.vuelos Domain

18.1 Mission and Purpose of .VUELOS

Despegar Online SRL ("Despegar") is a branch of the largest online travel agency in Latin America. Despegar enables its customers to book airline tickets, hotel rooms, rental cars, vacation packages, and other travel-related services. It also powers travel bookings for various airlines, hotels, rental car agencies, and other tourism-related organizations internationally. Despegar serves more than five million clients annually and has a presence in 21 countries. Its services and online content are accessible in the .COM gTLD and various ccTLDs.

Despegar is applying for five gTLDs: .VUELOS and .HOTELES, which target its Spanish-speaking audiences; .PASSAGENS and .HOTEIS, which target its Portuguese-speaking audiences; and .HOTEL, which targets its English, Spanish, and Portuguese-speaking audiences.

The intended future mission and purpose of .VUELOS is to serve as a trusted, hierarchical, and intuitive namespace provided by Despegar. Despegar is committed to filing a .VUELOS gTLD application; however at the time of filing this application, there has not been enough time, and there is not enough market information available, to fully analyze and evaluate all potential use case options.

Despegar will be analyzing and evaluating other gTLD applications as well as general market adoption to determine short- and long-term potential best-in-class use case options to most effectively serve and enhance its online strategy as a leading provider of travel services. As a multinational travel organization, Despegar helps customers book various travel reservations with a focus on competitive pricing and excellent service, and aims to protect its customers and other Internet users from fraudulent information. .VUELOS will accord with the company's focus by providing a trusted, hierarchical, secure, and intuitive namespace.

Superb service and pricing are at the core of Despegar's offerings, and will continue to remain at that core; Despegar will always be in the business of offering the best prices and services to those booking travel arrangements in Latin America. One of Despegar's key business segments is booking airline tickets. The .VUELOS gTLD will become one of Despegar's core assets and it is intended to enhance Despegar's online presence and identity; expand its marketing and promotion efforts; provide a secure channel for those booking airline tickets; and offer a platform through which to consolidate many of the intellectual property activities of Despegar.

Despegar intends to initially limit registration and use of domain names within the .VUELOS gTLD to Despegar and its qualified subsidiaries and affiliates. This initial limited use will allow Despegar to establish its operations and achieve full sustainability. This limited distribution, coupled with the other requirements set forth in Specification 9 of the template Registry Agreement, is intended to exempt Despegar from its annual Code of Conduct Compliance requirements.

After Stage 3 (see below), Despegar will evaluate whether opportunities exist to carry out the business strategy for the .VUELOS gTLD through expansion that continues the sustainable operations of the registry through fee-based registrations to parties other than Despegar and its qualified subsidiaries and affiliates.

Despegar currently plans a four-stage rollout for the .VUELOS gTLD:

1. Stage 1
The initial stage of implementation of the gTLD will involve Despegar registering a limited number of .VUELOS second-level domain names.

This initial use will provide Despegar's IT and security personnel the time to run a number of tests to ensure seamless and secure access using the .VUELOS gTLD domain names, interoperability with various software and Web-based applications, and unbroken and secure use of all names. This initial allocation will also allow the appropriate Despegar staff to coordinate with the internal and external staff responsible for the delegation and setup phases of the .VUELOS gTLD to ensure a proper transition from delegation to full operation.

2. Stage 2
Once all testing has been successfully completed, Despegar will begin allocating domain names in .VUELOS for more widespread internal corporate use. During this same period of time, Despegar will begin evaluating strategies to potentially migrate traffic away from its current patchwork network of second-level domain names, which are registered in a variety of TLDs, to Despegar's new gTLDs.

It is in Stage 2 that Despegar will evaluate expanding the operations of the gTLD to permit registration by other registrants such as licensees and/or strategic partners. Should an assessment of its expansion strategy lead to a decision to extend registration rights to other parties, this expansion is currently planned to take place during Stage 3. However, any expansion would be conditioned upon a review of Specification 9 (Registry Code of Conduct) set forth in the template Registry Agreement to ensure compliance with Despegar's business model.

3. Stage 3
Depending on the analysis of the evaluations undertaken in Stage 2, Despegar may implement its decision to extend registration rights to licensees or strategic partners, including, but not limited to, travel companies, hotels, airlines, and other tourism organizations, depending upon compliance with Specification 9 as noted above. The dates of such expansion are subject to change depending upon business, strategic, and industry factors at the time.

After consideration of the following factors: analysis of Despegar's existing domain name portfolio; internal analysis of marketing initiatives; and the fact that Despegar will have full control over the number of registrations in the .VUELOS gTLD namespace, Despegar is confident that the number of domain name registrations will be less than 10,000 in the first five years of operation.

