.dealer Domain Information
Applicant Full Legal Name
Dealer Dot Com, Inc.
1 Howard st.
Burlington VT 05401
Delaware General Corporation Law (Title 8, Chapter 1 of the Delaware Code)
Applied for gTLD
Mission/Purpose of Domain Extension
18.1.1 Dealer.com Dealer.com's mission is to be the most sought after automotive web solutions provider in the world. Dealer.com pursues this mission with the highest degree of integrity and a focus on creating superior products, satisfied clients and empowered employees - all with minimal impact... Read more
Dealer.com's mission is to be the most sought after automotive web solutions provider in the world. Dealer.com pursues this mission with the highest degree of integrity and a focus on creating superior products, satisfied clients and empowered employees - all with minimal impact on the environment.
Dealer.com's solutions include those for franchise automotive dealers, independent auto dealers, dealer groups, original equipment manufacturers (OEMs) and advertising agencies. Its proprietary platform is a customizable, multilayered software application that not only creates SEO-friendly websites but also features a completely integrated toolkit for dealerships both large and small.
This integrated platform has been engineered for maximum efficiency and performance to empower its customers' connections with consumers. Built from the ground up and using the latest technology, Dealer.com offers the most powerful digital marketing platform in the industry, aggregating the following solutions:
Online Advertising: Paid search management, email marketing, search engine optimization, social media & blogging;
Dealer Websites: Inventory integration, merchandising tools, mobile sites, custom branding;
Inventory Marketing: Video, incentives and specials, eBrochures, window stickers;
Lead Management: Contacts, leads, auto-responder management, lead life cycle and sales process; and
Performance Analytics: Call tracking, site activity and lead tracking, merchandising tracking, pay-per-click and advertising tracking.
Dealer.com also offers an array of Digital Marketing services that involve strategy, project management, consulting, training and regular maintenance to achieve maximum results for its customers. Dealer.com solutions also include Managed Services, training and award-winning customer service to complement its innovative platform.
18.1.2 Mission and Purpose
The intended mission and purpose of the .DEALER gTLD is to serve as a trusted and intuitive namespace for the benefit of Dealer.com, its qualified subsidiaries', affiliates' customers and other Internet users. The .DEALER gTLD will deepen and broaden these entities' relationships with those audiences.
The .DEALER gTLD may be thought of most appropriately as a "Brand TLD" in that it serves primarily to provide a trusted, hierarchical and intuitive namespace for businesses that use Dealer.com's broad range of online dealership products and services. Although ICANN has not specifically recognized a Brand TLD category, such as the .DEALER gTLD, in the current round, it is widely anticipated in the brand community that this will become a specialty subset of gTLDs. The .DEALER gTLD is planned to protect Dealer.com's online presence and identity, expand its marketing and promotion efforts, provide a secure channel for online products and services, and offer a platform through which to consolidate many of the intellectual property activities of Dealer.com.
Dealer.com intends to initially limit registration and use of domain names within the .DEALER gTLD to Dealer.com and its qualified partners and affiliates. This initial limited use will allow Dealer.com to establish .DEALERʹs operations and achieve full sustainability. This limited distribution coupled with the other requirements set forth in Specification 9 of the template Registry Agreement is intended to exempt Dealer.com from its annual Code of Conduct Compliance requirements.
After the initial stages of operation, Dealer.com will evaluate whether opportunities exist to carry out the business strategy for the gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to parties other than Dealer.com and its qualified partners and affiliates.
1. Stage One
The initial stage of implementation of the gTLD will involve the .DEALER gTLD registering a limited number of .DEALER second-level domain names. This stage is designed to meet Dealer.com's existing corporate requirements for use of domains including:
(1) Testing by Dealer.com's IT to ensure full administrative and technical access to the domain names.
(2) Testing by Dealer.com's security personnel to ensure unbroken and secure use of all names.
(3) Testing by IT personnel and users to ensure interoperability with various software and web-based applications.
2. Stage Two
Once all testing has been successfully completed, Dealer.com will begin allocating domain names in the .DEALER gTLD for more widespread corporate use. During this same period of time, Dealer.com may begin evaluating strategies to migrate traffic away from its existing second-level domain name, to Dealer.com's new .DEALER gTLD.
It is in Stage Two, that Dealer.com will also evaluate and potentially expand the operations of the .DEALER gTLD to permit registration by other registrants such as licensees or other strategic partners. The dates of such expansion are subject to change depending upon business, strategic and industry factors at the time.
