with domain name offerings, and/or the creation of their own respective gTLDs, to the benefit of all Internet users. Launching the proposed gTLD will also generate increased competition in the online marketplace by adding incremental availability to the second-level domain pool.

Charleston Road Registry intends to apply for an exemption to the ICANN Registry Operator Code of Conduct and to act as the sole registrar for the proposed gTLD. Given that the proposed gTLD is exclusively intended for use in connection with Googleʹs services, Charleston Road Registry believes that there is a reasonable case for such an exemption. Should ICANN not approve this proposed exemption, Charleston Road Registry will facilitate a fair and equitable registrar process, providing open access to any registrar who meets ICANN accreditation guidelines.

18.b.ii.2. Differentiation

The proposed gTLD will clearly be differentiated from other gTLDs due to its purposefully limited scope. This differentiation includes: (1) uniqueness in terms of the users the proposed gTLD seeks to benefit; (2) a clear indicator that second-level domains within the gTLD offer a particular, targeted content; (3) and because the gTLD will be associated with a Google offering, Internet users will immediately be able to rely on the quality of the product.

The gTLD will provide an authoritative environment for the provision of Google Docs offerings. New, higher quality products offered in the gTLD will also attract new users to the Google offering.

The .drive gTLD will provide Google with the opportunity to differentiate its offerings from other document management providers by virtue of its branded gTLD. This signification is not currently available in the gTLD space.

The proposed gTLD will also encourage differentiation among users. Google's services, including tools to improve and customize users' unique Google Docs experiences, will provide users with new ways of distinguishing themselves from others.

18.b.ii.3. Innovation

The proposed gTLD is in itself innovative, as it seamlessly combines DNS services with other Google products and services. The proposed gTLD will promote further innovation by creating a new space for the categorization and classification of online content. It will also provide services to users that will enable them to improve their interaction with Google Docs on the Internet. This environment delivers value to the public by introducing new and differentiated content, goods and services.

The proposed gTLD, .drive, will promote innovation by encouraging competitors of Google to provide linkages that fulfill the same need as Google will provide with its document management offerings. In addition, Google may choose to innovate within its portfolio of web spaces and introduce distinguishing feature(s) that will further crystallize the relationship between content offered in the gTLD and the Google brand and reputation. This will likely invite user comparison among domains, encouraging other document management services providers to innovate new features and services as a point of differentiation.

Charleston Road Registry considers the proposed gTLD to be a platform for innovation with existing and future Google products and services. Charleston Road Registry, therefore, may incorporate these new offerings into future registry service options (subject to the ICANN approval process), infusing new ideas into the gTLD for the betterment of the public.

Google consistently aims to improve upon technologies that connect people with information, as demonstrated by a proven record of innovation and iteration. Charleston Road Registry strives to offer its users this same level of continuous development in advancing its management and operation of the gTLD, engendering an improved user experience.

18.b.iii. User Experience

Charleston Road Registry will strive to provide the highest level of user experience through operational stability, security and performance to serve the interest of users in the proposed gTLD. Charleston Road Registry is uniquely positioned to provide this level of experience given its relationship with Google; per its SEC filings, Google invested over $3 billion in its IT infrastructure in 2011 and maintains a record of excellence in infrastructure operations.

Google keeps user experience in mind with each new service it releases, from allowing users to personalize their Gmail accounts to providing small to medium businesses with tools customized for their specific needs. The proposed gTLD provides Google with a formal mechanism whereby it can continue to improve its services to address the ever-changing needs of all Internet users.

The proposed gTLD, furthermore, facilitates an improved online user experience by provisioning the DNS on users' behalf and streamlining the process by which users are able to link to and make use of the Google offering.

The proposed gTLD, .drive, will provide users with an improved Google Docs experience by allowing for users' direct management of their respective content within the .drive gTLD.

