SUPPLEMENTAL COMMENTS OF IATA IN
SUPPORT OF “.TRAVEL” TLD
Following IATA’s submission to ICANN of its application
for the “.travel” TLD on October 2, scores of comments regarding the proposal were
posted to the TLD Comment Forum, and ICANN emailed four questions to IATA, to which
IATA responded on November 3. The comments and questions have raised important
issues and the entire process has, we respectfully submit, reinforced that: 1) “.travel”
should be among the first group of new TLDs selected by ICANN, and 2) IATA is fully
qualified to sponsor the new TLD. The IATA application demonstrated, and we
reaffirm below, that our proposal meets and exceeds all of the criteria adopted by
ICANN for selecting the next generation of TLDs, including the nine specific criteria
listed by ICANN at www.icann.org/tld-criteria-15aug.00htm. Furthermore, as
discussed below, our proposal for the “.travel” TLD has received widespread support
from a diverse cross-section of the global travel industry, and the initial concerns
over governance of the new TLD expressed by some travel agents have been, we believe,
fully resolved by the understandings we have reached with, and clarifications we
have made to, the leading travel agency trade associations of the world. The
worldwide support for the new TLD is strong and diverse, and all of the essential
elements are in place for the selection of “.travel” as a new TLD, as summarized
1. Maintenance of Internet Stability. As demonstrated in our proposal,
IATA and its proposed registry operator possess the requisite qualifications and
abilities to launch and operate the new TLD in a manner that would never jeopardize
the stability of the Internet. Not only do we have the technical capabilities
and financial wherewithal for the administration and operation of the new TLD, but
we also possess critical prior experience in handling large and complex worldwide
undertakings. As our proposal states, “IATA has been entrusted by the industry,
and by governments around the world, to design and equitably administer the coding
systems essential for the smooth and efficient functioning of the travel industry.”
§ C4. As set forth in § C12 of our proposal, IATA has an annual budget in excess
of US$ 240 million and is accustomed to managing activities with sizeable financial
implications and unquestionably has the capabilities and resources to successfully
launch and operate the “.travel” TLD. Significantly, no comments to the TLD
Comment Forum have questioned the fact that we would operate the new TLD in a manner
that would maintain Internet stability.
We also have ensured that any necessary
transition between registry providers will not result in any harm to the efficiency
or operation of the new TLD. As set forth in § E.7 of our proposal, the Memorandum
of Understanding between IATA and the registry operator provides that all data in
relation to the “.travel” TLD will be deposited with a reputable, mutually acceptable
escrow agent, to be transferred to IATA and/or ICANN upon expiration or termination
of the Agreement between IATA and the Registry Operator, in order to ensure reliable
and continuous operation of the “.travel” TLD.
2. Effective “Proof of Concept.”
The IATA application clearly articulates the restricted TLD concept that our proposal
will test, how the results of the test can be evaluated, and how the results of the
evaluation will assist in the long-range management of the DNS. As set forth
in § C, our plan to introduce quality controls to validate the businesses for “.travel”
domain names will serve as a model for future restricted TLDs focused on other sectors
of the economy. As provided in § C10 of our proposal, as a restricted TLD,
objective and transparent selection criteria will be established (to be determined
by the “.travel” Advisory Board) to ensure that only legitimate providers of travel-related
goods, services, and information will be allowed to register in the TLD. By
doing so, as more fully explained in § E of our proposal, an innovative and significant
value-added service will be provided that will be highly attractive to Internet users,
and which may serve as a model for future TLDs geared to other specific sectors of
3. Enhancement of Competition for Registration Services. The
“.travel” TLD will enhance competition for Registration Services because it “offers
the potential to introduce much needed competition in the provision of registry services,
which will drive down prices and increase the array of choices to the benefit of
users not only of ‘.travel’ but of all TLDs.” IATA Proposal § C. As sections
C and E of the IATA proposal also explain, IATA will encourage numerous travel industry
associations to become registrars, thus adding new competitors to the market for
providing registrar services. Once qualified as registrars for ".travel”, these
associations may also wish to act as registrars for ".com” and other unrestricted
TLDs, thereby enhancing competition for Internet registry services even more broadly.
