18.1 Mission and Purpose of .COMCAST
18.1.1 Comcast Corporation
Comcast Corporation (“Comcast”) is a leading provider of video, high-speed Internet, and phone services to residential and business customers in the United States. As of December 31, 2010, Comcast cable systems served approximately 22.8 million video customers, 17.0 million high-speed Internet customers and 8.6 million phone customers and passed over 51 million homes and businesses in 39 states and the District of Columbia.
Comcast offers services in the following segments:
Cable Services – Comcast offers a variety of services over its cable distribution system, including video, high-speed Internet, and phone services. Comcast focuses its technology initiatives on extending the capacity and efficiency of its network, increasing the capacity and functionality of set-top boxes, developing and integrating cross-service features and functionality, and developing interactive Internet protocol-based services.
Video Services – Comcast video service offerings range from a limited analog service to a full digital service, as well as advanced services. Comcast tailors its video services for each cable distribution system serving a particular geographic area according to applicable local and federal regulatory requirements, programming preferences, and demographics.
High-Speed Internet Services – Comcast offers high-speed Internet services with Internet access at downstream speeds of up to 105 Mbps. These services also include Comcast’s Internet portal, Comcast.net, which provides multiple e-mail addresses and online storage, as well as a variety of content and value-added features and enhancements that are designed to take advantage of the speed of the Internet services provided. Comcast’s high-speed Internet service for business customers also includes a website hosting service and an online tool that allows customers to share, coordinate, and store documents.
18.1.2 Mission and Purpose
Through a unified corporate approach, Comcast intends to submit two gTLD applications for the strings .COMCAST and .XFINITY. Comcast IP Holdings I, LLC, (“Comcast IP”) a wholly owned subsidiary of Comcast, will be the entity to file this application and bring the .COMCAST gTLD to market.
The intended mission and purpose of the .COMCAST gTLD is to serve as a trusted and intuitive namespace for the benefit of Comcast and its qualified subsidiaries’ and affiliates’ customers and other Internet users, that will deepen and broaden these entities’ relationships with those audiences.
Although ICANN has not specifically recognized a .BRAND gTLD specification in the current gTLD application round, it is widely anticipated in the brand-owner community that this will become a specialty subset of the gTLDs. .COMCAST is intended to be one of those .BRAND gTLDs, with the goal of protecting Comcast’s online presence and identity, expanding its marketing and promotion efforts, providing a secure channel for online products and services, and offering a platform through which to consolidate many of the intellectual property activities of Comcast.
Comcast IP intends to initially limit registration and use of domain names within the .COMCAST gTLD to Comcast and its qualified subsidiaries and affiliates. This initial limited use will allow Comcast IP to establish .COMCASTʹs 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 Comcast IP from its annual Code of Conduct Compliance requirements.
After the initial stages of operation, Comcast IP 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 Comcast and its qualified subsidiaries and affiliates.
Comcast IP currently plans a four-stage rollout for the .COMCAST gTLD:
Stage 1
The initial stage of implementation of the gTLD will involve Comcast registering a limited number of .COMCAST second-level domain names. This initial use will provide Comcast’s DNS Engineering personnel the time to run a number of tests to ensure seamless and secure access using the .COMCAST 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 Comcast staff to coordinate with the internal and external staff responsible for the application, delegation, and setup phases of the .COMCAST gTLD to ensure a proper transition from delegation to full operation.
Stage 2
Once all testing has been successfully completed, Comcast IP will begin allocating domain names in the .COMCAST gTLD for more widespread corporate use. During this same time period, Comcast 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 Comcast IP’s new gTLDs, .COMCAST and .XFINITY.
It is in Stage 2 that Comcast will evaluate expanding the operations of the .COMCAST gTLD to permit registration by other registrants, such as select 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 in Stage 3. However, any expansion would be conditioned upon a review of Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Comcast IP’s business model.
Stage 3
Depending on the analysis of the evaluations undertaken in Stage 2, Comcast may implement the permanent migration of Internet traffic away from the TLDs in which Comcast’s domain names are currently registered, and toward the new Comcast IP gTLDs, .COMCAST and .XFINITY. It is in this stage that Comcast IP also may implement Comcast’s decision to extend registration rights to licensees or strategic parties, depending upon compliance with Specification 9, as noted above. The dates of such expansion are subject to change depending upon business, strategic, and industry factors at the time.
After consideration of the following factors: analysis of Comcast’s existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Comcast will have full control over the number of registrations in the .COMCAST gTLD namespace, Comcast IP is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.
Stage 4
Based on their experiences with any expansion implemented in Stage 3, Comcast IP and Comcast will assess whether their business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, including potential customers of Comcast. It is anticipated by Comcast that changes to the domain name industry, and particularly the impact of .BRAND gTLDs, will take at least five years to be realized and assessed. Any decision to expand the gTLDs beyond corporate, qualified subsidiary⁄affiliate, and licensee⁄partner use will take into account this experience as well as the technical analysis of potential expansion.
Notwithstanding this potential future expanded use of the .COMCAST name space, Comcast IP currently anticipates implementing a throttle mechanism to ensure that any proposed expansion is controlled and responsible. This proposed “time-out” mechanism is described in greater detail in the responses to Questions 45-50 of this application.
Comcast intends to use the .COMCAST gTLD in ways that are consistent with the business strategies of these or its other business segments as identified in its annual report and investor filings, see http:⁄⁄www.cmcsa.com |