E1. General
E2. TLD String
E3. Naming Conventions
E4. Registrars
E5. Intellectual Property
E6. Dispute Resolution
E7. Data, Privacy, Escrow and Whois
E8. Billing and Collection
E9. Services and Pricing
E10. Other Policies

II. Registration Policies During the Start-Up Period

E11. Start-Up Period
E12. Rush for Registration
E13. Limits
E14. Pricing During Rush
E15. Sunrise Period

III. Registration Restrictions

E16. General Registration
E17. Criteria for Registration
E18. Application Process
E19. Enforcement Procedures
E20. Appeal Process

IV. Context of the TLD within the DNS

E22. Benefits of .kids
E23. Distinguishing Features of .kids
E24. Target Market
E25. Meeting Developing Needs of the DNS
E26. Enhancing the Utility of the DNS
E27. Enhancing Competition for Domain Name Registration

V. Value of Proposal as a Proof of Concept

E29. Concepts to be Proved or Disproved by introducing .kids
E30. Evaluating Results
E31. Long Range Value of Results
E32. Other Reasons to include .kids

Appendices

Executive Summary

oday’s children use the Internet in ever increasing numbers. They explore it. They learn from it. They form associations from and with it. And, they are now helping to build it. The proliferation of personal computers and access to the Internet from the home and from within the educational system has given rise to an online generation. Unfortunately, at this time many Internet sites are not designed for kids, not targeted for a child audience, and many contain material that is far from suited or appropriate for children. The Internet is currently like a vast unsorted library; a Dr. Suess book may be on the shelf next to a pornographic magazine; a set of children’s encyclopedias rests against a hate manifesto. One mistyped letter can redirect a child doing his homework towards an education that he/she is not prepared for. Students are turned into voyeurs. Playtime is unsupervised. Leadership is absent.

.KIDS Domains, Inc. herein applies to sponsor and administer a new Top Level Domain Name, .kids. In partnership with Tucows Corporation, our registry operator, .kids will provide a safe and engaging “greenspace” environment for children. We will segment the DNS system, to the benefit of the Internet Community, by intentionally creating sites where children, parents and institutions can rely on a greater level of adherence to the laws, findings of policy boards, and the regulations imposed by SROs that currently exist to protect children.

The restrictive measures offered by filtering systems have so far been unable to satisfy parents and guardians concerned about their children’s exposure to the entire Internet. Currently it’s a one-size-fits-all Internet and asking the “.com” world to deliver content to all audiences in all voices is foolish. Attempts to do so have made some sites too complex, reducing the relevancy of the content they deliver to their desired constituency.

A registry of .kids domain addresses will help those institutions and parents who want to, and have the right to, make choices for children. In addition, by educating and building a community of content providers who are delivering content specifically for children, children are empowered to make their own choices at the keyboard level. Today’s youth will become empowered to seek out the wonderful educational, entertainment oriented, and communication experiences the World Wide Web has to offer.

Educating our registrants as to the existing laws and policies that apply to this most important constituency of the Internet community will be our first priority. While we do not seek out authority to decide what any child may or may not see or do, we do plan to form a binding private contractual relationship with our domain name registrants. By executing the agreement, registrants will deliver .KIDS Domains, Inc. the authority to uphold and enforce a standard for the suitability and appropriateness of content on all sites in the .kids network.

.KIDS Domains, Inc will require more education, at the point of registration and registration renewal, as to what is currently, and in the future, deemed legal to do on the Internet (at any site) in the US and in the countries most likely making-up the website audience.

To further ensure adherence to our Terms of Use and the “Guidelines for the Publishing of Content and Use of .KIDS Domain Space” (“Guidelines”), we will require annual audits (see E10, Description of TLD Policies) of website content and appropriateness. This will range from an updated single page self administered audit for personal and family sites to a more thorough independent audit of larger and “high risk” sites.

We will update the Terms of Use and the “Guidelines” each year as the applicable laws and recognized policies regarding children and the Internet change. .KIDS Domains, Inc. also anticipates that the Terms of Use and “Guidelines” will change and evolve as technology continues to improve.

We look forward to working with ICANN, the Internet community, the existing and future pioneers of browser and filtering software, private and public nonprofit groups, and legislative bodies and commissions already developing strategies to meet the needs of kids and parents.

We will work in conjunction with existing watchdog groups and software developers to increase the level of adherence to existing content and decency laws. We believe that the existence of a .kids tld, as proposed in this application, with the standardized guidelines regarding content publication, will serve to make watchdog group more effective (when their efforts are focused within the .kids network).

In addition to the audit process, one way .KIDS Domains, Inc. may work with watchdog groups would be implementing a scoring process. Sites that are randomly visited, may receive a score out of 100, and a score of 70 or below would put the site on 30 day notice to bring the site back up to the standards set by the Terms of Use. Of course, gross violators of the policies, set forth by .KIDS Domains, Inc., will be shut down immediately.

.KIDS Domains seeks at the forefront to protect the existing stability of the DNS system. At all times we will vigorously strive to promote technology standards that are open, non-proprietary, and fully compatible with the Internet's existing end-to-end model and that preserve globally unique naming in a universally resolvable public name space.

Through our registry operator .KIDS Domains, Inc. will accept registrations for domain names in a manner protecting current trademark.. We plan to offer domain name applicants as fair a chance as possible to operate Internet sites using the .kids extension. We are targeting our policies toward those applicants who own and operate personal, family business and commercial venues using their registered domain names, and therefore will strictly require the presence of an operating site on .kids domain addresses within 120 days of registration.