4. Stage 4
Based on its experience with any expansion implemented in Stage 3, Despegar will assess whether its business plan and expansion strategy should be augmented by extending registration rights to a broader class of licensees, potentially including customers of Despegar. It is anticipated by Despegar that changes to the domain name industry will take at least five years to be realized and assessed. Any decision to expand the gTLD beyond corporate, partner, and licensee use will take into account this experience as well as the technical analysis of potential expansion.

Notwithstanding this potential future expanded use of .VUELOS beginning in the sixth year of operation, Despegar currently anticipates implementing a throttle mechanism to ensure that any proposed expansion is controlled and responsible.

Specifically, under the anticipated throttle mechanism Despegar would cease registration of domain names to this potential expanded universe of registrants if and when Despegar reaches 90 percent of the annual 50,000-domain name transaction threshold currently provided for in the template Registry Agreement. Despegar believes that is prudent to incorporate this "time-out" into the business plan in order to reevaluate potential future growth and the necessary resources to ensure that this growth does not negatively impact the secure and stable operation of .VUELOS when approaching the 50,000-domain name transaction threshold. This proposed "time-out" mechanism is described in greater detail in the responses to the financial questions (Questions 45 through 50) of this application.

The potential use of .VUELOS will also be driven by Despegar's future business strategies. Utilizing current projections based upon Despegar's existing businesses, future business plans, current domain name portfolio, and other strategic factors, Despegar estimates second-level domain name registrations to be in line with the projections set forth in the financial template provided in response to Question 46 of this application.×

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Despegar believes that a proposed .VUELOS gTLD has the potential to offer the following benefits to Internet users and consumers:
-Establish a trusted source of information and an online marketplace for the millions of consumers who make travel reservations through Despegar's websites, as well as serve as a secure point of sale location for numerous global airlines, for third parties seeking information, and for the general Internet user population;
-Provide Despegar and its qualified subsidiaries and affiliates with short and memorable Internet addresses; provide increased navigation to products, services, advertising campaigns, public interest content, public awareness initiatives, etc.;



-Minimize the cost and need for defensive registrations because domain names within .VUELOS will only be allocated internally to Despegar and its qualified subsidiaries and affiliates, at least for the first three years of operation; and
-Develop a potential platform for secure access to, purchase of, and distribution of Despegar's services and information to its Spanish-speaking consumers, in order to minimize the potential for counterfeit or infringing goods and services.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .VUELOS gTLD is to provide a trusted, hierarchical, secure, and intuitive online marketplace to deliver Despegar's content, services, and information relating to airline bookings and Despegar's other offerings and information to Spanish-speaking customers, interested parties, and the general internet population. As Despegar continues to expand, it wishes to pursue and develop opportunities to market and distribute its online content and products to consumers throughout Latin America, the United States, and internationally on various platforms, including the Internet and mobile devices, among others.

The tourism industry and travelers alike increasingly use the Internet as the main portal for making travel reservations. Given the increasing demand to access Despegar and its products through a variety of channels, including domain names, Despegar believes that a .VUELOS gTLD has the potential to provide an innovative, virtual avenue to Despegar goods and services that will deepen and broaden its relationship with consumers.

Most importantly, Despegar will be able to provide access to its products and online content in a namespace devoid of piracy, cybersquatting, and other malicious activities. Providing consumers with a trusted experience is paramount to Despegar, and a .VUELOS gTLD will be used to further that goal by creating a safe, dedicated marketplace serving Spanish-speaking consumers and interested parties.

While online travel companies such as Despegar fight a never-ending battle to protect consumers from piracy on the Internet, .VUELOS would offer consumers a safe and intuitive means of accessing authorized content from Despegar and its qualified subsidiaries and affiliates, as well as for shopping for and making reservations for travel-related services.

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

The primary driving factors of the .VUELOS gTLD are differentiation and innovation. Additionally, Despegar believes that the creation of a space dedicated to Spanish-speaking individuals that are interested in, and businesses that offer, airline- and travel-related content will benefit this group of consumers and businesses, as well general Internet users. The number of domain names registered will not measure the success of the gTLD, but rather success will be judged by the level of consumer recognition and trust that is placed in the .VUELOS gTLD. Using this benchmark, Despegar strives to build consumer recognition and trust through the usage of the .VUELOS gTLD that rises to the level of that found in the .EDU and .GOV gTLDs.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

Despegar believes that the .VUELOS gTLD will provide a trusted ecosystem experience for Spanish-speaking individuals and for the millions of consumers worldwide who make reservations through Despegar, as well as those who seek information that Despegar provides, such as members of the press. In addition to providing consumers with short, memorable, and intuitive domain names, the .VUELOS gTLD will indicate to consumers that all domains and content therein are owned and controlled by Despegar, thus protecting users from potential infringing, pirated, or harmful content.

