.retirement Domain

THE MISSION AND PURPOSE OF THE NEW RESTRICTED .RETIREMENT gTLD IS TO BENEFIT INTERNET USERS BY ENSURING INCREASED TRUST AND CONFIDENCE THROUGH THE ELIMINATION OF USER CONFUSION AND ASSURANCE OF BRAND AUTHENTICITY.

The new .retirement gTLD will operate as a restricted registry, in which Fidelity Brokerage Services LLC (Fidelity) can create and control domain spaces that promote its brand identity and authenticity. In this regard, the .retirement gTLD will be used by Fidelity and its affiliates to provide authoritative information, services and resources regarding retirement planning to consumers in a way that promotes trust, confidence and interactivity. Second and third level domains can then be utilized for retirement planning topics, Fidelity's retirement plans, products and services, as well as for education and marketing purposes, with internet users assured of brand authenticity.

Fidelity is a subsidiary of FMR LLC, the parent company of the affiliated group of businesses collectively known as "Fidelity Investments". Fidelity Investments is one of the world's largest providers of financial products and services including retirement planning, investment management, portfolio guidance, securities brokerage, and benefits outsourcing. Founded in 1946, Fidelity Investments provides financial products and services to more than 20 million individuals and institutions, as well as through 5,000 financial intermediary firms. Fidelity Investments is a leader in the US in retirement planning, retirement funds and Individual Retirement Accounts (IRAs). Fidelity Investments is the No.1 provider of 401(k) retirement savings plans, with over 24 million participants, and a leading provider of 403(b) retirement plans for not-for-profit institutions. Fidelity Investments provides defined contribution, defined benefit, health and welfare and stock plan services to over 19,000 employers. As of February 29, 2012, Fidelity Investments had assets under administration of USD 3.6 trillion, including managed assets of USD 1.6 trillion. Additionally, at the end of 2011, Fidelity Investments had USD 875 billion in retirement assets under management. Fidelity Investments' websites handled an average of more than 3.1 million visits per day during the fourth quarter of 2011. In this regard, brand reputation, consumer trust and continuous innovation are paramount considerations in all its activities. The .retirement gTLD will provide a secure and reliable online environment where current and potential customers and internet users can interact with Fidelity and each other and learn about retirement planning, related industry trends and Fidelity's range of retirement savings calculators, tools, products and services.

Since the inception of the current domain name system, business activities conducted on the internet are constantly changing and evolving with increased complexity. The volume of commercial transactions over the internet is constantly growing and bringing benefits of simplicity and lowered transaction costs to businesses and consumers. However, at the same time, criminal activities over the internet including data breach, hacking and phishing activities have also become more sophisticated resulting in loss of consumer confidence beyond mere monetary harm. The .retirement gTLD will facilitate greater trust and assurance from internet users connecting with Fidelity online, while still allowing convenient and efficient interaction.

Fidelity's mission and purpose of the proposed gTLD share ICANN's initiatives to promote public interest. Fidelity is committed to contribute towards achieving such initiatives in line with ICANN's Affirmation of Commitments, which includes:

- consumer trust: the .retirement gTLD will be operated in a centralized manner with a restrictive registration policy. Registration of domain names will only be available to Fidelity and its affiliated entities, at this stage, which will provide added consumer trust that .retirement domain names are trustworthy. As domain names are subject to registration standards, policies and procedures under Fidelity's control, this eliminates the possibility of malicious conduct within the .retirement gTLD;

- competition: the .retirement gTLD is not intended to instigate competition and consumer choice at the level of registration of domain names among prospective registrants. Instead it is anticipated to contribute to ICANN's initiatives to promote public interest through its operation focused on promoting consumer trust. Increased trust in the .retirement gTLD will drive existing and new top level domain (TLD) registry operators to make improvements in mechanisms to improve consumer trust of their TLDs; and

- consumer choice: the .retirement gTLD will enable user-driven improvements and innovations assisting Fidelity's marketing efforts through its ability to create new second and third level domain names on demand. These names will provide the consumers with more choices for interacting with Fidelity. As Fidelity has effective control over the registration and use of domain names under the .retirement gTLD, this will also contribute towards general service innovations on the internet.


Given the restricted nature of the .retirement gTLD, the projected number of registrations is likely to be limited, with about 5 to 100 domain names to be registered in the first three years. The number of registrations is likely to increase as Fidelity implements new retirement products, services and marketing campaigns.

Fidelity is committed to complying with all operational, technical and policy requirements, and will maintain consumer trust and the stability of the internet. Fidelity will keep ICANN reasonably informed of any material developments relating to the .retirement gTLD including compliance with the continued operations instrument obligations as set out in Specification 8 of the Registry Agreement.