We have devised a four-step registration process to deal with the anticipated pent up demand for sites that target children. This phased approach to the initial distribution of .kids domains to owners who have a legal right to the extension, owners who wish to do commercial business using the extension, and business owners seeking to use the Internet to provide children with a more enjoyable and appropriate Internet experience, will allow the registry operator to handle claims over a one-year period.

In order to describe the policies of .KIDS Domains, Inc. we must first look at the current uses of the Net and the implications for children. Most sites for companies and corporations under the .com name serve multi-faceted purposes. Sites are created to sell products and services; and provide information to customers and other stakeholders, such as, employees, vendors and governmental agencies. Increasingly, customer service, billing, financial transactions, and marketing is being done on the Internet through these websites.

Much of the experience that is the essence of and offered on the Net does not specifically and effectively engage children. While freedom of speech is at the core of the Internet, much of the alternative information represented on the Internet is not suitable or appropriate for children under the age of 18. Parents, who would like to guide their children’s introduction and experience on the Internet, have been searching for options to protect their children from inappropriate information and advances using this electronic medium. Government bodies and commissions have also been reviewing the existing technology solutions to help this process.

To date, parents have been able to buy software that is able to restrict their access to a specific series of sites, however, the Internet changes at such a rapid pace that these products are unable to keep up with the constant addition of sites inappropriate for viewing by children. In addition, we believe that in many cases these tools encourage the creation of dubious measures to bypass the restrictive measures.

Software solutions have not proven as effective as their supporters have promised because many children have found ways around them, or specific sites have been written in such a way that the preventative software does not work. (See attachment in Appendix A) In addition, sites that contain no inappropriate content are sometimes blocked because their domain name address contains a word that has several connotations. For instance, some filtering technologies, when set to the highest sensitivity, will not allow access to fantasyfootball.com because it contains the word ‘fantasy’. The .kids platform will remove a great deal of the ambiguity caused by dual connotations, simply because the only acceptable use of a given word will be in the child appropriate sense.

In developing the .kids platform of websites that meet a standardized and uniform set of guidelines, the potential effectiveness of existing filtering and child-safety software tools will be dramatically enhanced. .KIDS Domains, Inc. will actively engage these filtering and child protection software companies to promote a more effective development of their products.

While .KIDS Domains, Inc. seeks first to promote a network of sites that are engaging and relevant enough that most children will opt for the ‘.kids version’ of a corporate site, we do anticipate that filtering software companies will develop features within their products that will allow parents to restrict their children to only .kids websites.

At the same time, new marketing techniques, potentially violating the privacy rights of adult users, have been introduced. While the Internet community has been active in addressing the abuses of some of the marketing industry practices, we feel children may be especially susceptible to such practices. As those practices may abide by the letters of the law designed to protect privacy, they have been manipulated or interpreted in such a manner that they infringe upon the rights of privacy for children and their parents.

Applicants for domain names would be restricted as to the content and marketing practices they can use for sites bearing the .kids TLD.

In this application process, ICANN has asked us to introduce creative solutions to the problems currently existing in the areas of trademark protection, non-user speculations and other issues affecting the domain name registration process. Throughout this document we hope to prove that, not only can .KIDS Domains, Inc. creatively solve these problems, but is also well equipped to implement the unfolding of these resolutions.

We believe ICANN is currently presented with a unique and special opportunity to make a historic decision to benefit children now and in the future, all across the world.

We look forward to joining efforts in pioneering news ways to allocate domain names.

General TLD Policies

I. General TLD Policies

E1. General

Acknowledged.

E2. TLD String

The TLD string proposed is .kids. If the intent of ICANN is to have a 3 letter extension, such as .kid, .we will readily make the appropriate changes in our application.

E3. Naming Conventions

The naming convention will have registrants registering names at the second level and not organize with the sub-domains to create webs at a lower level.

E4. Registrars

.KIDS Domains, Inc. commends ICANN for allowing multiple registrars for .com, .net, and .org domain names and can see obvious benefits of the creation of a price-competitive environment in the domain registration industry. However, because .kids will be a restricted TLD, .KIDS Domains, Inc. does not intend to allow other registrars to register .kids domain names.

Initially, keeping a closed environment will allow for a more effective and productive development setting for standardizing the policies for registration, content publishing and for evaluating procedures for the administration of a new restricted, specialized TLD. Once controls for the integrity of the .kids domain-name registration process can be established and stabilized, the use of other registrars will be considered.

During the start-up period .KIDS Domains, Inc. may work with interested registrars to develop link partnership relationships, allowing outside registrars to refer customers directly to the .KIDS registration site and registration process starting point, while also providing a return link for customers to easily navigate back to the referring registrar.

E5. Intellectual Property Provisions

It is the primary intent of .KIDS Domains, Inc. to maintain and continuously update policies to protect the intellectual iroperty of others. In general, the initial policies are intended to take advantage of the efforts of countless individuals, advisory boards and committees who have formulated policies already being implemented in the .com, .net, and .org Top Level Domains (gTLDs). This includes work such as IPC’s findings of August 24^th, 2000.

One of the powerful benefits that .KIDS Domains, Inc anticipates contributing to the Internet community is the educating of registrants, website owners, and visitors of .kids sites about the existing laws, rules, regulations, and policies regarding not only the publication of content for the viewing of children, but also on the use of domain names by mark holders and the rights and titles that they have from an Intellectual Property perspective.

.KIDS Domains, Inc. will implement the following policies:

1. A policy to implement and maintain a Uniform Dispute Resolution Policy patterned after the Uniform Dispute Resolution Policy as approved by ICANN on October 24, 1999.

2. Maintaining an up-to-date "Whois" database having total public availability for all .KIDS domain registrations. The database will have a format that is readily accessible by and can be integrated into existing "Whois" databases for other gTLDs.