3. Stage Three
The third stage may potentially involve the migration of Internet traffic away from the gTLDs in which Dealer.com's domain names are currently registered, and toward the new Dealer.com branded gTLD, if Dealer.com has not already executed on this strategy earlier. Based on its experience in the initial stages, Dealer.com will assess whether its business plan and expansion strategy should be augmented by extending registration rights to third parties beyond licensees and/or strategic partners. It is anticipated by Dealer.com that changes to the domain name industry, and particularly the impact of the .DEALER gTLD, will take a number of years to be felt and assessed. Any decision to expand the gTLD beyond corporate, partner and licensee use and permanently migrate traffic away from existing gTLDs will take into effect this experience as well as the technical analysis of potential expansion.
Utilizing current projections based upon Dealer.com's existing and future business plans, current domain name portfolio, and other strategic factors, Dealer.com estimates second-level domain name registrations to be in line with the projections set forth in the financial template provided in the response to Question 46 of this application.×
18.2 Given that many businesses search for Dealer.com's content online, Dealer.com believes that the proposed .DEALER gTLD has the potential to offer the following benefits to Internet users and consumers: -Provide a trusted online marketplace for the businesses that use Dealer.com's services;... Read more
Given that many businesses search for Dealer.com's content online, Dealer.com believes that the proposed .DEALER gTLD has the potential to offer the following benefits to Internet users and consumers:
-Provide a trusted online marketplace for the businesses that use Dealer.com's services;
-Provide Dealer.com and its partners and affiliates with the use of short and memorable Internet addresses in order to facilitate increased ease of navigation to Dealer.com's online content and other services;
-Minimize the need for defensive registrations because domain names within the .DEALER gTLD will only be registered by Dealer.com to verified Dealer.com administrators and partners and affiliates of Dealer.com, at least for the first three years of operation;
-Serve as a secure platform for the distribution of copyrighted material to consumers; and
-Incorporate enhanced intellectual property rights (IPR) protection mechanisms.
Also, through the adoption of new gTLDs by the wider Internet user community, businesses may benefit from lower incidents of fraud, misdirection, infringement, phishing, malware, or other scams often associated with mistypes of domain names in the .COM space that are owned by cyber squatters, since they will be navigating to domain names in the .DEALER gTLD.
Dealer.com currently offers its platform to franchise dealers, independent dealers and dealer groups across the United States. Given this widespread service offering, Dealer.com believes that a .DEALER gTLD can provide an online single source-identifying location for its current and future customers.
Dealer.com would like to provide a hierarchical and intuitive framework for the .DEALER namespace by using geographical identifiers as second-level domain names. 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. Dealer.com would like to see if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality and innovation, as premised by ICANN.
Dealer.com has filed this application for a .DEALER gTLD in order to provide a secure, trusted, virtual platform to aggregate Dealer.com's already well-known and prestigious content and other solutions and services. As technologies for delivering content and services evolve, Dealer.com will pursue opportunities to distribute its content and services to consumers in the U.S. on various platforms, including the Internet, mobile devices, and video-on-demand. As noted above, Dealer.com intends to use the .DEALER gTLD as an intuitive means to offer its content and to deepen and broaden its relationship with audiences and viewers.
Most importantly, the Dealer.com content and services will be provided in an online namespace devoid of fraud, misdirection, infringement, phishing, malware, and other scams. While Dealer.com fights to protect its valuable intellectual property from piracy on the Internet, it would use the .DEALER gTLD to offer to consumers a safe and intuitive means of accessing authorized content from Dealer.com and its qualified subsidiaries and affiliates.
With regard to service level and reputation, Dealer.com will operate the .DEALER gTLD in accordance with its corporate philosophy:
The primary focus at Dealer.com is our dealer clients. We recognize that dealers are on the front lines of the automotive industry, talking to and servicing customers everyday. Our goal is to make selling easier, more efficient, and more profitable for dealers by providing them with the most innovate technological tools and services available so they can do what they do best - sell and service their customers.
We place as much importance on our team as we do our clients. We pride ourselves in working hard, working smart, and being the most technically advanced and innovative company in online automotive. None of that can be done without employees that thrive on being at work. Our culture attracts and encourages motivated people that want to make a difference in the industry and the world around them.
As a .BRAND gTLD, the primary factors driving Dealer.com to seek the .DEALER gTLD are differentiation and innovation. Dealer.com is a leading online marketing solutions company, and it uses existing technology and leverages emerging technologies to deliver content and services to its thousands of automotive dealership customers. A .DEALER gTLD has the potential to serve as a cornerstone of this online strategy.
While some of ICANN's new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, .DEALER from its launch will be a trusted online source of Dealer.com information, solutions, and services. Dealer.com will follow its own established good business practices in working with law enforcement to create a marketplace with safeguards designed to minimize fraud and other illegal activity.