Fidelity is a well-recognized global brand with six trademarks (held by parent company, FMR LLC) containing the term "Retirement", including "Fidelity Retirement Advantage" and "Fidelity Retirement Reserves", registered in the US for Financial services, namely, retirement fund investment services; providing financial information in the field of retirement planning; retirement plan administration services; investment management services; securities brokerage services; financial services including retirement fund investment services, retirement planning, retirement plan administration services, investment management services and securities brokerage services (Class 36).
Fidelity has an existing domain name, retirement.biz, which is an exact match to the applied-for .retirement string. Fidelity also has domain names containing the term "Retirement", in some cases combined with its "Fidelity" trademark, including in the following spaces:

- gTLDs: fidelityretirements.com, fidelityretirementplan.com, fidelity401kretirement.com, fidelityretirementfund.com, retirementinsight.net, retirementincomeadvantage.com, fidelityretirementservices.com, fidelityretirementadvisor.com, retirementbenifits.com, fidelityretirement.mobi and retirementplanning.mobi.

Fidelity is a leading global brand with a strong reputation around the world, particularly in the US and Canada. Fidelity has used the term Retirement in conjunction with its retirement planning businesses for over 25 years. As such, Fidelity is well known for providing high quality retirement planning, products and services and Fidelity believes that the .retirement gTLD is unlikely to cause confusion with either a generic term or any existing TLDs.×

18(B)I. WHAT IS THE GOAL OF YOUR PROPOSED gTLD IN TERMS OF AREAS OF SPECIALTY, SERVICE LEVELS OR REPUTATION?

The key goals of the proposed new .retirement gTLD are in line with ICANN's Affirmation of Commitments: to promote consumer trust, competition and consumer choice. Fidelity also seeks to foster its online reputation and provide an authoritative internet space through which Fidelity is able to communicate with its customers directly and effectively. The .retirement gTLD will allow Fidelity to provide a central location for current and prospective customers and internet users to interact and learn about retirement planning, related industry trends and Fidelity's products and services for retirement. The ability to create domain names on demand relating to retirement planning, specialty products and services and specific marketing supports these goals. Strengthened security measures, service levels and more effective functionality will provide a trusted and positive user experience.


18(B)II. WHAT DO YOU ANTICIPATE YOUR PROPOSED gTLD WILL ADD TO THE CURRENT SPACE, IN TERMS OF COMPETITION, DIFFERENTIATION, OR INNOVATION?

It is anticipated that the proposed .retirement gTLD will make positive contributions to the wider internet community by providing:


COMPETITION:

The differentiation of .retirement gTLD as a trusted site for Fidelity will ultimately drive existing and new TLD registry operators to make improvements in mechanisms to improve consumer trust of their TLDs. Customers and Internet users will be encouraged to interact with domain names under .retirement domain space. As a result, the .retirement gTLD will effectively enable increased competition in the marketplace. Therefore, the benefits of the proposed .retirement gTLD will be distributed not only to its direct customers, but to the internet community at large forcing improved services and competitive pricing in the market place.


DIFFERENTIATION (INCREASED TRUST):

The .retirement gTLD will simplify how internet users interact with Fidelity by providing a distinctive domain space. Current and future customers, consumers and Internet users will be able to directly navigate to the .retirement gTLD site, saving time and resources searching for an official site. The current domain name system has shown that it is vulnerable to malicious abuses due to registration of domain names which seek to exploit consumer confusion. Fidelity can address some of these vulnerabilities by maintaining complete control over the domain names registered under the .retirement domain space. The new .retirement gTLD will provide a secure and reliable central location for current and potential customers and other consumers to learn about retirement planning and interact with each other and with Fidelity online. Together with consumer trust, internet users will be able to rely on the authoritativeness of the domain names and information under the .retirement domain space, which will differentiate interaction between internet users and Fidelity.


INNOVATION:

With the expansion of the internet community to all corners of the world, the existing TLD structure presents limitations, not only in the availability of domain names for registrants, but also to businesses and organizations establishing a coherent global online brand presence to meet their evolving business needs. It is often difficult to register a domain name in existing domain space due to unavailability of the desired name, particularly domain names relating to Fidelity's business, products and services. Even when the desired domain name is available, it may come with a high price tag associated with a purchase of such desired name from a third party. Online brand coherence is particularly important for financial services providers such as Fidelity where consumer trust and protection is critical in especially in this era of new web-based and mobile technologies, which Fidelity has embraced to provide information, products and services to customers. The new .retirement gTLD will allow Fidelity to provide authoritative and relevant information about retirement planning, related industry trends and Fidelity's range of products and services related to retirement. Fidelity intends to utilize the .retirement domain space to provide a unique, innovative location where current and prospective customers and users can interact with Fidelity and each other about retirement planning through blogs, discussion groups and other interactive technologies. Fidelity has the ability to create second or third level domain names on demand, including the use of topics regarding retirement planning, retirement savings plans, products and services and geographic names relevant to its customer base. Fidelity will be able to combine its use of the domain space with innovative user focused marketing and services to address the currently unmet needs in the existing domain name system, therefore providing greater consumer choice.