3. A policy to implement any future Intellectual Property protection policies recommended by ICANN or other appropriate authoritative body.

4. A policy to maintain a dedicated, Staff Intellectual Property Advisor with the responsibility of keeping current on developments in the domain name dispute area and making periodic recommendations to changes in the intellectual property policies. Duties shall include review of any proposals by the Domain Name Support Organization (DNSO) working committees and drafting responses to any recommendations by ICANN.

5. A policy providing a "Sunrise Period" wherein trademark owners are given an opportunity to register .kids domains corresponding to their trademark before such a domain is opened to the general public.

6. Policies promoting the maintenance of an automated access database of both active and inactive U.S. Federal Trademark Applications and Registrations. During the .KIDS domain name registration process, a spot check will be done against this database to determine whether the domain exactly matches an existing word mark in the database. If so, a hold will be placed on the registration for a thirty-day publication period.

7. A policy promoting the establishment of an ICANN government liaison-working group, which fosters greater interaction with the U.S. Patent and Trademark Office wherein for a fee, the Patent and Trademark Office will provide an authorization check against conflicting names. Under such a system, owners of record of a conflicting mark would be notified of applicant's intention to register the .kids domain and given an opportunity (30 days) to submit an objection whereupon the applicant may abandon the application or submit the matter to dispute resolution.

8. Exploration of the use of “shared” pages. .KIDS Domains, Inc. will explore the feasibility of the use of a shared page when right to a particular domain name is disputed by “mark” holders. Under this scenario, the disputed domain acts as a link page, listing hyperlinks to the sites of the organizations that have claim to the domain in question. (See Appendix B)

E6. Dispute Resolution

A policy to implement and maintain a Uniform Dispute Resolution Policy patterned after the Uniform Dispute Resolution Policy as approved by ICANN on October 24, 1999.

E7. Data Privacy, Escrow and Whois

.KIDS Domains, Inc. will employ a strict data privacy policy. Other than in the form of the WHOIS service, the .KIDS Domains, Inc. registry information will not be made available in any form to any party, except to ICANN and a third party data escrow firm.

Third parties will not be allowed to use this information for any reason unless disclosed, and agreed to in advance by the domain-name owner. A declaration on the Whois service will list the limitations of that data.

WHOIS service will be made available on the .KIDS Domains, Inc. registration site and, in the interest of promoting a broad distribution of transparency regarding registration of .kids sites, access to the WHOIS service by other domain name service providers will be made available.

We will maintain an up-to-date "Whois" database having total public availability for all .KIDS domain registrations. The database will have a format that is readily accessible by and can be integrated into existing "Whois" databases for other TLDs.

.KIDS Domains, Inc. will engage an established data escrow provider to act as a third party holder of updated WHOIS data for the .kids registry. .KIDS Domains, Inc. also intends to make the WHOIS data available to ICANN and name ICANN a custodian with the data escrow provider, to protect .kids users in the event of an ICANN policy change or the dissolution of .KIDS Domains, Inc.

E8. Billing and Collection

The primary method of payment for the registration of a .kids domain name will be online via credit card utilizing a secure gateway in an encrypted, protected manner. .KIDS Domains, Inc will also open itself to alternate methods of real-time registration transactions such as x.com, paypal, and children's online payment systems such as Flooz.

.KIDS Domains, Inc. believes that it is important that the availability of registration rights for .kids domains also be made available to those who choose not to use, are unable to use, or in the case of many children, do not have access to credit cards and other instruments required for online payment. To that end, .KIDS Domains, Inc. will accept more traditional forms of payment, such as checks, money orders, and cashier's checks, for the registration of .kids domain names.

In the event that a registrant chooses a non-real time method of payment (such as check or money order), the domain that they seek to register will be held in escrow for 10 days. During that time the registrant will be required to deliver payment to .KIDS Domains, Inc. Three days prior to the end of the escrow period, if .KIDS Domains, Inc. has not received payment, a reminder will be sent to the registrant applicant offering a 5 day extension of the escrow period.

.KIDS Domains, Inc. will establish a separate mailing address and transaction department for the processing of payment made by registrants via courier. In this way .KIDS Domains, Inc. will ensure that registration requests made with non-real time payment methods receive an expedited treatment, and that registrants who pay for their .kids domain in that way are given access to a similar level of service.

While we do not anticipate high demand for the option, .KIDS Domains, Inc. will also allow prospective registrants who so desire to find and register a domain name completely off-line. These registrants will reserve a name over the phone and be mailed copies of the Terms of Use and “Guidelines” which they will be required to execute and return with payment. They may also phone in their credit card after .KIDS Domains, Inc. has received their agreements.

.KIDS Domains, Inc. will also establish a separate customer service team to handle registrations and transactional needs for children who register .kids domain names (see Services and Pricing, E9).

We will provide renewal billing by way of online payment, as well as renewal payment by way of postal billing. We will provide extended billing for more than one year at a time but will not give price breaks for early payment. Extended billing will not be transferable and will be non-refundable.

E9. Services and Pricing

.KIDS Domains, Inc. is proposing a pricing model that is based upon the intended owner of the domain and the risk of site content. Pricing will be broken down into four tiers using the following structure:

Four Tier Pricing Model

· Personal Domain Names – A fee of $19.00 (U.S. Dollars) annually, will be charged to applicants requesting a domain name for personal use. These websites are considered “low risk” due to their limited scope of content, and therefore, are easier to monitor. Registrants of Personal Domain Names will be required to expressly acknowledge their agreement with the .KIDS Domains, Inc. Terms of Service and the "Guidelines" at the time of registration and renewal of registration. Personal Domain Name owners will be required to complete and hold current an annual self-administered content audit.