Our pricing structure should also have a positive effect on competition.
As stated in § E of our proposal, the “.travel” TLD will be operated on a not-for-profit
basis, with pricing aimed to equate with actual costs. (Should any surpluses
result, IATA has committed that they will be used for public interest purposes, such
as “bridging the digital divide” for travel and tourism in developing countries.)
Moreover, ICANN is expected to authorize a number of new TLDs, all of which will
be competing for domain name registrations. Thus, market forces will act as
a further check on the pricing of all new TLD sponsors.
4. Enhancement of DNS Utility.
The “utility” of the “.travel” TLD will be profound and universal, both with respect
to the Domain Name System and Internet and world commerce in general.
with, the “.travel” TLD would sensibly add to the existing DNS hierarchy and would
help avoid confusion of Internet users in locating the Internet resources they seek.
The TLD label clearly reflects the particular purpose for which the TLD is intended.
In addition, the proposed TLD is semantically and phonetically “far” from existing
TLDS, such that confusion will be avoided. The restrictions on the TLD will
assist users in remembering or locating domain names within the TLD. For example,
users might conclude that “delta.travel” is associated with the airline, rather than
the dental plan.
The attraction and utility of the “.travel” TLD extends far beyond
airlines and their customers. In addition to its airline membership, IATA counts
among its customers approximately 90,000 IATA accredited and endorsed travel agents
located in 209 countries; the operators of other modes of transportation such as
railways and ferry companies; and numerous other suppliers of travel-related services
including hotels, travel insurance providers, etc. IATA Proposal § C1.
Attachment C1.C to the IATA Proposal shows a list of allied and associated organizations
that are participants in our Partnership Program.
Moreover, the comments
supporting IATA’s application have come from a widespread cross section of the global
travel community, which demonstrates the universal appeal of the “.travel” TLD proposal.
Annex A hereto contains a partial list of the comments which travel industry representatives
have submitted to the TLD Comment Forum in support of IATA’s proposal for the “.travel”
TLD. These comments (more than 75 in number) were filed by, among others, travel
agents, travel agent associations, airlines, airline associations, airline equipment
manufacturers, airports and airport authorities, e-commerce firms, hotels, railways,
travel and tourism organizations, and individual Internet users. The comments
in support have come from every continent, from businesses large and small, as well
as from individual consumers and from the major European travel consumer federation,
FATURE (the Federation of Air Travel User Representatives in Europe). These
comments, more than anything else, establish the worldwide desire for “.travel” to
be included in the new group of TLDs, and the confidence which the global travel
community, in the broadest possible sense, places in IATA to sponsor and administer
the “.travel” TLD.
IATA’s proposal also has been embraced by key segments of the
business community. For example, in a recent comment filed in the TLD Comment
Forum, financial powerhouse Citibank “heartily endorse[d]” IATA’s application, offering
its belief that “IATA's application may be the single best example of how the Internet
community can benefit from independent management of a top level domain.”
Citibank further stated that it has “worked closely with IATA for years to help ensure
fair, prompt clearing and settlement of payments among a broad spectrum of travel
industry participants - including such diverse entities as airlines, travel agents,
cargo carriers, freight forwarders, hotels, and car rental agencies. We are
pleased to have had the opportunity to have seen and supported IATA's successful
efforts to establish a neutral environment that promotes the growth of the entire
travel industry without prejudice against any industry segment.” Citibank added
that it had “also worked closely with IATA in recent years to develop Internet projects
that would benefit the broad travel community. From this activity, we can report
that IATA understands the effect that e-commerce can play in transforming the industry,
and that IATA understands how to act as a force for positive change in this area.
