.ott

(a) Describe the mission/purpose of your proposed gTLD

DISH DBS Corporation ("Applicant") is the parent company of DISH Network L.L.C., which operates the DISH Network television service in the United States. The DISH Network television service provides a direct broadcast satellite (DBS) subscription television service and other content and video distribution systems in North America. As of December 31, 2011, the company served approximately 13.967 million customers in the United States. The Applicant's DISH Network DBS System consists of the company's licensed Federal Communications Commission authorized DBS and Fixed Satellite Service spectrum, as well as its owned and leased satellites, receiver systems, third-party broadcast operations, customer service facilities, and in-home service and call center operations. The Applicant was founded in 1996 and is headquartered in Englewood, Colorado. The Applicant is a subsidiary of DISH Network Corporation, a publically traded company.

In addition, Applicant's affiliated company, Blockbuster L.L.C ("Blockbuster"), is in the business of renting movies and video games to the general public. Blockbuster operates movie rental stores, a movie-by-mail business, and a multi-channel content delivery service, which includes an on-demand movie streaming service. Applicant's parent company DISH Network Corporation purchased the assets of Blockbuster out of bankruptcy in 2011. Further, in certain geographic locations, Applicant offers phone and internet services as ancillary services to it DBS television service. Applicant continues to grow these service offerings in expanding geographic locations.

Applicant seeks the proposed .ott gTLD as a restricted, exclusively-controlled gTLD for the purpose of expanding Applicant and its affiliated entities' ability to:
• create a connected digital presence and personalized brand experience for customers and other business partners;
• deliver product and service marketing/advertising;
• enable marketing campaign activation;
• facilitate secure interaction and communication with individuals and entities with whom Applicant has a business relationship;
• improve business operations;
• simplify Internet user navigation to information about Applicant products and services;
• demonstrate market leadership in protecting customer privacy and confidential information online; and
• meet future client expectations and competitive market demands.

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PROPOSED RESPONSE:

b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

i. What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
• The goal of the proposed .ott gTLD in terms of specialty, service levels and reputation are:
o Specialty - Applicant and its affiliated entities are a leading provider of DBS subscription television service and satellite and internet access services primarily in North America. In the course of its business with customers and other business partners, highly-sensitive, personal and confidential information is collected and shared between authorized parties. To further demonstrate Applicant's commitment and market leadership in the area of data security and privacy within its industry, Applicant intends to utilize the .ott gTLD to create a restricted, exclusively-controlled online environment for customers and other business partners with the goal of further securing the collection and transmission of personal and other confidential data required for contracted services and other product-related activities.
o Service levels -One of the key goals of the proposed .ott gTLD is to create a restricted, exclusively-controlled online environment for customers and other business partners which will increase customer confidence and trust in conducting business online. Through greater use of online tools by customers, Applicant and its affiliated entities expect to further streamline business processes, reduce turn-around times, provide more personalized service and improve overall client service delivery and satisfaction.
o Reputation - Applicant and its affiliated entities have a reputation of stellar client service, innovation and market leadership. With the online channel growing in importance, one of the goals of the proposed .ott gTLD is to position Applicant and its affiliated companies to meet future client expectations and competitive market demands to ensure it can continue to grow its reputation in the broadcasting, cable television, internet, phone, video sales and rentals, video on demand and wireless industries, as well as in the global marketplace.


ii. What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
• Applicant plans to operate the proposed .ott gTLD as a restricted, exclusively-controlled TLD and as such, will not be commercially offered for registration by the general public. Thus, Applicant and its affiliated entities will have exclusive ownership and control over all second-level registrations within the TLD. As a result, we believe the proposed .ott gTLD will add to the current names space in three (3) areas:
o Competition - As technology advances, so too do client expectations of companies online. They expect that companies will utilize the latest and greatest technology and online practices to improve the user experience, protect their information and deliver quality service. Applicant and its affiliated entities anticipate that the proposed .ott gTLD will enable it to communicate, interact and protect data in ways and under conditions not possible under the existing namespace, thus enabling Applicant to meet future client expectations and competitive market demands.
o Differentiation - While today companies like Applicant can register brand strings at the second-level (e.g., .ott), the proliferation of cybersquatting and typosquatting has placed a great burden on consumers to carefully tread online because there is no guarantee that what looks like a branded website is indeed an authorized website of the brand owner. The proposed .ott gTLD will enable customers and other business partners and Internet users to distinguish on the face of the domain name alone whether the site is an authorized company site because the gTLD will be a restricted, exclusively- controlled online environment where only authorized Applicant and affiliated entity web properties and e-mail will exist and operate online.
o Innovation - The proposed .ott gTLD as a restricted, exclusively-controlled TLD will provide Applicant and its affiliated entities with a new platform on which to build future innovation of its online brand presence.


iii. What goals does your proposed gTLD have in terms of user experience?

• The Internet has been plagued by cybersquatting, typosquatting, phishing, pharming and identity theft scams. This malicious online conduct has shaken the trust and confidence of consumers to share information and transact business online. Thus, the proposed .OTT gTLD has the following user experience goals:
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o Unify the full breadth of products and services offered by Applicant and its affiliated entities under one brand umbrella;
o Improve and streamline the manner in which customers and other business partners can interact with Applicant and its affiliated entities in the online digital space;
o Foster trust and confidence in online interactions by customers and other business partners with Applicant and its affiliated entities;
o Reduce the risk of Internet users being misled, believing and/or acting on erroneous, information about Applicant and its affiliated entities, its business partners and/or its products and services presented online by unauthorized third parties; and
o Simplify online navigation to products, services and business partner information for Applicant and its affiliated entities.

iv. Provide a complete description of the applicant's intended registration policies in support of the goals listed above.