Child Registrants - .KIDS Domains, Inc. anticipates offering a discount to children who register .kids domain names. We anticipate the formation of a special customer service team to address the special needs of child registrants, such as payment method, express parental consent and modified Terms of Use and “Guidelines” that are accessible and educating for children.

· Business Domain Names – A fee of $39.00 (U.S. Dollars) annually, will be charged to businesses and organizations that intend to use their sites for commercial or non-commercial purposes. Business Domain owners must have direct control over 80% of the content of their websites, with no more than 20% content not directly under control of the owner. These sites are considered “mid risk” because of the percentage of content not under the direct control and supervision of the content owner, and because many of these sites will seek to engage in commerce of some form with children using the .kids sites. Registrants of Business Domain Names will be required to expressly acknowledge their agreement with the .KIDS Domains, Inc. Terms of Service and the "Guidelines" at the time of registration and renewal of registration. Business Domain Name owners will also be allowed to complete and hold current, an annual self-administered content audit.

· Portal Site Domain Names - An annual registration fee of $99.00 (U.S. Dollars) will be charged to businesses and organizations using their sites for commercial or non-commercial purposes, to provide links to a variety of sites, not directly under the control of the site operator, which have or anticipate developing, at the time of registration or renewal, no more than 200,000 page views per month. These sites are considered “serious risk” due to the amount of content present on the sites that is not under the direct control of the registrant. Registrants of Portal Site Domain Names will be required to expressly acknowledge their agreement with the .KIDS Domains, Inc. Terms of Service and the "Guidelines" at the time of registration and the renewal of registration. Portal Site owners will also be required to submit to and hold current, an annual audit administered by a .KIDS accredited auditing firm (see "Auditing" E10).

· Special Site Domain Names - An annual registration fee of between $150.00 and $2,500.00 (U.S. Dollars) will be charged to businesses and organizations using their sites for commercial or non-commercial purposes, to provide links to a variety of sites, not directly under the control of the site operator, which have or anticipate developing, at the time of registration or renewal, more than 200,000 page views per month.

The sliding scale of registration fees will be based upon page views per month and will be determined during the negotiation period with ICANN. It is anticipated that sites which have or anticipate developing within the registration period more than 4 million page views per month will fall into the highest paying category. These sites are considered “high risk” due to the amount of content present on the sites that is not under the direct control of the registrant. Registrants of Special Site Domain Names will be required to expressly acknowledge their agreement with the .KIDS Domains, Inc. Terms of Service and the "Guidelines for the Publishing of Content and Use of .kids Domain Space" at the time of registration and the renewal of registration. Special Site owners will also be required to submit to and hold current, an annual audit administered by a .KIDS Domains, Inc. accredited auditing firm (see E10 "Auditing")

As part of their registration fee, Special Site Domain registrants will also gain membership in the constituency that elects the High Risk Group Self-Regulatory Commission (Self-Regulatory Commission). The Self-Regulatory Commission will exist as an organization comprised of .KIDS Domains, Inc. high risk domain name registrants, under the oversight of the Content Policy Board, and will be responsible for determining specific guidelines and policy regarding questions of content appropriateness on .kids sites.

The Self-Regulatory Commission will be charged by the Content Policy Board to work closely with established child safety and online policy organizations.

E10. Other Policies

.KIDS Domains, Inc. Audit and Auditor Accreditation Process

.KIDS Domains, Inc. intends to require that each domain registrant in the .kids network submit to an annual content and suitability audit. The audit process will be managed and overseen by the Content Policy Board. The .KIDS Domains, Inc. Content Policy Board will be responsible for:

1. The formulation of the .KIDS Domains, Inc. "Guidelines for the Publishing of Content and Use of .KIDS Domain Space" (“Guidelines”).

2. Determining the criteria for the accreditation of independent auditing firms.

3. Managing the process of accrediting independent firms as authorized to perform .KIDS Content Audits.

4. Overseeing the High Risk Group Self-Regulatory Commission.

Personal and Business sites, as defined above under "Services and Pricing", will be required to perform a self-administered audit, acknowledging their compliance with the individual points outlined in, "Guidelines for the Publishing of Content and Use of .KIDS Domain Space". Registrants of personal and business sites will be required to have a completed Self-Audit acknowledgment on file with .KIDS Domains, Inc. that is dated during the current contract year.

Portal and Special sites, as defined under "Services and Pricing", will be required to arrange for, and submit to, an annual audit administered by a firm accredited by .KIDS Domains, Inc. Set by the original domain name registration date, a current annually-completed audit must be on file with .KIDS Domains, Inc., in order to maintain ownership of a .kids domain name. Audit requirements will differ for Portal and Special sites, with the requirements for these audits being more in depth.

.KIDS Domains, Inc. intends that the Content Policy Board will fund the content audit accreditation process through fees collected from firms applying to be registered as Official Accredited .KIDS Domains, Inc. Auditors. Accredited auditors will be required to be bonded and insured, be subject to random compliance inspections from the Content Policy Board, and will be required to renew their status as accredited auditors every two (2) years.

.KIDS Domains, Inc. anticipates that the registration enough accredited .KIDS Domains, Inc. auditors to create a competitive environment will ensure .kids domain name registrants can contract auditing firms a fair market price.

Education

One of the powerful benefits that .KIDS Domains, Inc anticipates contributing to the Internet community is in the education of registrants, website owners, visitors of .kids sites, and the Internet community as a whole. .KIDS Domains, Inc. intends to illuminate the existing laws, rules, regulations, and policies regarding the publication of content for the viewing of children on the Internet, and the engagement of children in commerce and contracts.

