Application Comment Details


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James G Trope

Erie Insurance Group

Allstate Fire and Casualty Insurance Company

CARINSURANCE

1-1191-70059

Limited Public Interest Objection Ground

Anticompetitive Impact

27 September 2012 at 01:17:01 UTC

Erie Insurance Group (Erie) consists of six affiliated insurance carriers and is based in Erie, Pennsylvania. Erie, founded in 1925, provides a full range of insurance products and services to its clients in eleven states and the District of Colombia. Erie’s products include homeowners insurance, auto insurance, commercial insurance and life insurance. Erie has over 4.3 million policies in force and is rated A+ by A.M. Best.

Erie reviewed Allstate Fire and Casualty Insurance Company’s (Allstate) application for the proposed new gTLD .CARINSURANCE. Our initial conclusion is that Allstate’s filing would be contrary to the basic principles that were established by ICANN as a rationale for expanding the number of available gTLD’s.

ICANN states on its website that:

“The new generic Top-Level Domain program was developed to increase competition and choice by introducing new gTLDs into the Internet’s addressing system.”

ICANN states further that internet users would benefit from the expanded universe of Top-Level Domain names because expansion would:

• Create a platform for innovation in the industry and internet

• Open doors to increase choice and competition in the marketplace

• Provide new ways to find information, products and services.

Allstate’s application for the new gTLD .CARINSURANCE. states that:

The .CARINSURANCE gTLD registry will be a standard, not a community-based, registry. The .CARINSURANCE gTLD registry will be a standard registry restricted to AFCIC and its qualified subsidiaries, affiliates, business partners, or others having the Required Agreement. The registry will be closed to registrants who do not have a formal, written agreement from AFCIC or an affiliate of AFCIC, specifically allowing the registration of a second-level domain name in the .CARINSURANCE gTLD registry (the “Required Agreement”). There will be no market for second-level registrations outside of registrants that are affiliated with AFCIC…

Erie believes that awarding the new gTLD .CARINSURANCE to Allstate for its exclusive use would be contrary to underlying principles enunciated by ICANN in fostering competition, innovation, and growth. Awarding the gTLD .CARINURANCE to Allstate would have significant consequences because Allstate would then be in a position to dictate and control both access and use on a global basis by both insurance related entities and internet users. The growth of the internet as a source of information has grown exponentially because an internet user can readily obtain information about competing products and companies. The result is a more informed buying decision. Allstate’s filing would impede information dissemination and stifle competition.

The awarding of a new gTLD to an entity establishes that entity as a gatekeeper. In any highly competitive environment the gatekeeper must remain neutral at all times. It would be difficult for Allstate as a competitor in the insurance marketplace to remain neutral. This point is brought home by Allstate’s gTLD filing.

In view of the foregoing, Erie believes that it would be inappropriate for ICANN to award the new gTLD .CARINSURANCE to Allstate.