We believe that IATA will be a fair and responsible manager of this top level domain.”
We also highlight the fact that our proposal is now supported by the major trade
associations for the travel agency community. Since filing its application
on October 2nd, IATA has been in communication with the travel industry to discuss
its proposal for sponsorship of the “.travel” TLD and to seek a consensus within
this diverse and global industry in support of IATA’s application. While approximately
100 of the 90,000 accredited/endorsed travel agents of the world have posted comments
on the TLD Comment Forum questioning the proposed governance of a “.travel” TLD,
the IATA proposal has now gained the support of the American Society of Travel Agents
(“ASTA”), the world’s largest association of travel professionals representing over
26,000 travel agent members (primarily in the US), and the Universal Federation of
Travel Agents’ Associations (“UFTAA”), the largest federation of travel agent associations
worldwide representing over 48,000 travel agent members in 97 countries. Both
ASTA and UFTAA are now satisfied that the governance procedures, as clarified by
IATA, are appropriately representative of, and accountable to, the diverse and dynamic
travel industry. Both ASTA and UFTAA have posted their comments confirming
their support for the IATA application on the ICANN TLD Comment Forum. As noted
in the ASTA press release announcing its position on the IATA application, “[t]his
is the first time since 1995 that agents and airlines have found grounds of mutual
interest on a controversial subject…” IATA has agreed to these clarified governance
procedures and is committed to ensure that the “.travel” TLD shall incorporate them.
IATA also has taken the necessary steps to ensure that the new TLD will be governed
in a manner that reflects the entire diversity of the world’s travel community.
As set forth in Section C4 of the IATA application, the “.travel” TLD will be governed
by a “.travel” Advisory Committee, comprised of a “broad range of representatives
of members of the ‘.travel’ stakeholder community, including specifically travel
consumer groups, and travel services suppliers.” IATA is committed to ensuring
that the ”.travel” Advisory Committee will function as an “Advisory Board” with supreme
authority for determining the objective and transparent criteria to be applied in
deciding whether a particular person or entity qualifies to receive a domain name
within the “.travel” TLD. Moreover, neither IATA nor the airlines (nor any other
individual segment of the travel industry) will control or dominate the ".travel"
Advisory Board and its decisions. No individual segment of the travel industry,
including airlines, will ever have more than a minority of the total number of seats
on the Board, and no one segment, including airlines, will have any “veto” rights
over decisions approved by a majority of Board members. Thus, ultimate authority
on such matters shall lie with the broad range of stakeholder representatives which
will comprise the “.travel” Advisory Board, rather than the IATA Board of Governors
or any other entity internal to IATA.
Section C6 of the IATA application also
references the IATA-Registrars Forum which will be created to provide input into
TLD policy development, and serve as a vehicle for communication between registrars
and the TLD sponsor. Given that many industry associations, representing travel
agencies, hotels, car rental firms, etc., will be encouraged to become registrars
for the “.travel” TLD, the IATA-Registrars Forum will provide an additional avenue
for entities throughout the dynamic and global travel industry to ensure that the
policies of the ".travel" TLD reflect the entire travel industry, and all of its
5. Meeting Unmet Needs. IATA’s proposal meets the unmet
needs of having a TLD dedicated to the travel industry, and a process which helps
ensure the legitimacy of entities holding themselves out as qualified providers of
travel related goods, services, and information.
As set forth in § E of
our proposal, travel accounts for more than 10% of the world’s economy, but consumers
of travel goods, services, and information are faced with a great deal of uncertainty
and mistrust which has impeded the fullest possible adoption of Internet e-commerce.
The “.travel” TLD will set a new standard of quality and provide the level of buying
confidence that consumers expect from traditional brick and mortar travel providers.
The “.travel” TLD will serve as an essential hallmark that the consumer will associate
with quality and credibility, something absent in the .com TLD.