.KIDS Domains, Inc. believes that the .kids TLD as proposed within this application presents a unique opportunity to educate both personal website owners as well as large corporations and mark holders, as to the regulations and guidelines regarding the use of their domain name and website as it relates to children.

There exists significant policy, legislation, and regulations regarding interaction with children and the publication of content that is available for viewing by children on the Internet. We believe that the vastness, global multi-jurisdictional nature, and explosive growth of the World Wide Web has made those policies and regulations, to date, difficult if not impossible to enforce on the current Internet landscape.

We believe that one of the reasons for the lack of enforcement of current law, policy, and regulations, is the lack of an impetus to encourage Internet users and more importantly domain name owners and website operators to abide by those guidelines. However, .KIDS Domains, Inc. believes that the primary reason for the lack of abided behavior on the Internet regarding children is simply a lack of awareness regarding exactly what those existing laws, policies, and regulations are.

.KIDS Domains, Inc. further believes that there are currently no attempts by registrars to promote that education at the point of registration. By removing the time-sensitivity of the registration process via the use of a Sunrise Period and Wristband system (see E11, Phase 3), .KIDS Domains, Inc. will both promote and ensure that registrants become aware not only of the policies for publication of content on .kids sites but also on websites located on the Internet at large.

II. Registration Policies During the Start-Up Period

E11. Start-Up Period

All prospective registrants of .kids domain names will be required, prior to registration of a domain name or entry into any of the initial programs below, to become registered users. To become a registered user, prospective registrants will be required to expressly acknowledge the .KIDS Domains, Inc Terms of Use and the “Guidelines”

We believe that by making registrants first become registered users, .KIDS Domains will promote the stability of the .kids platform as a haven for safe content, and also the enhance the education of the Internet community as a whole.

.KIDS Domains, Inc. Four Phase TLD Registration Process

Phase One: Sunrise Period

a) The sunrise period will entail a sufficient notification period followed by a 30 day application period where trademark owners will be given an opportunity to register .kids domain names upon payment of the initial fee and the first year’s annual fee.

i) .kids domain names corresponding to trademark owners marks can be registered before such a domain is opened to the general public.

ii) It is the primary intent of .KIDS Domains, Inc. to maintain policies to protect the intellectual property of others.

iii) A $20.00 (U.S. Dollars) fee will be charged to famous name and trademark holders to cover the costs of mark name ownership research and verification.

iv) If more than one claim is made for the same domain-name the rules of arbitration and mediation set by WIPO will be followed.

v) .KIDS Domains, Inc. may offer the opportunity to all claimants of the same second-level domain-names to a distribution page which would show the user a list of sites operating under the same name.

vi) If all parties agree a lottery may be held to determine the owner of the second-level domain-name.

Phase Two: Popular & Appropriate Domain-Name Distribution

a) In this phase .KIDS will develop a “glamour” list of the top 1000 to 2000 words/names and will seek to sell these domain names using an established, well-respected, online auction service. The proceeds of this auction will be distributed to a newly formed public charity, chartered to distribute the funds as follows:

i) 50% to the support of the infrastructure pursuing worthwhile endeavors toward the safety of children using the Internet.

iv) 50% allocated by the Board of Directors of the Public Foundation to charities whose mission is to feed, clothe, or enrich the lives of children around the world.

v) Subsequent annual registration fees for these names will be 25% of the auctioned price. This fee will forever be established as a reoccurring donation to the charity fund.

Upon transfer of ownership the registration policy, the annual registration fee to charitable contribution, will remain in place.

Note: All domains are transferable, but restrictions and regulations transfer with the name.

Phase Three: “Wrist Band” Period – 4 Weeks

a) A month-long period will be initiated where registrants can claim names not trademarked or part of the charitable lottery program. All applicants must be registered users and agree to .KIDS Domains, Inc. Terms and Conditions, as well as, pay the registration fee.

i) Users will be able to go to the .kids site and enter a list of 10 names that they would like to register. Applicants will be encouraged to prioritize their choices from high to low.

ii) Applicants will be assigned a random priority position, generated by a computer, in the selection process and will be overseen by a large, reputable accounting firm.

iii) A computer will generate random priority assignments, essentially placing the applicants in line for their domains.

iv) Our computer system will then go through the line processing the requests of the applicants according to their randomly assigned number. The domain name highest on an applicant’s list and still available for registration will be assigned to the applicant. Applicants will be able to register only one (1) domain-name on their list.

v) Applicants must have their website under construction or online within 120 days from the date of registration.

Phase Four: Open Registration

Registration will be opened to all requests. All terms and conditions must be followed upon the grant of a domain-name, including Terms of Use and “Guidelines”. During open registration, prospective registrants will also be required to register as users, and in doing so expressly acknowledge the Terms of Use and “Guidelines”.

E12. Rush for Registration

.KIDS Domains, Inc. anticipates significant general demand for .kids domain names. .KIDS Domains, Inc. believes that by instituting a 4-phase registration plan which will, in essence, disburse and extend the initial registration process, we will effectively and positively manage the initial rush for registration.

.KIDS Domains, Inc., and our registry operation partner, Tucows, Inc., have the ability to handle 10,000 queries per minute and believe that this will more than adequately cover the volume expected during the initial registration period.

We believe that the implementation of a “Sunrise” period for famous and trademark names, as well as our proposed "Wristband" period for initial registration of .kids domain names by the public, will ensure a more managed and controlled flow of requests and corresponding assignment of domain names, as well as simultaneously improving the inherent fairness of the initial registration process.

