.analytics Domain

18.1 MISSION AND PURPOSE OF .ANALYTICS

Campus IP LLC has filed this application for a .ANALYTICS gTLD to serve as a trusted, hierarchical, and intuitive namespace for general and business software-related information, as well as the goods and services that its parent company, SAS Institute, provides to its customers on a global basis. As a Registry Operator, Campus IP LLC will be entrusted to provide domain name registration services to SAS Institute, its qualified subsidiaries and affiliates, and/or any other designated third party.

Although Campus IP LLC is committed to moving forward with a .ANALYTICS gTLD application, at the time of filing this application there has not been enough time or market information available to fully analyze and evaluate all potential use case options.

18.1.1 CAMPUS IP LLC AND SAS INSTITUTE

Campus IP LLC is a wholly-owned subsidiary of SAS Institute. SAS Institute is the leader in business analytics software and services, and the largest independent vendor in the business intelligence market. SAS Institute provides an integrated set of software products and services to more than 45,000 customer sites in 118 countries. SAS Institute is a global company with more than 12,500 employees in local and regional offices in 54 countries.

SAS Institute's name is synonymous in the business world with high-quality analytics software and solutions. In fact, SAS Institute is well-known for its extensive product line of analytical solutions, which are designed to provide an integrated environment for predictive and descriptive modeling, data mining, text analytics, forecasting, optimization, simulation, experimental design and more. Therefore, SAS Institute, through its wholly owned subsidiary, Campus IP LLC, is proceeding with an application for the .ANALYTICS gTLD.

18.1.2 Mission and Purpose

Campus IP LLC currently plans a four-stage rollout for its .ANALYTICS gTLD:

1. Stage 1
The initial stage of implementation of the gTLD will involve SAS Institute registering a limited number of .ANALYTICS second-level domain names.

This initial use will provide Campus IP LLCʹs and SAS Institute's IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .ANALYTICS gTLD domain names, interoperability with various software and Web-based applications, and unbroken and secure use of all names. This initial allocation will also allow the appropriate Campus IP LLC staff to coordinate with the internal and external staff responsible for the delegation and setup phases of the .ANALYTICS gTLD to ensure a proper transition from delegation to full operation.

2. Stage 2
Once all testing has been successfully completed, Campus IP LLC will begin allocating domain names in .ANALYTICS to SAS Institute for more widespread corporate use. During this same period of time, SAS Institute will begin evaluating strategies to potentially migrate traffic away from its current patchwork network of second-level domain names, which are registered in a variety of TLDs, to the .ANALYTICS gTLD.

It is in Stage 2 that SAS Institute will evaluate expanding the operations of the gTLD to permit registration by other registrants such as licensees or strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other parties, this expansion is currently planned to take place during Stage 3. However, any expansion would be conditioned upon a review of the Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Campus IP LLC's business model.

3. Stage 3
Depending on the analysis of the evaluations undertaken in Stage 2, Campus IP LLC may implement the permanent migration of Internet traffic away from the TLDs in which SAS Institute's domain names are currently registered, and toward the new .ANALYTICS gTLD. It is in this stage that Campus IP LLC also may implement SAS Institute's decision to extend registration rights to licensees or strategic partners, depending upon compliance with Specification 9 as noted above.

After consideration of the following factors: analysis of SAS Institute's existing domain name portfolio; internal analysis of marketing initiatives; and the fact that SAS Institute will have full control over the number of registrations in the .ANALYTICS gTLD namespace, Campus IP LLC is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.

4. Stage 4
Based on its experience during the initial stages of operation and upon its experience with any expansion implemented in Stage 3, Campus IP LLC and SAS Institute will assess whether the business plan and expansion strategy should be augmented by extending registration rights to a broader class of registrants, potentially including other third parties and customers of SAS Institute. It is anticipated by SAS Institute that changes to the domain name industry, and particularly the impact of restricted gTLDs, will take at least five years to be realized and assessed. Any decision to expand the gTLD beyond corporate, qualified subsidiary/affiliate, and licensee/partner use will take into account this experience as well as the technical analysis of potential expansion.