In addition, as
reflected in § E29 of our application, the restricted “.travel” TLD would go beyond
the current environment with .com, .net and .org by providing a solution to address
the current issues of trademark infringement, trademark dilution, cybersquatting
and business practice assurance, while not infringing on the original intent of free
6. Enhancement of DNS Diversity and Registration Services. Diversity
of the DNS would be enhanced by the “.travel” TLD because entities and individuals
from all over the world, who are part of the travel community, will be able to use
the “.travel” TLD as a means for the provision of travel-related goods, services,
and information over and in connection with the Internet. In addition, consumers
of travel goods, services, and information throughout the world will be able to access
the multitude of “.travel” sites in a reliable and efficient manner. Furthermore,
as stated in § E of our application, with offices in over 75 countries, IATA has
intimate first hand knowledge of the cultural awareness needed to generate a high
level of confidence from consumers in both economically developing and developed
Throughout § C of its proposal, IATA refers to IATA’s intention to establish
a new “.travel” Advisory Committee, or Board, comprised of “a broad range of representatives
of members of the ‘.travel’ stakeholder community, including specifically travel
consumer groups, and travel service providers.” As clarified and confirmed
in our response to ICANN’s questions (and in No. 4 above), IATA is determined to
ensure the “.travel” Advisory Board shall have substantive and efficacious participation
by representatives of travel consumer groups, travel agent associations, and other
segments of the travel and tourism industry, including tourist promotion boards,
cruise lines, railways, car rental firms, hotels, and travel guide publishers.
7. Delegation of Policy-Formulation Functions. Under the IATA proposal,
ICANN would delegate the authority to adopt and implement policies regarding the
use and operation of the “.travel “TLD to IATA, which in turn would delegate authority
to the .travel Advisory Board, which would consist of representatives from all sectors
of the travel industry and would not be controlled or dominated by any sector, including
airlines. In this manner, the TLD will be governed in a manner that reflects
the functional and geographic diversity of the Internet and its users, and involves
the sort of “bottom-up” governance that has characterized the development of the
Internet to date.
8. Protection of Third Party Rights. Section E of IATA’s
application sets forth the numerous ways in which IATA shall ensure that the intellectual
property and other rights of third parties are appropriately protected in the issuance
of “.travel” domain names. As detailed in § E5, IATA intends to implement a
multi-tiered approach to provide, in a practical manner, the highest level of protection
of intellectual property rights and to encourage full compliance with anti-cybersquatting
legislation. This approach includes careful review of the applications, geographic
name restrictions, a screening process, holding of registrations in abeyance for
10 days or longer to accommodate legitimate challenges, application of the ICANN
UDRP, availability of IATA alternative dispute resolution procedures, a requirement
that the domain name be actually used, and ongoing monitoring by IATA. In addition,
the proposed registry operator for the “.travel” TLD proposes to offer an Intellectual
Property Notification Service to enable interested parties to monitor domain registrations.
its “IPC Evaluation Chart for Proposed TLD(s),” the Intellectual Property Constituency
(“IPC”) accorded IATA’s application for the “.travel” TLD the highest ratings possible
for the categories of: 1) “consider[ation of] intellectual property protections for
third party interests” (Category C) and 2) incorporat[ion of] policies that are likely
to discourage abusive registration practices” (Category E).
submits that other aspects of the IPC Chart do not, for some reason, accurately reflect
the true nature of IATA’s proposal. For Category A (whether the proposals “have
a well thought-out plan for allocation of names during the startup phase”) IATA’s
proposal received an “Unsatisfactory” rating (as did a majority of the proposals).
This rating may have reflected a misunderstanding on the part of the IPC evaluators.
There is, in fact, a “sunrise provision” in our proposal. Section E15 states
that, although “IATA believes that the practice of offering pre-registrations to
particular applicants to be a discriminatory practice . . . IATA will use a phased
approach to limit the initial sign-on rush by only allowing those who qualify for
top level domain names to proceed in the approval process.” (Emphasis added).