It is anticipated that Phase Three, and the initial weeks of the Phase Four general registration process, will bear the greatest traffic load, with requests for information and the number of registrations.

Because the 4-phase registration plan will control the demand for .kids domain name .KIDS Domains, Inc. believes that the proposed TLD presents a unique opportunity to educate both personal website owners, as well as large corporations and mark holders, as to the regulations and guidelines regarding the use of the domain name and website as it relates to children.

E13. Limits

There will be no limit to the number of requests an applicant can make, however they must abide by the “Guidelines” and have a working website for each granted domain name, within 120 days.

E14. Pricing During Rush

There is no special rush pricing for registration under the “Wristband” period, or during the subsequent general registrations.

An extra $20.00 (U.S. Dollars) fee will apply to famous name and trademark holders to cover the costs of mark name ownership research and verification.

E15. Sunrise Period

.KIDS Domains, Inc. will implement a "Sunrise” period policy wherein the owners of famous marks as identified in the famous marks list maintained by WIPO and any exactly matching active U.S. Federal Trademark Registration may claim their .kids domain names.

An extra $20.00 (U.S. Dollars) fee will apply to famous name and trademark holders to cover the costs of mark name ownership research and verification.

We have read and fully intend to comply with the IPCs findings of August 24, 2000.

III. Registration Restrictions

E16.

General registration for .kids domain names, outside of the initial procedures described in the section "Four Phase TLD Registration Process", are limited to, and depend wholly on the express acknowledgement and agreement by the registrant to 1) the .KIDS Domains, Inc. Terms of Use, 2) the " Guidelines" as described and published by the Content Policy Board, and 3) completion and/or current status of a an audit performed by an accredited .KIDS Domains Auditing Firm.

New registrants and registrants seeking to renew their registration will be required, as part of the registration process, to read and acknowledge each point in the .KIDS Domains, Inc. Terms of Use and "Guidelines" by entering their initials into a form field beside each paragraph.

.KIDS Domains, Inc. also believes it will be an effective force in educating the Internet community regarding the laws and rules concerning children and content for children on the Internet. The majority of the material in the .KIDS Domain, Inc. Terms of Use and the “Guidelines" will be based in current US Policy, such as The Federal Trade Commission's final rule pursuant to the Children's Online Privacy Protection Act of 1998 (``COPPA''), effective April 21, 2000, and on recognized policy developed by worldwide consensus forming bodies.

As such, .KIDS Domains, Inc. believes that in effectively communicating the requirements for operating a website at a .kids domain address, and in requiring registrants to expressly read and acknowledge those requirements the company will further the awareness of the laws and policy regarding children and content on the Internet as a whole.

By removing the time-sensitivity of the registration process via the use of a “Sunrise” period and “Wristband” system. .KIDS Domains, Inc. will both promote and ensure that registrants become aware not only of the policies for publication of content on .kids sites but also on websites located on the Internet at large.

E17. Criteria for Registration

.kids domain applicants will be required to acknowledge and accept the Terms of Use and the “Guidelines” produced by the .KIDS Domains, Inc. Content Policy Board.

.kids domain applicants will be asked to categorize the nature of their site content and intended use as either Personal, Business and Organization, Portal, or Special.

.kids domain applicants will be required to have an operating site present and available at their .kids domain address within 3 months of registration. .kids domain applicants will also agree to complete the audit on their newly registered site within 4 months of registration.

E18. Application Process

The majority of applications for .kids domain names will be done online. During the general registration period, prospective applicants will:

1. Become registered .KIDS Domains, Inc. users and agree to the Terms of Use and “Guidelines”

2. Enter their desired domain name into an initial form and search for its availability.

3. Subsequent to a query confirming that the domain name is available, be asked to categorize their proposed website as a.) Personal, b.) Business or Organization, c.) Portal or d.) Special. Highly specific, easily understandable definitions and rules to aid in categorization will be made obvious.

4. Be asked to provide registrant information, administrative, billing, technical contact information, hosting and DNS information. There will be a non-technical , one-step solution for novice registrants to “park” their new domain.

5. Asked to read and accept each individual tenet of the .KIDS Terms of Use and the “Guidelines”. At this point registrants will be agreeing to the immediate forfeiture of their .kids domain name in the event of a breach of the terms and conditions.

6. Read the educational document covering the policies for publication of content on .kids sites and policy, laws, and regulations regarding the providing of content for viewing of children in general.

One of the powerful benefits that .KIDS Domains, Inc. anticipates contributing to the Internet community is the education of registrants, website owners, visitors of .kids sites, and the community as a whole, at the point of application. The aim is to illuminate existing laws, rules, regulations, and policies regarding the publication of content for the viewing of children on the Internet and the engagement of children in commerce and contract.

We believe that one of the reasons for the lack of enforcement of current law, policy, and regulations, is the lack of an impetus to encourage Internet users and, more importantly domain name owners and website operators to abide by those guidelines. However, .KIDS Domains, Inc. believes that the primary reason for the lack of abided behavior on the Internet regarding children is simply a lack of awareness regarding exactly what those existing laws, policies, and regulations are.

E19. Enforcement Procedures

.KIDS Domains, Inc. will require that each domain registrant in the .kids network submit to an annual content and suitability audit. The audit process will be managed and overseen by the Content Policy Board. The .KIDS Domains, Inc. Content Policy Board will be responsible for:

1. The formulation of the .KIDS Domains, Inc. "Guidelines for the Publishing of Content and Use of .kids Domain Space".

2. Determining the criteria for the accreditation of independent auditing firms.

3. Managing the process of accrediting independent firms as authorized to perform .kids content audits.

4. Personal and Business Sites, as defined above under "Services and Pricing", will be required to perform a self-administered audit, acknowledging their compliance with the individual points outlined in the "Guidelines". Registrants of Personal and Business sites will be required to have a completed Self-Audit acknowledgment on file with .KIDS Domains, Inc, dated during the current contract year.