In focusing on the user, Google strives to provide the best user experience possible. Google will continue to operate under this principle when designing and providing new service offerings in the proposed gTLD. The proposed gTLD will provide users with improved customization services and facilitate additional opportunities to enhance their current and future experience with Google Docs.

The proposed gTLD will provide a more trusted and user-friendly environment where domain names and content related to the .drive gTLD can flourish. Charleston Road Registry seeks to have users deem the gTLD trustworthy and reliable and recognize it as an aggregated source of specific goods, services, and information.

Lastly, the proposed gTLD improves the Internet user experience by creating greater structure and categorization on the Internet.

18.b.iv. Registration Policies

Because the sole purpose of the proposed gTLD is to associate domain names with the Google Docs product, Charleston Road Registry intends to apply for an exemption to the ICANN Registry Operator Code of Conduct and operate the gTLD with Google as the sole registrar and registrant. As the sole registrant, Google will have the opportunity to differentiate and innovate upon its Google Docs products and services through its use of the gTLD.

Given the proposed limited scope and use of the gTLD, Charleston Road Registry believes that there is a reasonable case for such an exemption. Should ICANN not condone this proposed exemption, Charleston Road Registry will make access to Registry Services, including the shared registration system, available to all ICANN-accredited registrars.

Charleston Road Registry believes that given its specific use, the .drive gTLD will best add value to the gTLD space by limiting all second-level domains to the sole use of pointing to Google Docs offerings. Google will manage a process whereby users will be able to make use of unique vanity names in the gTLD; such second-level domains will only point to the Google Docs offering. In addition, only entities and individuals with a Google log-in or those who register for a new account in the registration process may register within the gTLD.

Charleston Road Registry is committed to implementing strong and integrated intellectual property rights protection mechanisms. Doing so is critical to Google's goals of model Internet citizenship and fostering Internet development, especially in emerging regions. Accordingly, Charleston Road Registry intends to offer a suite of rights protection measures, which builds upon ICANNʹs required policies while fulfilling its commitment to encouraging innovation, competition and choice on the Internet.

18.b.v. Protection of Privacy and Confidential Information

Charleston Road Registry will strive to ensure the appropriate level of privacy and security will be met for its users. Although Google will be the only registrant (and is intended to serve as the only registrar for the gTLD as well), Charleston Road Registry and its provider of registry services, Google, have imposed measures to achieve this protection for their users; additional specifics regarding the practices for the registry include but are not limited to the following:

- Since Google will be the only registrant, personally identifying information regarding individual users will not be sent to or stored by the registry. Such data will remain on Google's infrastructure used to provide the individual service, and is subject to Google's existing privacy policy.

- Charleston Road Registry will attempt to prevent the misuse of WHOIS data for improper purposes such as spam, intellectual property theft or phishing. Charleston Road Registry will attempt to identify patterns of abusive usage of the WHOIS service and will appropriately use CAPTCHA, query throttling or other techniques to prevent information scraping.

- Google will restrict access to data and information systems maintained by the registry to a specific list of individuals involved with supporting the Google Registry system in production. Google will review this list on a periodic basis to ensure that the level of access granted to individuals is appropriate. Google uses two-factor authentication and other mechanisms to ensure that staff with access to user information are properly identified prior to using registry systems.

- In the event that other registrars are involved, registrar billing and payment information will not be stored alongside domain name registration information. All registrar billing and payment information will be stored in a PCI-compliant billing system similar to that used by Google Ads.

Beyond these specific mechanisms, both Charleston Road Registry and Google will govern its approach to privacy by the Google Privacy Policy. This policy applies to registrars, registrants and end users of registry services such as DNS zone publication and WHOIS data publication. The Privacy Policy is located at http://www.google.com/policies/privacy/.

18.b.vi. Outreach and Communications Efforts

Once Google begins developing public-facing resources in its gTLD, it intends to inform the public about the gTLD and the opportunity for users to obtain domain space there through marketing and public relation investments.