The proposal also states in § E12 that “IATA believes that by limiting the applicant
process to only those qualified for a top level domain name in the first few months,
IATA will be able to provide the most expansive benefits to the common Internet user,
without overwhelming the registry, registrar and accrediting process.” Further, IATA
emphasizes in § E14 that the “rush for registration in the startup phase” for ‘.travel’
will be “limited by the type of TLD assignment available during that period.”
For Category B of the IPC evaluation (whether the proposal “provide[s] for a reasonably
accessible and efficient mechanism for resolving domain name disputes”), IATA received
a “Satisfactory” rating. We respectfully submit that the rating should be “Good”
because IATA’s proposal embraces the ICANN UDRP (see §§ E1, E6) and offers alternative
specific accessible and efficient mechanisms for the resolution of domain name disputes.
See §§ E1, E5 and §E6. Finally, we would like to clear up any confusion
which may have resulted in IPC concluding that IATA provided insufficient information
for Category D, which relates to the manner which the “.travel” TLD will provide
an effective and properly balanced WHOIS service. Section E5.6 of our
proposal contains our commitment to provide WHOIS information to the public, and
we can assure IPC and the public that the amount of information provided shall be
more than adequate to assist trademark owners to obtain the necessary information
regarding registrants in order to take the necessary actions to protect their trademark
and other intellectual property rights. We regret any contrary construction
placed on our proposal by IPC.
9. Proposal Completeness, et al. IATA’s proposal
was both complete and demonstrated fully that IATA has a thorough understanding of
what is involved in the sponsorship and operation of a restricted TLD such as “.travel,”
and that IATA has carefully considered all relevant issues, realistically assessed
the business, financial, technical, operational and marketing requirements for implementing
the proposal, has produced firm commitments for all necessary resources, and has
formulated sound business and technical plans for executing the proposal.
For all these
reasons and those set forth in our application, we respectfully request that ICANN
grant our application for the “.travel” TLD and that ICANN and IATA collectively
proceed to the realization of the “.travel” TLD.
Support of IATA’s Application for a “.travel” TLD
AGENTS AND AGENT
ASTA (American Society of Travel Agents)
World’s largest association of travel professionals.
26 000 members comprised
of travel agents, as well as tour and cruises companies, hotels, car rentals etc.
ABA (A Bargain Affair)
Leader in providing low fare, reliable travel
services to the frugal shopper.
of Canadian Travel Agents is Canada's largest membership based tourism association
with close to 3,000 members
It represents the interests of Canadian travellers
through 5,000 travel agencies
Bill Healy Travel
CITS (China International Travel Service)
travel agent in China.
Covers 80% of the travel spectrum, both inbound
[Miami, FL and Raleigh, NC]
ARC accredited agency that provides a wide
range of travel and consulting services to international ministry and humanitarian
relief organizations located throughout North America.
SITA World Travel
(Nepal) Pvt. Ltd.
Southeast Travel Corp
Travel Industry Services, Gregorys International
An organization that works within the more austere environments, such as the Eastern
UFTAA (Universal Federation of Travel Agents’ Associations)
Represents 48 000 individual travel agencies in 97 countries.
AIRCRAFT MANUFACTURING INDUSTRY
Fairchild Dornier Corporation
Aerospace Regional Aircraft
CAE Electronics Ltd.