The potential use of the .ANALYTICS gTLD will also be driven by SAS Institute's future business strategies as identified in its publicly available corporation information, see http://www.sas.com/company/.

Utilizing current projections based upon SAS Institute's existing businesses, future business plans, current domain name portfolio, and other strategic factors, Campus IP LLC estimates second-level domain name registrations to be in line with the projections set forth in the Financial Template provided in its response to Question 46 of this application.×

18.2 HOW DO YOU EXPECT THAT YOUR PROPOSED GTLD WILL BENEFIT REGISTRANTS, INTERNET USERS, AND OTHERS?

Campus IP LLC and SAS Institute believe that a proposed .ANALYTICS gTLD has the potential to offer the following benefits to Internet users and consumers:

- Establish a trusted portal for existing clients as well as a source of information and an online destination for the millions of customers that seek information about SAS Institute products or who purchase goods and services through SAS Institute's trained sales staff; for investors and third parties seeking information; and for the general Internet user population;
- Provide SAS Institute with short and memorable Internet addresses that enable increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc;
- Eliminate the cost of, and need for, defensive registrations by other brands because domain names will only be allocated by Campus IP LLC to SAS Institute and its qualified subsidiaries and affiliates;
- Develop a potential platform for the secure access to, purchase of, and distribution of SAS Institute products and information to customers in order to minimize the potential for counterfeit or infringing goods and services; and
- Increase consumer awareness to potentially minimize incidents of phishing and malware often associated with domain names that incorporate the SAS mark, or variations of said mark (typos), that are registered by cybersquatters and/or criminal elements.

Additionally, SAS Institute maintains country-specific websites for its customers around the world and maintains multi-lingual websites for many of its markets. Most SAS Institute websites are hosted through the SAS.com website and follow the naming convention: SAS.com/offices/REGION/COUNTRY. For example, the website for France is available at SAS.com/offices/europe/france. As identified in the response to Question 22 of this application, Campus IP LLC believes that the potential use of geographic identifiers at the second level would be an innovative convention and would be highly beneficial for a global company such as SAS Institute.

18.2.1 WHAT IS THE GOAL OF YOUR PROPOSED GTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS, OR REPUTATION?

The primary mission and purpose of the .ANALYTICS gTLD is to provide a trusted, hierarchical, and intuitive online destination to deliver thought leadership content on analytics, SAS Institute content, information on SAS Institute's product lines, business, focus, and other goods and services. As SAS Institute continues to expand, it is the company's desire to pursue and develop opportunities to market and distribute its online content and products to consumers throughout the United States and internationally on various platforms, including the Internet and mobile devices, among others. Given that customers increasingly demand access to SAS Institute products and services through a variety of channels, which include domain names and the address bar, SAS Institute and Campus IP LLC believe that a .ANALYTICS gTLD has the potential to provide an innovative, virtual avenue to SAS Instituteʹs products that will deepen and broaden its relationship with customers.

Most importantly, SAS Institute will be able to provide access to its products and online content in a namespace void of piracy, cybersquatting, and other malicious activities. Providing consumers with a trusted experience is paramount to SAS Institute, and a .ANALYTICS gTLD will be used to further that goal.

While business software companies such as SAS Institute fight a never-ending battle to protect valuable intellectual property from piracy on the Internet, a .ANALYTICS gTLD would offer customers a safe and intuitive means of accessing authorized content from SAS Institute and its qualified subsidiaries and affiliates.

Campus IP LLC and SAS Institute are supportive of existing anti-cybersquatting legislation and consumer protection measures, including the U.S. Anti-Cybersquatting Consumer Protection Act (ACPA) and others. As both Campus IP LLC and SAS Institute invest in expanding the domain name space through the establishment of a .ANALYTICS gTLD, they will also actively prevent cybersquatting, fraud, phishing, and other malicious activities within the .ANALYTICS gTLD. Maintaining the highest standards within the .ANALYTICS gTLD will give Campus IP LLC and SAS Institute the opportunity to take a proactive approach to protecting intellectual property rights and fostering a cleaner, safer online experience for all Internet users.