Charleston Road Registry, in conjunction with Google, intends to promote gTLDs under its purview collectively, such that the public gains an awareness and understanding of new gTLDs and the availability of new second-level domain space on the Internet. Charleston Road Registry and Google believe that this approach will make the strongest impact in modifying consumer behavior and is the best path to achieving success for all new gTLDs collectively.

Charleston Road Registry and Google will reach out to the Internet community via a number of different outreach and communications methods and venues to deliver its mission and message to the public, including but not limited to: press briefings, videos posted on various Internet sites, blogs and other social media, and paid advertising. In addition, when developing resources for localized Internet registrars in different global regions, Google will use local marketing and communications platforms as needed.×

18.c. Minimizing Social Costs and Other Negative Consequences

18.c.i
Should ICANN grant Charleston Road Registry's exemption to the Code of Conduct, and the proposed gTLD operate with Google as the sole registrar and registrant, members of the public will not be able to directly register domain names in this new gTLD. Users will, however, be given the opportunity to make use of a vanity second-level domain as a memorable identifier linked to content in Google Docs. Users will be assigned a vanity domain name pursuant to Google's forthcoming user registration guidelines. In addition, Google will follow ICANN rules for attributions of trademarked second-level domains and will offer other protections for trademark owners, including but not limited to an extended Trademark Claims Service of indefinite length.

18.c.ii
Should ICANN grant Charleston Road Registry's exemption to the Code of Conduct, the proposed gTLD will operate with Google as the sole registrar and registrant. As registrations will be granted based on Google business needs and user demand, Charleston Road Registry will charge prices commensurate with overall business costs. Charleston Road Registry does not intend but reserves the right to offer introductory discounts and bulk registration discounts to this sole registrant.

18.c.iii
Should ICANN grant Charleston Road Registry's exemption to the Code of Conduct, the proposed gTLD operate with Google as the sole registrar and registrant. As registrations will be granted based on Google business needs and user demand, Charleston Road Registry will charge prices commensurate with overall business costs. Contractual commitments to registrants regarding price escalation are not relevant to Google's mission or goals for the new gTLD at this time, as Google is the sole registrant.×

As specified throughout this application, Charleston Road Registry (CRR) plans to implement comprehensive anti-abuse mechanisms. CRR will protect against the abusive registration of geographic names at the second and other levels in the applied-for gTLD by reserving to the registry protected geographic names in order to prevent registration of such strings.

In that regard, CRR has thoroughly reviewed Specification 5 of the Registry Agreement, the Government Advisory Committee's (GAC) "Principles Regarding New gTLDs", and the .info methodology for reservation and release of country names. Accordingly, CRR will, in connection with its registry services operator and registrar, initially reserve from registration by any party names with national or geographic significance within the TLD during the TLD's Sunrise Period and Trademark Claims Period.

The names with national or geographic significance (hereto referred to as "geographic names") that will be initially blocked are those specified in Specification 5 of the New gTLD Registry Agreement, namely:

(1) The short form (in English) of all country and territory names contained on the ISO 3166-1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union;
(2) The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and
(3) The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

As noted above, the top-level domain shall not permit the public to register domain names with national or geographic significant at the second-level. The names will be set aside by use of the Reserved state making them inaccessible (See response to Question 27 for details). Google, as the registry services provider, has arranged for such reservation to occur prior to the launch of the TLD.

In the event there is a compelling use of a two-character geographic name, the two-character label string may be released to the extent that CRR reaches agreement with the government and country-code manager and consults with the GAC and ICANN. The Registry may also propose the future release of these reserved names based on the implementation by the prospective registrant of measures to avoid confusion with the corresponding country codes.

As with the .info TLD, only if a potential second-level domain registrant makes a proper showing of governmental support for country or territorial names will CRR relay this request to ICANN. CRR also plans to consult with the GAC and of ICANN before proceeding to delegate the domain at issue.
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