The initial use of the .VUELOS gTLD will involve Despegar registering a limited number of second-level domain names. This initial use will provide Despegar's IT and security personnel the ability to run a number of tests to ensure seamless and secure access to the Despegar websites, and interoperability with various software and Web-/mobile-based applications. Once appropriate security and stability issues have been satisfactorily addressed, Despegar will likely begin allocating domain names for internal corporate use and may redirect new .VUELOS domain names to preexisting content. This phased rollout will likely take place over a multi-year period, but is subject to change depending upon a range of external factors.

During this same period of time, Despegar will evaluate potential strategies to use the .VUELOS gTLD in other ways that will advance Despegar's corporate mission and goals.

18.2.4 Provide a complete description of the applicant's intended registration policies in support of the goals listed above.

Despegar currently intends for the .VUELOS gTLD to be exclusively used by Despegar and its qualified subsidiaries and affiliates, at least for the first three years of operation. Because of this condition, Despegar intends to address registration and use requirements in its qualified subsidiary and affiliate agreements, rather than in a domain name registration agreement.

Notwithstanding this, Despegar will incorporate all required ICANN consensus policies and other legal/policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreements.

18.2.5 Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

As an Internet-based travel company, Despegar recognizes that this is an evolving area of law in which there is no international standard. However, due to the fact that every domain name will be registered to Despegar and its qualified subsidiaries and affiliates, at least for the first three years of operation, Despegar has a vested interest in making sure that accurate and current domain name information is readily available in connection with each .VUELOS domain name. For the .VUELOS gTLD, all private and confidential information will be protected.




Despegar will ensure that the operation of the .VUELOS gTLD will be consistent with its privacy policy, available on its website, see http://www.us.despegar.com/commercial-web/security/confidentiality.

In addition, Despegar intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators.

The template Registry Agreement states, "Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person ("Personal Data") submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars."

18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

Despegar sees the potential for this gTLD to play a large role in Despegar's future online strategic initiative. However, there are a number of unanswered questions concerning consumer recognition, the adoption of new gTLDs, and the response from search engines in the marketplace that will influence the usage of the gTLD and communication about that usage.

Notwithstanding this, Despegar plans to start using .VUELOS domains initially as redirects to existing .COM domains. Despegar also plans to carefully review the release of new gTLDs by others, the response from search engines to gTLDs, and the perception of consumers. As the marketplace evolves, Despegar will invest in outreach and communication as needed to ensure that its consumers, partners, and affiliates continue to interact with Despegar content in a simplified and efficient manner.×

18.3 What operating rules will you adopt to eliminate or minimize social costs (e.g., time or financial resource costs, as well as various types of consumer vulnerabilities)?

Despegar's proposed operating rules to limit registration to Despegar and its qualified subsidiaries and affiliates, at least for the first three years of operation, will provide a trusted online environment for consumers to access Despegar's online content, and by default will minimize social costs. This verified ecosystem provides consumers with a single, trusted source for Despegar goods and services with a substantially lower risk of the fraud, misdirection, infringement, or scams that consumers are plagued with in .COM and other open gTLDs. Despegar does not anticipate consumer vulnerabilities. Therefore, one way in which social costs will be eliminated is that there will be no need for other trademark and brand owners to defensively register second-level domains in the .VUELOS gTLD. In fact, Despegar's expectation is that the usage of a .VUELOS gTLD will eliminate many of the vulnerabilities that Despegar consumers face in the wider Internet today.

18.3.1 What other steps will you take to minimize negative consequences/costs imposed upon consumers?

Despegar believes that the proposed operation of the .VUELOS gTLD as set forth in this application has no known negative consequences or cost implications to consumers. On the contrary, the proposed operation of this registry will likely lead to direct and quantifiable benefits to consumers.

18.3.2 How will multiple applications for a particular domain name be resolved, for example, by auction or on a first-come/first-serve basis?

Despegar does not envision multiple applicants for the same domain name, as domain names will only be allocated to Despegar and its qualified subsidiaries and affiliates, at least for the first three years of operation, in accordance with Despegar's business plan for the .VUELOS gTLD.

18.3.3 Explain any cost benefits for registrants you intend to implement (e.g., advantageous pricing, introductory discounts, bulk registration discounts).