18.2.2 WHAT DO YOU ANTICIPATE YOUR PROPOSED GTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?

As a restricted gTLD, the primary driving factors of the .ANALYTICS gTLD are security, customization, differentiation, and innovation. The number of domain names registered will not measure the success of the gTLD, but rather success will be judged by the level of consumer recognition and trust that is placed in the .ANALYTICS gTLD. Using these levels as benchmarks, Campus IP LLC and SAS Institute will strive to build consumer recognition and trust in the usage of the .ANALYTICS gTLD that rise to the levels found in the .EDU and .GOV gTLDs.

As noted above, SAS Institute is a leading global business software company that leverages numerous distribution channels and emerging technologies to deliver its online content, products, and services to its customers internationally. A .ANALYTICS gTLD has the potential to serve as a cornerstone of this online strategy.

18.2.3 WHAT GOALS DOES YOUR PROPOSED GTLD HAVE IN TERMS OF USER EXPERIENCE?

Campus IP LLC believes that the .ANALYTICS gTLD will provide a trusted ecosystem experience for the millions of customers worldwide that leverage the company's business software products and services, as well as those who seek information that SAS Institute provides, such as potential clients, partners, job seekers, and members of the general Internet community. In addition to providing customers with short, memorable, and intuitive domain names, customers will know all domains and content are owned and controlled by SAS Institute or a qualified subsidiary or affiliate, thus protecting users from potentially infringing, counterfeit, or harmful content within the .ANALYTICS gTLD.

The initial use of the .ANALYTICS gTLD will be primarily defensive in nature, with Campus IP LLC and SAS Institute registering a limited number of second-level domain names. This initial use will provide Campus IP LLC's and SAS Instituteʹs IT and security personnel the ability to run a number of tests to ensure seamless and secure access to SAS Institute's websites and interoperability with various software and Web/mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Campus IP LLC will likely begin allocating domain names for internal corporate use and may redirect new .ANALYTICS domain names to pre-existing content. This phased rollout will likely take place over a multi-year period, but is subject to change depending upon a range of external factors.

During this same period of time, Campus IP LLC will evaluate strategies to potentially migrate traffic away from the current network of second-level domains registered in various gTLDs to the .ANALYTICS gTLD. This will provide customers with a centralized, trusted online source for SAS Instituteʹs products and services.

18.2.4 PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANT'S INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.

Campus IP LLC currently intends for the .ANALYTICS gTLD to be exclusively used by SAS Institute and its qualified subsidiaries and affiliates, of which Campus IP LLC is one. Because of this controlled use, any registration and use requirements are more appropriately vested in corporate/affiliate agreements and not in a domain name registration agreement. Any registration and use requirements (e.g., trademark quality control provisions) must vest in these other agreements.
Notwithstanding these concerns, Campus IP LLC will incorporate all required ICANN consensus policies and other legal/policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each party will execute.

18.2.5 WILL YOUR PROPOSED GTLD IMPOSE ANY MEASURES FOR PROTECTING THE PRIVACY OR CONFIDENTIAL INFORMATION OF REGISTRANTS OR USERS? IF SO, PLEASE DESCRIBE ANY SUCH MEASURES.

As a global business software company, SAS Institute and its subsidiary, Campus IP LLC, recognize firsthand that privacy protection is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will initially be registered to SAS Institute or a qualified subsidiary or affiliate of SAS Institute, Campus IP LLC and SAS Institute have a vested interest to ensure that accurate and current domain name information is readily available in connection with each .ANALYTICS domain name. SAS Institute's current privacy policy is available online at http://www.sas.com/Privacy.html. It is anticipated that Campus IP LLC will seek to operate its gTLD in a manner that is consistent with this corporate policy, provided that it is not in conflict with any ICANN consensus policy.

In addition, Campus IP LLC intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states, "Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person ("Personal Data") submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.ʺ

18.2.6 DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.

In addition to the factors noted above, Campus IP LLC's driving factor in securing a .ANALYTICS gTLD in ICANN's first round is strategic in nature and, while Campus IP LLC and SAS Institute see the potential for this gTLD to play a large role in SAS Institute's future online strategic initiatives, there are a number of unanswered questions concerning consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace that will influence the usage of the gTLD and communication about that usage.