Delta Air Lines
Iberia Airlines of Spain
Saudi Arabian Airlines
Lan Chile Airlines
Royal Jordanian Airline
SairGroup, Swissair, The Airline of Switzerland
AACO (Arab Air Carriers Association)
AAFRA (African Airlines Association)
representing 33 member airlines:
Libyan Arab Airlines
LAM Mocambique Airlines
Lignes Aeriennes Congolaises
Royal Air Maroc
South African Airways
TAAG Angola Airlines
AASA (Airlines Association
of Southern Africa) representing 29 members:
Airports Company South Africa
Avis Rent A Car
Shell South Africa
South African Airlink
South African Airways
The Boeing Company
AEA (Association of European Airlines)
Represents 29 major European scheduled
TAP Air Portugal
AITAL (Asociation Internacional de Transporte Aereo Latinoamericano)
Major airline trade association, comprising 23 international carriers:
Alas de Venezuela
Lloyd Aereo Boliviano
Mexicana de Aviacion
AAPA (Asia Pacific Airlines Association)
IACA (International Air Carrier
37 airline members:
Air Europa Espana
Air Europe SPA
Air Holland Charter
Britannia Airways UK
Hapag Lloyd Flug
LTU International Airways
Aeroport de Paris (ADP)
BAA plc (British Airport
Owner and operator of major international airports in the
UK, US, Italy and Australia.
Air Navigation Services Organisation)
AIR TRANSPORT SALES AGENCIES
CAS (China Air Service)
One of the largest air transport sales agencies,
including tour operations, in China for both inbound and outbound travel.
AU PAIR ORGANIZATIONS
IAPA (International Au Pair Association)
Consulting firm active
in the travel and transport industry worldwide.
KPMG Consulting LP
Consulting firm with significant experience across multiple industry verticals.
Air Transport User Representatives in Europe
Leading consumer travel
federation in Europe.
I WINGS, Inc.
Internet-based travel service company.
Provides travel agency community
with the ability to search instantly all available Web fares for comparison with
GDS fares when seeking travel itineraries for their clients.
(Paul Mencinger) –Webmaster of many
tourism and travel oriented web sites.
GROUND HANDLING SERVICES
Leading service provider in the airline industry
ACCOR Asia Pacific Division
IH&RA (International Hotel & Restaurant Association)
Global network of
independent and chain operators, national associations, hospitality suppliers and
educational centres in the hotel and restaurant industry.
over 750,000 establishments in more than 150 countries.
Provides a voice
at international level for an industry which comprises more than 300,000 hotels and
8 million restaurants world-wide, employs 60 million people and contributes US$950
billion to the global economy.
ATPCO (Airline Tariff Publishing Company)
Eurostar Group U.K.
The UK provider of the Eurostar
Rail Services together with French (SNCF) and Belgian (ANCB/NMBS) Railways.
U.I.C. (Union Internationale des Chemins de Fer – International Union of Railways)
VIA Rail Canada
Canada’s national passenger
Messe Service Leipzig GmbH
Organizer of the “Leipziger Messe,” one of the world’s
foremost trade fairs.
TRAVEL AND TOURISM ORGANIZATIONS
Aviation and Tourism International
of Language Travel Organisations)
FIYTO (Federation of International
Youth Travel Organisations)
Israeli Government Tourism Office for the
PATA (Pacific Asia Travel Association)
Members: nearly 2 000 government tourist offices, destination promotion boards,
airlines, cruise lines, hotels, tour operators, travel agencies and other travel-related
Mission: enhance the growth, value and quality of Pacific
Asia travel and tourism on behalf of members.
TIA (Travel Industry Association
Represents the U.S. travel industry for 59 years.
Mission: facilitate enhanced travel to and within the United States.
WTO (World Tourism Organization)
organization that serves as a global forum for tourism policy and issues.
Members include 138 countries and territories and more than 350 affiliate members
from the public and private sectors.
Mission: Promote and develop
tourism as a significant means of fostering international peace and understanding,
economic development, and international trade.
WTTC (World Travel and
Global non-profit association that has worked together
with the Travel & Tourism industry to ensure its competitive and sustainable development.
Members represent all sectors of the Travel & Tourism industry, have over the years
worked together with public and private sectors across the globe to advance the development
of Information Technology and E-commerce to benefit Travel & Tourism business and
WYSTC (World Youth and Student Travel Conference)
INDIVIDUALS / CUSTOMERS
an “e-commerce professional”