applications of generic internet domain names
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. Please note: This email and any files transmitted with it is intended only for the named recipients and may contain confidential and/or privileged information. If you are not the intended recipient, please do not read, copy, use or disclose the contents of this communication to others and notify the sender immediately. Then please delete the email and any copies of it. Thank you. P Please consider the environment before printing this e-mail.