Notwithstanding these concerns, Campus IP LLC's current best thinking involves the implementation of .ANALYTICS domain names in a multi-stage approach set forth in Section 18.1.2 above. The actual usage of .ANALYTICS domain names will dictate what public communications and consumer outreach initiatives are undertaken to encourage navigation to the .ANALYTICS gTLD. This is not limited to, but may include advertising, media outreach, email campaigns, etc.
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18.3 WHAT OPERATING RULES WILL YOU ADOPT TO ELIMINATE OR MINIMIZE SOCIAL COSTS (E.G., TIME OR FINANCIAL RESOURCE COSTS, AS WELL AS VARIOUS TYPES OF CONSUMER VULNERABILITIES)?

Campus IP LLC's proposed operating rules to initially limit registration to SAS Institute and its qualified subsidiaries and affiliates will provide a trusted online environment for customers to access SAS Institute's online content and, by default, will minimize social costs. This verified ecosystem will provide customers with a centralized, trusted source for SAS Institute goods and services with a substantially lower risk of fraud and/or scams.

Campus IP LLC does not anticipate consumer vulnerabilities. In addition, there is no need for other trademark and brand owners to defensively register second-level domains in the gTLD. In fact, Campus IP LLC's expectation is that the usage of a .ANALYTICS gTLD will eliminate many of the vulnerabilities that SAS Institute customers and consumers face on the wider Internet today.

18.3.1 WHAT OTHER STEPS WILL YOU TAKE TO MINIMIZE NEGATIVE CONSEQUENCES/COSTS IMPOSED UPON CONSUMERS?

Campus IP LLC believes that the proposed operation of the .ANALYTICS gTLD as set forth in this application has no known negative consequences or cost implications to consumers. To the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to consumers by providing a unified framework for the access to, and distribution of, SAS Institute's goods and services, instead of the current patchwork of domain names registered across various gTLDs and ccTLDs.

18.3.2 HOW WILL MULTIPLE APPLICATIONS FOR A PARTICULAR DOMAIN NAME BE RESOLVED, FOR EXAMPLE, BY AUCTION OR ON A FIRST-COME/FIRST-SERVE BASIS?

Campus IP LLC does not envision multiple applicants for the same domain name, as domain names will initially only be allocated to SAS Institute and its qualified subsidiaries and affiliates.

18.3.3 EXPLAIN ANY COST BENEFITS FOR REGISTRANTS YOU INTEND TO IMPLEMENT (E.G., ADVANTAGEOUS PRICING, INTRODUCTORY DISCOUNTS, BULK REGISTRATION DISCOUNTS).

Campus IP LLC does not envision any pricing, introductory, or bulk registration discounts because these marketing/commercial initiatives are inconsistent with the mission and purpose of the .ANALYTICS gTLD as a trusted online source identifier. However, should Campus IP LLC, at some future date, consider permitting third parties (customers) to register domain names in the .ANALYTICS gTLD, Campus IP LLC would reevaluate this practice at that time.

18.3.4 NOTE THAT THE REGISTRY AGREEMENT REQUIRES THAT REGISTRARS BE OFFERED THE OPTION TO OBTAIN INITIAL DOMAIN NAME REGISTRATIONS FOR PERIODS OF ONE TO TEN YEARS AT THE DISCRETION OF THE REGISTRAR, BUT NO GREATER THAN TEN YEARS. ADDITIONALLY, THE REGISTRY AGREEMENT REQUIRES ADVANCE WRITTEN NOTICE OF PRICE INCREASES. DO YOU INTEND TO MAKE CONTRACTUAL COMMITMENTS TO REGISTRANTS REGARDING THE MAGNITUDE OF PRICE ESCALATION? IF SO, PLEASE DESCRIBE YOUR PLANS.