Despegar does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing/commercial initiatives are inconsistent with the mission and purpose of the .VUELOS gTLD as a trusted online source identifier. Moreover, Despegar currently intends to provide domain name registrations to itself and its qualified subsidiaries and affiliates at no cost, though the company reserves the right to reevaluate this decision and may alter it in the future.

18.3.4 Note that the Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than ten years. Additionally, the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation? If so, please describe your plans.

Despegar is committed to providing the domain name registration periods set forth in the Registry Agreement. However, as noted above, the registration and use of the domain name is conditioned upon a separate qualified subsidiary or affiliate relationship with Despegar. As such, providing contractual commitments in a domain name registrant agreement regarding the magnitude of price escalations does not seem relevant or appropriate. Additionally, as noted above, the current business model envisions Despegar providing domain name registrations to itself and its qualified subsidiaries and affiliates at no cost, at least for the first three years of operation.

Despegar acknowledges that the current template Registry Agreement requires the Registry Operator to "offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar." However, Despegar and its qualified subsidiaries and affiliates, as the sole registrants within the .VUELOS gTLD, will only be registering domain names annually. This is done to better account for annual costs, as well as to provide for more concise financial statements in Question 46 of this application; therefore there will be no multi-year registrations or deferred revenue.×

22.1 Despegar Online SRL has Properly Researched this Topic

Despegar Online SRL ("Despegar") is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the Domain Name System (ʺDNSʺ). In preparation for answering this question, Despegar reviewed the following relevant background material regarding the protection of geographic names in the DNS:

-ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain, see http://www.icann.org/en/minutes/minutes-10sep01.htm;
-ICANN's Proposed Action Plan on .INFO Country Names, see http://www.icann.org/en/meetings/montevideo/action-plan-country-names-09oct01.htm;
-"Report of the Second WIPO Internet Domain Name Process: The Recognition and Rights and the Use of Names in the Internet Domain Name System," Section 6, Geographical Identifiers, see http://www.wipo.int/amc/en/processes/process2/report/html/report.html;
- ICANN's Governmental Advisory Committee (GAC) Principles Regarding New gTLDs, see https://gacweb.icann.org/download/attachments/1540128/gTLD_principles_0.pdf?version=1&modificationDate=1312358178000; and
-ICANN's Generic Names Supporting Organization Reserved Names Working Group - Final Report, see http://gnso.icann.org/issues/new-gtlds/final-report-rn-wg-23may07.htm.

22.2 Initial Reservation of Country and Territory Names

Despegar is committed to initially reserving the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the Applicant Guidebook at the second level and at all other levels within the .VUELOS gTLD at which Despegar will provide registrations. Specifically, Despegar will reserve:

1. The short form (in English) of all country and territory names contained on the ISO 3166-1 list, as updated from time to time, including the European Union, which is exceptionally reserved on the ISO 3166-1 list, and its scope extended in August 1999 to any application needing to represent the name European Union, see http://www.iso.org/iso/support/country_codes/iso_3166_code_lists/iso-3166-1_decoding_table.htm#EU;

2. The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and

3. The list of United Nations member states in six official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

22.3 Fair & Non-Misleading Use of Geographical Identifiers

Despegar Online SRL ("Despegar") is a branch of the largest online travel agency in Latin America. Despegar is a leading multinational tourism organization that enables customers to book airline tickets, hotel rooms, rental cars, vacation packages, and other travel-related services. Despegar also powers travel bookings for various airlines, hotels, rental car agencies, and other tourism-related organizations internationally. Despegar serves more than five million clients annually and has a presence in 21 countries. Its services and online content are accessible in the .COM gTLD and various other ccTLDs.

Despegar is applying for five generic-term gTLDs: .VUELOS and .HOTELES, which target its Spanish-speaking audiences; .PASSAGENS and .HOTEIS, which target its Portuguese-speaking audiences; and .HOTEL, which targets its English, Spanish, and Portuguese-speaking audiences.

In providing online content, sales, and services, Despegar makes regular use of geographical identifiers to provide consumers with a hierarchical and intuitive namespace to navigate for relevant content. For example, at its home page, users have the ability to select a country in order to receive the appropriate, geographically specific content, see www.Despegar.com.

Despegar would like to provide a hierarchical and intuitive framework for the .VUELOS namespace by using geographical identifiers as second-level domain names. This use of geographical identifiers to the left of the gTLD and as part of the domain name itself is believed to have a direct and material impact on search engine algorithms and their corresponding query results. Despegar would like to see if this type of hierarchical and intuitive use of second-level domain names within a gTLD provides increased consumer functionality and innovation, as premised by ICANN.