5. Portal and Business sites, as defined under "Services and Pricing", will be required to arrange for, and submit to, an annual audit administered by firm accredited by .KIDS Domains, Inc.. A current (1 year) completed audit must be on file with .KIDS Domains, Inc., in order to maintain ownership of a .kids domain name.

6. Audit requirements will differ for Portal and Special sites, with the requirements for Special audits being more in depth.

7. .KIDS Domains, Inc. anticipates that many sites will have occasion to register a .kids domain name and have the address redirect the user to their established site (a .com or .net address for example). We will have no policy against redirects, however the .kids registrant will be accountable for the content on the redirect site and the .kids domain will be subject to the same restrictions.

8. .KIDS Domains, Inc. will establish a separate Policy Dispute department under the Content Policy Board that will process, mediate, and make decisions on disputes that arise out of action taken by .KIDS Domains, Inc. in response to violations of the .KIDS Domains, Inc. Terms of Use or "Guidelines".

.KIDS Domains, Inc. expects that the Content Policy Board will fund the content audit accreditation process through fees collected from firms applying to be registered as official, accredited .KIDS Domains, Inc. auditors. Accredited auditors will be required to be bonded and insured, and will be subject to random compliance inspections from the Content Policy Board, and will be required to renew their status as accredited auditors every two (2) years.

.KIDS Domains, Inc. anticipates the registering of enough accredited .KIDS Domains, Inc. auditors to create a competitive environment that will ensure .kids domain name registrants can contract auditing firms at the fairest market price.

As described in other areas of this proposal, .KIDS Domains, Inc. believes that one of the powerful benefits we anticipate contributing to the Internet community is in the education of registrants, website owners, visitors of .kids sites, and the Internet community as a whole. .KIDS Domains, Inc. intends to illuminate the existing laws, rules, regulations, and policies regarding the publication of content for the viewing of children on the Internet, and the engagement of children in commerce and contracts; thereby minimizing the violations of the guidelines set for .kids sites.

The High Risk Group Self Regulatory Commission operating under the supervision of the Content Policy Board and with a membership made up of “high risk” domain name registrants as defined in Pricing (E9) will be responsible for the formulation of policy regarding less objective areas of suitability.

The Content Policy Board itself will be directly charged with discovering, gathering, and aggregating those policies, regulations, and laws that are age based and are currently in effect. .KIDS Domains, Inc. believes this is a crucial delineation in our proposal to oversee the .kids TLD. The fundamental pillars of .KIDS Domains, Inc. policy on suitability and appropriateness will be built upon laws, accepted policy, and regulations that already exist but which are virtually impossible to enforce on the Internet as it exists currently.

As an example, The 21st Amendment of the United States grants individual authority to regulate the distribution and use of alcoholic beverages. Each state has enacted statutes that govern the distribution, taxation, sale, and consumption of alcoholic beverages within that state, as well as provisions regarding criminal and civil liability for harms resulting from the consumption of alcohol.

In every state it is illegal to sell alcohol to minors. More importantly there exist countless non-profit groups, advertising industry coalitions, and alcohol industry coalitions which have established policy codes aimed at eliminating the advertising and promotion of alcohol to children.

On the Internet these policies have proved difficult to enforce. And, according the Center For Media Education’s Report, “Youth Access to Alcohol and Tobacco Web Marketing” October 1999, “…it is clear that these companies are creating environments and activities that could appeal to children and teens.”

.KIDS Domains, Inc. would mandate a clear cut policy prohibiting the advertising of alcoholic products, promotion by and for the alcohol industry, links to non-educational alcohol related sites, and obviously any alcohol related commerce.

The table below (Figure 1.1) illuminates guidelines as they currently exist regarding products and issues, and the straightforward ease with which those guidelines will translate to .kids policy.

THE DOT COM CONUNDRUM

Challenging Issues Regarding Children and the Internet

Issue Product	.COM	.KIDS
Alcohol	¨ It is illegal to sell alcohol to minors in all 50 US States. ¨ It is, however, legal to sell alcohol and advertise it to adults. But there is no way to tell how old the person visiting a website is. ¨ The alcohol and advertising industries have expressed their desire to avoid advertising their product to children. ¨ The World Health Organization’s European Charter on Alcohol has also addressed the issue responsibility in advertising regarding children.	Because children are the only constituency, the advertising of alcoholic products, promotion by and for the alcohol industry, links to alcohol industry sites or promotional material will be strictly prohibited on .kids websites.
Tobacco	¨ The sale of tobacco products to children is strictly prohibited. But it is legal for adults to purchase cigarettes and so it is a very difficult issue on an anonymous Internet. ¨ Sale to minors via the Internet is also illegal. Recently, Congressman Meehan of Massachusetts became aware of the lack of age restrictions at various sites, which offered cigarettes for sale. ¨ Meehan has introduced HR 2914 to prohibit the sale of tobacco to minors on the Internet.	Because children are the only constituency, the advertising of tobacco products, promotion by and for the tobacco industry, links to tobacco industry sites or promotional material, and obviously the sale of tobacco products will be strictly prohibited on .kids websites.
Pornography	¨ By law, the availability of pornography offline is limited to adults. ¨ The Internet has made that same adult oriented material much more easily available to minors online. Not only is it available but also it is at times unavoidable. ¨ A study by the Safe American Foundation reported that 91% of teenagers said they unintentionally accessed web sites featuring pornographic, hate-based or violent material while conducting research for school or just surfing the Web.**	The laws regarding the distribution of pornography to minors in the will apply to all sites in the .kids network. Because children are the only constituency, all pornography will be strictly prohibited on .kids websites.
Hate and Bigotry	The first amendment does not protect threats, and that includes racial epithets and racial animus. According to Christopher Wolf of the Anti-Defamation League, “Where the activities of hate groups once were limited by geographical boundaries, the Internet allows even the smallest fringe group to spread hate and freely recruit members online by tapping into the worldwide audience that the Web provides. Technology also offers such groups the ability to post messages in chat rooms and communicate like never before.” Unfortunately, the anonymity of the Internet makes the current medium nearly impossible to police criminal hate.	All current law and the strictest of existing policy regarding hate related communication will be enforced on .kids sites. Further, .kids will work with groups like the Anti-defamation league to develop a clear cut component of overall policy prohibiting the publication of hate related communication and material.
Privacy	The Children’s Online Privacy Protection Act of 1998 states that it, “…is unlawful for an operator of a website or online service directed to children, or any operator that has actual knowledge that it is collecting personal information from a child, to collect personal information from a child…” without, “…verifiable parental consent for the collection, use, or disclosure of personal information from children.” Among other things.	Because children are the only constituency assumed on .KIDS sites, any and ALL requests for personal information will be required to comply with the Children’s Online Privacy Protection Act of 1998