Campus IP LLC is committed to providing the domain name registration periods set forth in the Registry Agreement. However, as noted above, because this will be a restricted gTLD, the registration and use of the domain name is conditioned upon a separate contractual relationship with SAS Institute. Therefore, providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate. That said, the .ANALYTICS domain agreements will be in accordance with all ICANN requirements.
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22 Campus IP LLC Has Properly Researched This Topic

Campus IP LLC, a wholly owned subsidiary of SAS Institute, is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the Domain Name System (DNS). In preparation for answering this question, Campus IP LLC reviewed the following relevant background material regarding the protection of geographic names in the DNS:

--ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain, see http://www.icann.org/en/minutes/minutes-10sep01.htm;
--ICANN's Proposed Action Plan on .INFO Country Names, see http://www.icann.org/en/meetings/montevideo/action-plan-country-names-09oct01.htm;
--Report of the Second WIPO Internet Domain Name Process: The Recognition and Rights and the Use of Names in the Internet Domain Name System, Section 6, Geographical Identifiers, see http://www.wipo.int/amc/en/processes/process2/report/html/report.html;
--ICANN's Governmental Advisory Committee (GAC) Principles Regarding New gTLDs, see https://gacweb.icann.org/download/attachments/1540128/gTLD_principles_0.pdf?version=1&modificationDate=1312358178000;
--ICANN's Generic Names Supporting Organization Reserved Names Working Group - Final Report, see http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.htm.

22.1 Initial Reservation of Country and Territory Names

Campus IP LLC is committed to initially reserving the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and all other levels within the .ANALYTICS generic top-level domain (gTLD) at which Campus IP LLC will provide for registrations. Specifically, Campus IP LLC will reserve:

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, see: http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166-1_decoding_table.htm#EU;

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 six official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

22.2 Fair & Non-Misleading Use of Geographical Identifiers

Campus IP LLCʹs parent company, SAS Institute, is the leader in business analytics software and services, and the largest independent vendor in the business intelligence market. SAS Institute provides an integrated set of software products and services to more than 45,000 customer sites in 118 countries. SAS Institute is a global company with more than 12,500 employees in local and regional offices in 54 countries.

Today the SAS.com website serves as a source of news, brand information, and a digital catalog of the brand's entire line of products. SAS Institute makes regular use of Internet technology that allows users to quickly find local content and offices. SAS Institute maintains country-specific websites for its customers around the world and maintains multi-lingual websites for many of its markets. Most SAS Institute websites are hosted through the SAS.com website and follow the naming convention: SAS.com/offices/REGION/COUNTRY. For example, the SAS website for France is available at SAS.com/offices/europe/france.

Given this geographic approach to finding SAS Institute content, and given that SAS Institute offers its products to countries all around the world, Campus IP LLC intends to explore the option of providing a hierarchical and intuitive framework for the .ANALYTICS namespace by using geographical identifiers at the second level within the .ANALYTICS namespace.

This use of geographical identifiers to the left of the gTLD and as part of the domain name itself is believed to have a direct and material impact on search engine algorithms and their corresponding query results. In addition, such naming conventions are intuitive and practiced by direct navigation Internet users (those that type their intended destination into address bars opposed to search engines). Campus IP LLC would like to see if this type of hierarchical and intuitive use of second-level domain names within its .ANALYTICS gTLD provides increased consumer functionality and drives innovation.


22.3 The Legal Protection of Geographical Identifiers

One of the more authoritative resources on the current state of the law in connection with the protection of geographical identifiers was authored by the World Intellectual Property Organization (WIPO) in its 2001 "Report of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name System" report (ʺWIPO Reportʺ). Section six of this report was devoted exclusively to the protection of geographical identifiers.

From its analysis of the well established framework against the misuse of geographical identifiers at the international, regional, and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications (See WIPO Report Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in SAS Institute's current or Campus IP LLCʹs proposed use of geographical identifiers.

Notwithstanding WIPO's recommendation that the protection of geographical identifiers is "a difficult area on which views are not only divided, but also ardently held" (Paragraph 237), national governments within the ICANN Governmental Advisory Committee (GAC) and other international fora have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the DNS.

