applications of generic internet domain names

["Leclercq, Laurent (AMOS SE)" <laurent.leclercq@xxxxxxxxxxx>]

Dear All,

We are writing you to express our concern about the closed generic Top-Level 
Domains application for all industries and even more for the insurance & 
financial industry which is a highly regulated business sector in order to 
protect the consumers.

Such a rule would indeed enable particular entities to pre-empt a common 
interest category with a clear risk of confusion in the customer's mind, a 
negative impact on competition and customers' protection. Concrete applications 
such as .autoinsurance, .carinsurance, .insurance, .insure, .bank, .finance, 
.financial, .fund, ... would be very confusing with the risk - amongst others - 
that people consider the proposed guarantees as being recommended by the 
industry and therefore as appropriate as is. Other insurers share our view and 
have serious concerns against closed generics. Therefore our association GdV 
and other insurance associations intend to file community objections.

Openness and freedom of the internet would also be really endangered and we 
believe that internet users could be hurt worldwide. It could become a major 
obstacle to the web extension especially towards the 55+ people, whose number 
of users is constantly growing so far.

In that context, achieving a true competition beneficial to the customers while 
ensuring the current level of protection would not be possible any longer.

These entities would then have an unfair advantage in direct navigation and 
online search. The brands which have built their reputation on trust would be 
harmed as not being as visible and accessible as before.

The diversity of proposed offers could dramatically shrink making more 
difficult for the different segments of customers to find what fits to their 
specific needs in terms of products, coverage, service, pricing, mix of 
distribution networks, advice ...  On top it would also raise the barrier to 
entry to entrepreneurs with innovative concepts. The relationship between 
consumers and providers would become unbalanced.

In conclusion, different from other applications for generics, such as "shop", 
the term "Insurance" is protected by the law. If TLDs that match with such a 
protected term could be admitted at all, their management, supervision and use 
have to be regulated in a strict and transparent manner. Further, the new 
domain space under this protected term has to be opened for all admitted 
members of this sector and can not be monopolised. If permitted at all, such 
generics have to be open.


Sincerely yours,

Laurent Leclercq
on behalf of Michel Krauch
Allianz Digitalization Program Manager

LL
Laurent Leclercq
Digitalisation Transformation Officer
AMOS | Digitalization Program | Königinstr. 28 | 80802 Munich, Germany
phone +49.89.3800 12436 | e-Mail 
laurent.leclercq@xxxxxxxxxxx<mailto:laurent.leclercq@xxxxxxxxxxx>


Allianz Managed Operations & Services SE: Vorsitzender des Aufsichtsrats / 
Chairman of the Supervisory Board: Dr. Christof Mascher. Vorstand / Board of 
Management: Sylvie Ouziel, Vorsitzende / Chairwoman; Dr. Rüdiger Schäfer, Dr. 
Ralf Schneider, Holger Werner (Stand / Release 02.2012). Sitz der Gesellschaft 
/ Registered Office: München / Munich. Registergericht / Registration Court: 
München/Munich HRB 173 388. USt-Id-Nr./VAT ID Number: DE 815 001 893.

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