Currently, Despegar operates a number of corporate websites using a combination of second-level and top-level domain names. A representative sampling of Despegar websites that incorporate geographical identifiers into the domain name include:

Despegar.cl
Despegar.com.bo
Despegar.com.ve
DespegarPeru.com
VuelosMiami.com.mx

Despegar believes that a .VUELOS gTLD can provide an online, single-source identifying function for its current and future customers around the world who are seeking to make flight and other travel purchases. This is in contrast to the present approach Despegar has used as it expands into different markets around the world, which consists of registering the domain names that are available, rather than those that may be the most intuitive.

22.4 The Legal Protection of Geographical Identifiers

One of the more authoritative resources on the current state of the law in connection with the protection of geographical identifiers was authored by the World Intellectual Property Organization (WIPO) in its 2001 "Report of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name System" publication. Section six of this report was devoted exclusively to the protection of geographical identifiers.

In analyzing the well-established framework against the misuse of geographical identifiers at the international, regional, and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications (see "Report of the Second WIPO Internet Domain Name Process," Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in Despegar's current or proposed use of geographical identifiers.

Notwithstanding WIPO's recommendation that the protection of geographical identifiers is "a difficult area on which views are not only divided, but also ardently held" (Paragraph 237) national governments within the ICANN Governmental Advisory Committee (GAC) and other international forums have continued to advocate for increased safeguards to protect against the misuse of geographical identifiers within the domain name system.

Despegar, acting as a responsible international business, seeks to minimize any potential business practices that might mislead consumers. However, at the same time, it believes that it is important to be able to use geographical identifiers in a fair use and non-misleading manner, if such use can benefit Internet users as proposed in Despegar's business model.

22.5 Samples of Fair & Non-Misleading Use of Geographical Identifiers

In undertaking a thorough research of this subject matter prior to filing this application, Despegar's subject matter experts were able to uncover the following representative sampling of fair and non-misleading use of geographical identifiers used in the existing gTLD domain name space:

Fair Use of National Geographical Identifiers

AUSTRALIA.COOP - Is operated by Co-operatives Australia, the national body for State Co-operative Federations, and provides a valuable resource about cooperatives within Australia.

USA.JOB〉 - Is operated by DirectEmployers Association (ʺDEʺ). While Employ Media, the registry operator of the .JOBS gTLD, is currently in a dispute with ICANN regarding the allocation of this and other domain names, DE has a series of partnerships and programs with the United States Department of Labor, the National Association of State Workforce Agencies, and Facebook to help unemployed workers find jobs.

MALDIVIAN.AERO - Is the dominant domestic air carrier in Maldives, and provides a range of commercial and leisure air transport services.

Fair Use of Regional/Local Geographical Indicators

BROOKLYN.COOP - Is operated by Brooklyn Cooperative Federal Credit Union, which began as a modest storefront business in 2001, but is now New York City's fastest growing credit union and a model for community development credit unions nationwide.

HYDERABAD.AERO - Is operated by the Hyderabad International Airport and provides a range of interactive services and information for both business and leisure travelers.

SACRAMENTO.AERO - Is a portal website operated by Sacramento County to provide links to each of the airports serving the Sacramento area: Sacramento International Airport (SMF), Mather Airport (MHR), Executive Airport (SAC), and Franklin Field (F72).

22.6 Protection of Regional and Local Geographic Names for Non-Misleading Use

Despegar has stated its intention to consider using non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading use to help consumers navigate the .VUELOS namespace. Despegar is committed to operating the .VUELOS namespace in a manner that minimizes potential consumer confusion, and will actively work with others in the ICANN community regarding any future policy development in this area.

22.7 Potential Future Release of Initially Reserved Names

Given that Despegar is an international organization currently operating in numerous countries, Despegar looks forward to collaborating with other new gTLD registry operators in potentially working with ICANN's GAC to explore potential processes that could permit the release of initially reserved country names (including ISO-3166 two-characters). Specifically, Despegar is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD registry operators in releasing previously reserved domain names.

22.8 Dispute Resolution

Despegar does not envision any potential disputes from governments or public authorities in connection with the registration and use of geographic names within the .VUELOS gTLD based upon its proposed use, set forth in the response to Question 18 of this application.

However, Despegar is committed to working with governments, public authorities, or IGOs that may have a concern regarding the registration of names with national or geographic significance at the second level within .VUELOS. Therefore, should there arise any potential disputes, Despegar will undertake an immediate policy development process as identified below.

22.9 Creation and Updating the Policies

If there should arise some future need for the creation or updating of the policies regarding this class of domain names, Despegar will act in an open and transparent manner consistent with its prior practices to develop such a policy and/or recommendation.

Despegar is also committed to continually reviewing and updating these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, Despegar intends to remain an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.×