SAS Institute, acting as a responsible international business, and Campus IP LLC seek to minimize any potential business practices that might mislead consumers. At the same time, however, Campus IP LLC believes that it is important to be able to use geographical identifiers in a fair and non-misleading manner, if such use can benefit Internet users as proposed in Campus IP LLC's business model.


22.4 Fair & Non-Misleading Use of Geographical Identifiers

In undertaking a thorough research of this subject matter prior to filing this application, Campus IP LLC's subject matter experts were able to uncover the following representative sampling of fair and non-misleading use of geographical identifiers used in the existing gTLD domain name space:

Fair Use of National Geographical Identifiers

AUSTRALIA.COOP - Is operated by Co-operatives Australia, the national body for State Co-operative Federations, and provides a valuable resource about cooperatives within Australia.

UK.COOP - Is operated by Co-operatives UK, the national trade body that campaigns for cooperation and works to promote, develop, and unite cooperative enterprises within the United Kingdom.

NZ.COOP - Is operated by the New Zealand Cooperatives Association, which brings together the country's cooperative mutual businesses in a not-for-profit incorporated society.

USA.JOBS - Is operated by DirectEmployers Association (ʺDEʺ). While Employ Media, the Registry Operator of the .JOBS gTLD, is currently in a dispute with ICANN regarding the allocation of this and other domain names, DE has a series of partnerships and programs with the United States Department of Labor, the National Association of State Workforce Agencies, and Facebook to help unemployed workers find jobs.

MALDIVIAN.AERO - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.

Fair Use Regional /Local

TEXAS.JOBS - Is operated through a joint effort between DE, the Texas Workforce Commission, and the National Labor Exchange to connect job seekers with approximately 96,000 job openings. An additional domain name operated by this joint effort was WORKINTEXAS-VETERANS.JOBS, a resource devoted to helping Texas veterans translate their military skills to jobs in the civil marketplace.

BOISE.COOP - Is operated by Boise Co-op, a member-owned cooperative founded in 1973 by a few dozen individuals who shared a mutual interest in buying healthy and organic food at reasonable prices.

HYDERABAD.AERO - Is operated by the Hyderabad International Airport and provides a range of interactive services and information for both business and leisure travelers.

SACRAMENTO.AERO - Is a portal website operated by Sacramento County to provide links to each of the airports serving the Sacramento area: Sacramento International Airport (SMF), Mather Airport (MHR), Executive Airport (SAC), and Franklin Field (F72).

22.5 Protection of Regional and Local Geographic Names for Non-Misleading Use

Although Campus IP LLC has stated its intention to consider using non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading manner to help consumers navigate the .ANALYTICS namespace, Campus IP LLC is committed to operating the .ANALYTICS namespace in a manner that minimizes potential consumer confusion, and will actively work with others in the ICANN community regarding any future policy development in this area.

22.6 Potential Future Release of Initially Reserved Names

Given that SAS Institute is an international organization currently operating around the world, together, SAS Institute and Campus IP LLC look forward to collaborating with other new gTLD Registry Operators (especially other restricted registries) in potentially working with ICANN's GAC to explore processes that could permit the release of initially reserved country names (including ISO-3166 two characters). Specifically, Campus IP LLC is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD Registry Operators in releasing previously reserved domain names.

22.7 Dispute Resolution

Campus IP LLC does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .ANALYTICS gTLD, based upon its proposed use set forth in the response to Question 18 of this application.

However, Campus IP LLC is committed to working with governments, public authorities, or IGOs that may have a concern regarding the registration of names with national or geographic significance at the second level within .ANALYTICS. Therefore, should there arise any potential disputes, Campus IP LLC will undertake an immediate policy development process as identified below.

22.8 Creation and Updating the Policies

If there should arise some future need for the creation or updating of the policies regarding this class of domain names, Campus IP LLC will act in an open and transparent manner to develop such a policy and/or recommendation.

Campus IP LLC is also committed to continually reviewing and updating these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, Campus IP LLC and SAS Institute intend to remain active participants in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.
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