18(B)III. WHAT GOALS DOES YOUR PROPOSED gTLD HAVE IN TERMS OF USER EXPERIENCE?

The proposed .retirement gTLD will provide a positive user experience, which meets the changing and growing needs of the global internet community. Fidelity will maintain control in the registration and use of domain names and will ensure that the new gTLD will only be used for purposes authorized by Fidelity. Therefore, the .retirement gTLD will:

- provide an accessible, secure and intuitive central location for customers to learn about retirement planning and interact with Fidelity online;

- provide an innovative location where current and prospective customers and users can interact with each other about retirement planning through blogs, discussion groups and other interactive technologies;

- create second level domains relating to Fidelityʹs businesses or for topics about retirement and Fidelity's products and services relating to retirement planning;

- represent authenticity thus promoting user confidence;

- strengthen brand reputation and user confidence by eliminating user confusion;

- direct internet users to relevant information in a timely manner by creating domain names on demand;

- use geographic names to localize its websites to connect with internet users in the relevant regions and to comply with local laws;

- enhance security and minimize security risks by implementing necessary technical and policy measures; and

- prevent potential abuses in the registration process reducing overall costs to businesses and users.


Fidelity intends to create relevant domain names including some corresponding to its financial products and services, its business unit or affiliated entity names, or geographic names at the second or third level. In accordance with the draft registration policy included in the response to Question 28 and the proposed measures for protection of geographic names and two-character country-code labels as outlined in response to Question 22, Fidelity may use geographic names to localize its websites in countries in which it, or an affiliate, operates. The use of geographic names is intended to:

- connect internet users with relevant information as applicable to the territory; and

- comply with required rules and regulations in the national territory.


At this stage, Fidelity does not intend to utilize Internationalized Domain Names (IDNs) at the second level. However, as the .retirement gTLD evolves, Fidelity may wish to utilize IDNs to allow internet users to engage with .retirement in their native language, creating a more positive user experience and encouraging diversity.

The .retirement gTLD should address the concerns that the current domain name system is open to potential malicious abuse and user confusion in the registration processes. Although the current system allows an eligible party to lodge a claim through existing Uniform Domain Name Dispute Resolution Policy (UDRP) or other dispute resolution processes, the .retirement gTLD will reduce potential abuses in the registration processes and overall costs to internet users. User confidence in the domain name system will be strengthened, which will ultimately contribute towards promoting ICANN's core values in benefiting the public interest.


18(B)IV. PROVIDE A COMPLETE DESCRIPTION OF THE APPLICANTʹS INTENDED REGISTRATION POLICIES IN SUPPORT OF THE GOALS LISTED ABOVE.

The proposed registration policy is attached in response to Question 28.

Only entities which are affiliated with Fidelity will be eligible to register domain names in the .retirement gTLD at this stage. The domain name registration processes and policies will address the requirements mandated by ICANN, including rights abuse prevention measures.


18(B)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.

Fidelity is committed to protection of privacy and confidential information in accordance with its objective of increasing consumer trust and providing a safe and legitimate internet space for internet users. Privacy and confidential information will be protected in accordance with all applicable laws and regulations relating to internet security, privacy and user's confidential information, including all applicable data privacy legislation applicable in the US and ISO 2000 and ISO 27001 certification in relation to security programs. For example, Fidelity maintains processes and measures to comply as applicable with the privacy components of the Financial Services Modernization Act 1999 (also known as the Gramm-Leach-Bliley Act), Related Rule S-P of the Securities and Exchange Commission, the Federal Trade Commission Standards for Safeguarding Customer Information, the privacy rule and the security rule of the U.S. Health and Insurance Portability and Accountability Act and the Massachusetts Standards for the Protection of Personal Information of Residents of the Commonwealth.