The proposed gTLD will be a restricted, exclusively-controlled gTLD where only Applicant, affiliated entities and authorized business partners will be permitted to register second-level domains for Applicant business purposes only for a term of one to ten years. Affiliated entities who are part of the same corporate organization as the Applicant who seek registrations for second-level names under the TLD will be required to present evidence in writing to accredited registrar(s) for the TLD demonstrating explicit authorization from an officer of the Applicant company to register second-level names within the TLD to protect against unauthorized registration within the TLD by unaffiliated third parties. Applicants and affiliated entities owned and/or controlled by the same corporate parent company will supply corporate contact and ownership information, not personal information, for each registration obtained under the TLD for display in the TLD WHOIS.
To the extent second-level domain names are ever registered to Applicant's business partners and/or affiliates that are not owned by Applicant or its corporate parent company, registrants will be required to execute a registration agreement that incorporates 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. Such registration may also be subject to additional terms and conditions under separate business partner and/or affiliate agreements with Applicant entity. Registrations by business partners or affiliates not owned by Applicant or its corporate parent company will require written, pre-approval by designated individual(s) at Applicant company, must provide corporate contact information, not personal information, for WHOIS purposes and must be made with Applicant's registrar of choice. Registrants must not use the domain name in any way that may damage or diminish Applicants brand reputation, business relationships or other business interests. Failure to do any of the above, will result in the immediate suspension of registrant's registration agreement and/or all deletion of all domain names currently registered in the TLD.

v. Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

The proposed .ott gTLD will be a restricted, exclusively-controlled gTLD where only Applicant will authorize/issue registrations within the TLD to itself and affiliated entities for business purposes. Corporate contact information will be clearly listed in the WHOIS record for each registration within the TLD. Thus, there are no measures that need to be proposed to protect the privacy or confidential registration information of registrants/users of the TLD. However, Applicant is investing in the proposed .ott gTLD to further demonstrate its commitment and market leadership with regard to privacy of consumer data (as evidenced by its current data privacy policy, http://www.ott-systems.com/about/privacy-policy/, as Applicant believes the utilization of the proposed new gTLD could position the company to more fully meet online challenges that may threaten the security of customer data in the future.


vi. Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Prior to using the proposed .ott gTLD for product and service marketing/advertising, marketing campaign activation, interaction and communication with individuals and entities with whom Applicant has a business relationship, and/or implementing new online navigation strategies, Applicant and its affiliated entities anticipate incorporating messaging regarding .ott as part of appropriate company and product communication campaigns that will likely involve all communication channels, including but not limited to, TV, radio, mobile, print, social media, direct mail, online advertising and marketing via our active, client and affiliate-facing websites and other public relations activities to:
• Further communicate Applicant and its affiliated entities' commitment to online consumer safety and data privacy;
• Inform the market of Applicant's ownership and planned use of the proposed .ott gTLD;
• Clearly define the expected benefits to customers, prospective customers, other business partners and Internet users at large.
Future outreach and communications campaigns will be carried out as when needed to reaffirm and clarify the above. Applicant believes outreach and communication will be critical to building trust and confidence in the legitimacy of the TLD.




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c) What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)? What other steps will you take to minimize negative consequences/costs imposed upon consumers?

i. How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come/first serve basis?
• There will not be multiple applications for a particular domain in the proposed .ott TLD because this will be a restricted, exclusively-controlled where only Applicant and its affiliated, authorized entities will be able to seek and obtain registrations.

ii. Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).
• This question is not applicable to a restricted, exclusively-controlled, self-funded TLD, like the proposed .ott TLD.

iii. Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.
• The proposed .ott TLD will be a restricted, exclusively-controlled, self-funded TLD available only to Applicant and its affiliated entities. Thus, there will be no per domain name registration cost incurred by any party for this TLD and thus, no price changes and/or escalations for which registrants will need to be notified.

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We will protect names with national or geographic significance by reserving the country and territory names at the second level and at all other levels within the TLD, as per the requirements in the New TLD Registry Agreement (Specification 5, paragraph 5).
We will employ a series of rules to translate the geographical names required to be reserved by Specification 5, paragraph 5 to a form consistent with the ʺhost namesʺ format used in domain names.
Considering the Governmental Advisory Committee (GAC) advice "Principles regarding new gTLDs", these domains will be blocked, at no cost to governments, public authorities, or IGOs, before the TLD is introduced (Sunrise), so that no parties may apply for them. We will publish a list of these names before Sunrise, so our registrars and their prospective applicants can be aware that these names are reserved.
As defined by Specification 5, paragraph 5, such geographic domains may be released to the extent that Registry Operator reaches agreement with the applicable government(s). Registry operator will work with respective GAC representatives of the country's relevant Ministry of Department to obtain their release of the names to the Registry Operator.
If internationalized domains names (IDNs) are introduced in the TLD in the future, we will also reserve the IDN versions of the country names in the relevant script(s) before IDNs become available to the public. If we find it advisable and practical, we will confer with relevant language authorities so that we can reserve the IDN domains properly along with their variants.
Regarding GAC advice regarding second-level domains not specified via Specification 5, paragraph 5: All domains awarded to registrants are subject to the Uniform Domain Name Dispute
Resolution Policy (UDRP), and to any properly-situated court proceeding. We will ensure appropriate procedures to allow governments, public authorities or IGO's to challenge abuses of names with national or geographic significance at the second level. In its registry-registrar agreement, and flowing down to registrar-registrant agreements, the registry operator will institute a provision to suspend domains names in the event of a dispute. We may exercise that right in the case of a dispute over a geographic name.×