(Figure 1.1) ** "In Brief: Look What We Have Here." (October 11, 1999). Time

E20. Appeal Process

The registrant may pay an appeal fee and appear before a standards board. A separate Policy Dispute Department under the Content Policy Board will process, mediate, and make decisions on disputes that arise out of action taken by .KIDS Domains, Inc. in response to violations of the .KIDS Domains, Inc. Terms of Use or "Guidelines".

E21. Failure to Comply

Failure to comply with the Terms of Use for .kids domain names, and/or violation of “Guidelines” , and/or failure to complete an annual audit may result in the revocation of rights to the domain name in question.

Registrants guilty of a first time, aberrant violation, (to be defined in the “Guidelines For The Publishing Of Content And Use Of .kids Domain Space”) will receive a warning via email and US Post. .kids registrants will be allowed one warning per year. A second "typical violation" within a year will result in a letter informing the registrant of the intended revocation of their .kids domain name license in 10 days, and the actual revocation of the license and the removal of the domain name address from the .kids registry.

.KIDS Domains, Inc. reserves the right, in the case of a gross aberrant violation, (to be defined in the “Guidelines”), to remove the domain address from the registry immediately and without notice. .KIDS Domains, Inc. rights and proposed actions in the case of a Failure to Comply will be outlined in the Terms of Use and agreed to by .kids domain name registrants.

IV. Context of the TLD within the DNS

E22. Benefits of .kids

Obvious benefits of a .kids top level domain include the already mentioned expansion of available domain names, increase in specific segmented space, and a target audience that will provide a large test bed, with limitations and restrictions placed on content and use.

Utilizing the top level domain space to segment space specifically to be used by a particular group or segmentation is the evolution of the DNS. Utilizing the inherent specifications for children can prove as an excellent test bed for continued technological improvement. The global Internet community will no doubt benefit from the concept of responsibility of content, enforcement of restrictions, and value placed on positive change rather than penalization.

.kids would benefit the global internet community by preventing access to content that should not be on websites designed for users, ages 8 to 18. Currently .com, .net, .org, and even .edu, are used by a variety of interests to promote a multitude of services. Adults on the Internet are able to comprehend more information, enter into legal contracts, and from experience in their own lives, make judgments regarding commercial transactions, opportunities and content made available to them on the Internet.

We do not believe children, especially at a young age, possess these abilities, nor should they interact with the Internet content creators on a level playing field. We believe ICANN should allocate the .kids top level domain name to provide protection and encourage to children to use the internet in a way most beneficial to them.

In some ways the current Internet may look to children the same way that the voices of parents were portrayed in the Peanut’s Cartoon Strip—Blah Blah Blah Blah Blah. The way sites are organized, in an effective manner to communicate with adults, may not be the best way to engage children.

In addition, children cannot enter into a binding contract. If a child is required to register for a page, or purchases an item, that is not a legally enforceable contract. The concept of “buyer beware” is now used for people to be on their toes, to be on their look out against fraudulent schemes. Children do not possess enough experience to use the Internet in the same manner as adults, when it comes to giving out personal information. Instead of telling children that they can’t use the same internet, or that they can’t go to certain sites, we want the children to have access to .kids sites to find out about history, geography, specific companies, music, entertainment, people, diversity and all the other things that one might search for by typing in a domain name on the internet.

We believe we will be providing a user experience for kids directly. In the same way that adults are able to choose what domain name they use to access a site, we expect children to do the same thing and we believe that this is a presently unmet need in the DNS. We strongly hold that the new TLD .kids, as well as other new TLDs, segmenting the internet by user group, will enhance the utility of the DNS and the communities served by our top level domain name.

Using the DNS to create a child safe area will enable the Internet community to focus “kid safe” authoring tools and software, to become more effective. We believe that the segmentation we will achieve with the .kids TLD will enable a more definitive line to be drawn for filtering technologies. The .kids extension should vastly improve the effectiveness of filtering technologies and increase parents’ confidence in them.

Developing the .kids platform of websites that meet a standardized and uniform set of guidelines, the potential effectiveness of existing filtering and child-safety software tools will be dramatically enhanced. .KIDS Domains, Inc. will actively engage these filtering and child protection software companies to promote a more effective development of their products.

.KIDS Domains, Inc.

Description of TLD Policies

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