Fidelity also has implemented its own privacy policy (Privacy Policy) to demonstrate its commitment to the protection of user privacy and confidential information. Fidelity is committed to maintaining the confidentiality, integrity and security of personal information about its current and prospective customers. Fidelity takes great care to protect the personal information of its customers and Fidelity uses such information with complete respect for customers' privacy. Fidelity's Privacy Policy provides that Fidelity will not provide customers' information to unaffiliated third parties for marketing purposes and will only use customers' personal information to:

- service and maintain customers' accounts;

- process transactions in connection with customers' accounts;

- respond to inquiries from customers or their representative;

- develop, offer and deliver products and services to customers;

- fulfill legal and regulatory requirements;

- disclose necessary information to Fidelity's contracted unaffiliated service providers, such as printing and mailing companies;

- disclose information to government agencies, regulatory bodies and law enforcement officials, including for tax purposes; and

- disclose information to other financial organizations, only with customers consent or as directed by the customers' representatives, for credit assessments, or as permitted or required by law, for example to prevent fraudulent transactions.


As registering domain names within the .retirement gTLD will be available, initially, only to Fidelity and its affiliates, the amount of personal data that will be collected for the purposes of operating the .retirement gTLD and made publicly available in the WHOIS database will be very limited. Fidelity will provide a publicly available and searchable WHOIS look up facility, where information about the domain name status, registrant information including administrative and technical contact details can be found in accordance with Specification 4 of the Registry Agreement. In order to prevent misuse of the WHOIS look up facility, Fidelity will utilize measures including a requirement where any person submitting a WHOIS database query is required to read and agree to the terms and conditions in accordance with the registration policy. This will include the terms of use that the WHOIS database is provided for information purposes only and that the user agrees not to use the information for any other purposes such as allowing or enabling the transmission of unsolicited commercial advertising or other communication.

Fidelity will deploy Domain Name System Security Extensions (DNSSEC) which is intended to benefit both Fidelity and its users interacting with Fidelity online. DNSSEC provides additional security by validating information in the transmission. Therefore, it is intended to benefit those who publish information in the domain name system (DNS) and the users who retrieve information from the new .retirement gTLD. Fidelity already implements measures to protect privacy or confidential information of its users against misuse, loss, alteration and unauthorized access. Such measures include the use of:

- Firewalls using multiple layers of firewalls and diverse technologies under a "defense in depth" network protection strategy;

- Denial of Service (DOS) protection at carrier, service provider and infrastructure tiers;

- Intrusion Detection and Prevention to identify and block malicious behaviour and content;

- Network Encryption including Secure Sockets Layer for general web traffic and VPNs for client and specific partner connections;

- Security Monitoring to continuously monitor for unauthorized activity at system, network and application layers;

- Secure development including regular penetration testing and code inspection to detect and remediate security issues proactively;

- Security policy, training and awareness;

- Rigorous Access Management ensuring only approved and authorized access to systems and data;

- Data Management including systems and programs to ensure that data is classified to protect customer's personal information as well as corporate proprietary and confidential data;

- Oversight including an independent audit function to test and verify security control and processes;

- Certification including ISO20000 and ISO27001 standards to validate its security programs; and

- Fraud detection and management.


Fidelity will continue to apply all security measures currently implemented and will comply with all other policies and practices required by ICANN in the Registry Agreement and any relevant Consensus Policy for protecting the privacy and confidential information of registrants and users in the new .retirement domain space.


18(B)VI. DESCRIBE WHETHER AND IN WHAT WAYS OUTREACH AND COMMUNICATIONS WILL HELP TO ACHIEVE YOUR PROJECTED BENEFITS.

The proposed new .retirement gTLD will be publicised by a media plan to promote recognition of the new gTLD within the internet community to be a trusted site and as a sign of authenticity. Fidelity intends to utilize a variety of marketing channels, both traditional and online, to educate its customers and internet users about the new .retirement gTLD and the information, services and resources that will be available under the .retirement domain space.

During the initial stage of the operation of the proposed new gTLD, it is anticipated that internet users will be re-directed to current websites. However, over time, it is foreseen that communication to the internet community of the existence of the proposed new gTLD and encouragement to use the trusted site will contribute towards minimising malicious abuses and protecting internet users.
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As a restricted gTLD, registration will be open only to Fidelity and its affiliates at this stage, and no third parties will be able to register domain names under .retirement domain space. Therefore, it is not anticipated that third party trademark owners will incur costs in relation to the .retirement gTLD. The entities wishing to register domain names must ensure that all the policy requirements for registration are satisfied. Fidelity will utilize the services of the proposed Trademark Clearinghouse to ensure that domain names registered and the use of those domain names, do not infringe any registered third party intellectual property rights.

No unaffiliated third party will be permitted to register domain names at this stage. It is estimated that time and money spent by consumers who have been targeted by malicious abuse in utilising services on the internet will decrease over time as a result of the new, trusted .retirement gTLD.