Dealer.com believes that the success of the gTLD will not be measured by the number of domain names registered, but rather by the level of consumer recognition and trust that is placed in the .DEALER gTLD. Using this benchmark, Dealer.com strives to build consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.
In addition to providing a trusted ecosystem experience for its millions of customers who use its content, solutions, and services, Dealer.com will minimize potential fraud, misdirection, infringement, phishing, malware, and other scams because domains will only be registered to Dealer.com and its partners and affiliates, at least for the first three years of operation. As a leading online marketing solutions company, Dealer.com believes that it can be a pioneer in bringing innovation in consumer choice to this new Internet medium.
Dealer.com is fully committed to implementing all of ICANN's consensus policies and other Rights Protection Mechanisms (RPMs) identified in the Applicant Guidebook. Moreover, based upon Dealer.com's commitment and established track record in providing a safe ecosystem for consumers and vendors, Dealer.com intends to provide best-in-class safeguards that will evolve over time.
At the time of completing this application, Dealer.com has identified a Rights Protection Mechanism (RPM) that will allow trademark owners to challenge domain names initially reserved by the registry (e.g., generic and geographic names identified in Section 18.1.2). This process will be modeled after the dotAsia Pioneer Policies adopted by dotAsia in connection with its launch, see http://www.wipo.int/amc/en/domains/gtld/asia/.
Because the domains within the .DEALER gTLD are currently intended to be initially registered exclusively to Dealer.com and its partners and affiliates, any registration and use requirements are more appropriately vested in the corporate-partner and corporate-affiliate agreements, or corporate policies and practices, and not in a domain name registration agreement.
As a innovative marketing solutions company, with extensive online operations, Dealer.com has a vested interest in making sure that accurate and current domain name information is readily available in connection with each .DEALER domain name. For the .DEALER gTLD, all private and confidential information will be protected.
In addition, Dealer.com 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 successful 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
Dealer.com sees the potential for the .DEALER gTLD to play a meaningful role in the company's future online strategy. While the extent of likely benefits is currently uncertain due to questions of consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace, all of which will influence the communication and usage strategies for the gTLD, Dealer.com anticipates a phased-in approach to using and promoting the .DEALER gTLD.
At first, Dealer.com plans to start using .DEALER domains initially as it redirects to existing .COM domains and other domains that Dealer.com currently operates. Subsequently, Dealer.com expects to initiate a targeted rollout using select gTLD domains as primary addresses and, after a careful review and analysis of this rollout and of the release of new gTLDs by others, the response from search engines to .BRAND gTLDs, and the perception of consumer, Dealer.com may engage in a broader initiative, should the results be satisfactory and in accordance with the company's overall strategic goals. As the marketplace evolves, the actual usage of the gTLD will dictate what outreach and communication is needed to ensure that consumers continue to interact with Dealer.com content in this new namespace.×
Operational Rules and Cost Benefits
Dealer.comʹs proposed operating rules to limit registration to Dealer.com and its partners and affiliates will provide a trusted online environment for businesses that use Dealer.com's content, solutions, and services. Therefore, Dealer.com will minimize social costs by eliminating the need for... Read more
Dealer.comʹs proposed operating rules to limit registration to Dealer.com and its partners and affiliates will provide a trusted online environment for businesses that use Dealer.com's content, solutions, and services. Therefore, Dealer.com will minimize social costs by eliminating the need for third-party brand owners to defensively register their trademark in the .DEALER gTLD, unlike other open registries. In addition, the .DEALER gTLD will provide businesses with a trusted source for Dealer.com's content, solutions and services without the risk of fraud, misdirection, infringement, phishing, malware, and other scams that consumers are plagued with in .COM and other open gTLDs.
Dealer.com believes that the proposed operation of the .DEALER gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to consumer benefits.
Dealer.com does not envision multiple applicants for the same domain name, as domain names will initially only be registered to Dealer.com and its partners and affiliates.
Dealer.com does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because it will not be marketing or creating commercial initiatives for the sale of .DEALER domain names. Its intention is to use the gTLD as a recognizable, trusted, virtual platform offering Dealer.comʹs and its partners' and affiliates' content, solutions, and services to customers and Internet users. Any potential registrant fees imposed upon licensees and other third parties will be made in the future if this class of registrants is permitted to register domain names in the .DEALER gTLD.