18(C)I. HOW WILL MULTIPLE APPLICATIONS FOR A PARTICULAR DOMAIN NAME BE RESOLVED, FOR EXAMPLE, BY AUCTION OR ON A FIRST-COME/FIRST-SERVE BASIS?

The initial use of the proposed new gTLD will be restricted to Fidelity and itsaffiliates, any of which may be registrants under the .retirement gTLD. Therefore conflicts between multiple applications are not anticipated to occur.


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

This gTLD will be used only by Fidelity and its affiliates, at this stage, so pricing incentives are not applicable or relevant.


18(C)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 PLAN.

This gTLD will be usedonly by Fidelity and its affiliates, at this stage, so pricing incentives or pricing increases are not applicable or relevant as no additional fees are to be charged.
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REGISTRY AGREEMENT - SPECIFICATION 5 CRITERIA

§2 The reservation of two-character label strings may be released to the extent that Registry Operator reaches agreement with the government and the country-code manager. The Registry Operator may also propose release of these reservations based on its implementation of measures to avoid confusion with the corresponding country names.

§5 The reservation of specific country and territory names may be released to the extent that the Registry Operator reaches agreement with the applicable government(s), provided, further, that Registry Operator may also propose release of these reservations, subject to review by ICANN's Governmental Advisory Committee and approval by ICANN.


Fidelity Brokerage Services LLC ("Fidelity") generally respects and agrees to abide by the Governmental Advisory Committe's Principles regarding New gTLDs, dated March 28, 2007. In order to comply with the requirements of the Registry Agreement, Specification 5, all Two-character labels (§2) and Country and Territory Names (§5) will be initially reserved.

However, Fidelity believes that the use of geographic terms can provide great benefit and simplicity to internet users because these terms are intuitive ways to resolve to content that may be specifically relevant and targeted to users in the particular country or geographic region or users with an interest in the particular country or geographic region. If Fidelity intended to use any Two-character label and/or Country or Territory Name domains, then it would participate in or implement a process by which any Government may reasonably object to that use. Fidelity will not use geographic names or strings until ICANN has approved such use.

Fidelity envisions a number of possible scenarios for ensuring Government agreement to the use of country and territory names or two-character label strings. These will be explored in detail with ICANN and the GAC to ensure a mutually agreeable solution. The plausible scenarios would include the following:


SCENARIO 1 (LETTER INFORMING GAC):

In advance of any registration or use of geographic names or strings, Fidelity will send a letter to the chair of the Governmental Advisory Committee (GAC) informing the GAC of its intention to use such geographic names or strings in the .retirement gTLD. The letter will outline the reasons for using such geographical names or strings and provide Governments with the opportunity to contact Fidelity within 90 days to reserve their respective geographic names or strings from use in the TLD. Should a Government inform Fidelity that it wishes to reserve the use of its geographic name or string, the name will remain reserved for the duration of Fidelity's registry agreement with ICANN. The opportunity to reserve a geographic name or string will be offered to Governments free of charge.


SCENARIO 2 (LETTER INFORMING INDIVIDUAL GOVERNMENTS):

In advance of any registration or use of a geographic name or string, Fidelity will send a letter to the Government concerned and inform it of Fidelity's intention to use the particular geographic name or string in the .retirement gTLD. The letter will outline the reasons for using such geographic name or string and provide the Government with the opportunity to contact Fidelity within 90 days to reserve its geographic name or string from use in the .retirement gTLD. Should the Government inform Fidelity that it wishes to reserve the use of its geographic name or string, the name or string will remain reserved for the duration of Fidelity's registry agreement with ICANN. The opportunity to reserve a geographic name or string will be offered to the Government free of charge.


SCENARIO 3 (LETTER REQUESTING PERMISSION FROM INDIVIDUAL GOVERNMENT):

In advance of any registration or use of a geographic name or string, Fidelity will send a letter to the Government concerned and inform it of Fidelity's intention to use a particular geographic name or string in the .retirement gTLD. The letter will outline the reasons for using a particular geographic name or string and request the Government's approval or non-objection to the proposed use of the geographic name or string. Should the Government not respond to Fidelity within 90 days, Fidelity will understand this to mean that the Government does not object to Fidelity's proposed use of the geographic name or string.

Alternatively, however, under any of the plausible scenarios, should a Government at a later stage contact Fidelity and request that a particular geographic name or string no longer be used, Fidelity will work in good faith with the Government to try to find a mutually agreeable solution. If such a solution cannot be found, Fidelity will respect the Government's wishes and reserve the name from use without cost to the Government concerned.




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