Dealer.com is committed to providing the domain name registration periods set forth in the Registry Agreement. As a .BRAND gTLD, the use of any .DEALER domain names is conditioned upon a partner or affiliate relationship with Dealer.com. Therefore, there is a natural incentive for Dealer.com to provide domain names with minimal price escalations and the maximum flexibility in domain registration terms possible under ICANN rules. Understanding the ownership of .DEALER domains as noted previously, contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations is not relevant or appropriate. That said, the .DEALER domain agreements will be in accordance with all ICANN requirements.
Dealer.com acknowledges that the current template Registry Agreement requires that the Registry Operator "shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar." However, Dealer.com and its qualified subsidiaries and affiliates, as the sole registrants within the .DEALER gTLD, will initially only be registering domain names on an annual basis.
If Dealer.com moves forward with a validation process whereby parties outside the proposed network of Dealer.com and its partners and affiliates, without such a stringent commercial agreement, are permitted to register and use .DEALER domain names, Dealer.com is fully committed to providing these domain name registrants with annual registrations that include pricing predictability and notice in connection with the registration of domain names. However, in connection with potential premium generic or geographic domain names, there may be additional requirements that would legally bind these registrants in connection with the registration and use of these domain names. These terms will be known by this class of domain name registrants prior to the creation of any legal obligation between the parties.×
Is this a Community-based TLD?
Is this a Geographic-based TLD?
Protection of Geographic Names
22 Dealer.com Has Properly Researched This Topic Dealer.com, Inc. ("Dealer.com") 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, Dealer.com... Read more
22 Dealer.com Has Properly Researched This Topic
Dealer.com, Inc. ("Dealer.com") 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, Dealer.com 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;
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;
The 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
Dealer.com 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 at all other levels within the .DEALER generic top-level domain (gTLD), within which Dealer.com will provide for registrations. Specifically, Dealer.com will reserve:
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;
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
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
Dealer.com's mission is to be the most sought after automotive web solutions provider in the world. Dealer.com pursues this mission with the highest degree of integrity and focus on creating superior products, satisfied clients and empowered employees - all with minimal impact on the environment.
Dealer.com believes the use of geographical identifiers to the left of the TLD and as part of the domain name itself has 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 who type their intended destination into address bars as opposed to search engines). As ICANN has largely premised this new gTLD round on promoting innovation, Dealer.com would like to determine if this type of hierarchical and intuitive use of second level domain names within a TLD provides increased consumer functionality.
Dealer.com believes that a .DEALER gTLD can provide an online, single-source identifying function for its current and future customers both regionally and internationally, instead of the mix-and-match approach currently required for expansion into different markets.
22.3 The Legal Protection of Geographical Identifiers
The World Intellectual Property Organization (WIPO) authored an authoritative resource on the current state of the law in connection with the protection of geographical identifiers, 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 ("WIPO Report"). Chapter six of the WIPO 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 of these elements is present in Dealer.com's current or proposed use of geographical identifiers.
Notwithstanding WIPO's observation 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 Government 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.
Dealer.com, acting as a responsible online business, seeks to avoid business practices that could potentially mislead consumers. Dealer.com believes, however, 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 and consumers as proposed in Dealer.com'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, Dealer.com uncovered the following examples 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 co-operation and works to promote, develop and unite co-operative 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 (DE). 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, Direct Employers 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 of Regional/Local Geographic Identifiers
〈TEXAS.JOBS〉 - Is operated through a joint effort between Direct Employers, 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 healthful and organic food at reasonable prices.
〈BROOKLYN.COOP〉 - Is operated by Brooklyn Cooperative Federal Credit Union, which began as a modest storefront business in 2001, but is now New York City's fastest growing credit union and a model for community development credit unions nationwide.
〈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
Dealer.com 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 businesses navigate the .DEALER namespace. Dealer.com is committed to operating the .DEALER 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
As a global company, Dealer.com looks forward to collaborating with other new gTLD registry operators (especially .BRANDs) in potentially working with the GAC to explore processes that could permit the release of initially reserved country names (including ISO-3166 two characters). Specifically, Dealer.com 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
Dealer.com does not anticipate any disputes with governments or public authorities arising in connection with the registration and use of geographic names within the .DEALER gTLD based upon its proposed use set forth in Answer 18 above. Nevertheless, Dealer.com is committed to working with governments, public authorities, or IGOs to quickly resolve any such potential disputes.
22.8 Creation and Updating the Policies
Should the need arise in the future for the creation or updating of the policies regarding this class of domain names, Dealer.com will act in an open and transparent manner to develop such a policy and/or recommendation.
Dealer.com is also committed to the ongoing review and updating of these lists to prevent misleading use of geographical identifiers. Consistent with this commitment, Dealer.com intends to participate in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.×