Application number: 1-1000-62742 for STARTING DOT

STARTING DOT

+33977196810

+33977196810

http:⁄⁄www.startingdot.com

Mr. Godefroy Jordan

President

+33977196810

startingdot@jwgroupe.com

Mr. Guillaume Buffet

Managing Director

+33609482241

guillaume@startingdot.com

société anonyme simplifiée (S.A.S)

Loi numéro 94-1 du 3 janvier 1994
Republique française (France)
http:⁄⁄legifrance.gouv.fr⁄affichTexte.do?cidTexte=JORFTEXT000000727529

Not Available

Godefroy JORDAN
President
Guillaume BUFFET
Managing Director

Godefroy JORDAN
President

immo

Not Available

We have carefully examined (including S.W.O.R.D test) the applied-for string .immo and found that deployment of it would not cause adverse operational, rendering, or general user-confusion due to visual similarity with existing TLDs⁄ISO3166 lists⁄ICANN reserved list of names & list of ineligible strings. The string consists entirely of ASCII letters and is a valid hostname having at least three and less than 63 characters, the ASCII Label is therefore in compliance with the string requirements set forth in the Applicant Guidebook (Applicant Guidebook, page 64, section: 2.2.1.3.2 “String Requirements”) and with all technical standards such as but not limited to RFC 1035, RFC 2181, RFC 952, RFC 1123, and RFC 3696.
Although the applied for string is pure ASCII characters the applicant is aware of its responsibility to seek to mitigate and solve inter alia such issues, as discussed on the “TLD Universal Acceptance” session at the Costa Rica ICANN Meeting on Wed, 14 March 2012 (http:⁄⁄costarica43.icann.org⁄meetings⁄sanjose2012⁄presentation-tld-universal-acceptance-14mar12-en.pdf):
1. Validity checks of TLDs based on either a hard coded list (may not be updated with all new gTLDs) or on a length check (i.e. maximum three characters).
2. Name conversion in various applications and browsers. Based on wrong definitions or outdated lists of TLDs, some applications may not convert this new gTLD to links.
3. User acceptance. Some websites⁄applications may refuse user acceptance of users entering a new gTLD not accepted by the website⁄application.
4. Email clients validating on length on TLDs on by applying an outdated list of TLDs may also cause problems for this new gTLD, as valid email addresses may not be accepted.
5. Websites and Search Engines such as, but not limited to, Google, Yahoo! may refuse to offer services such as advertising, if they validate email addresses and valid domain names based on outdated definitions of TLDs, or simply refuse to add new gTLDs to their lists.
6. Mobile browsers may also not be updating their lists of valid TLDs, as live DNS look ups, may be considered costly or in adequate by the providers.
Actions to mitigate or solve these issues:
As the TLD is longer than 3 characters, it is understood that some issues concerning usage of the TLD in online forms will exists. We take the full responsibility for any such issues and will work towards enabling general global acceptance for TLDs, not just with this TLD but all others as well. We will ensure that all known websites expecting to use the TLD will be communicated with concerning this issue and we will make all our own online forms available to accept all ICANN TLDs per the IANA list. We will work with ICANN in our on-going effort on this subject both for IDN TLDs and ASCII TLDs.
Second Level IDN specific issues are addressed in our response to Question 44.

The .immo gTLD will serve a community restricted to businesses, organizations, associations, and governmental and non-governmental organizations operating in the real estate industry, while targeting in particular German, French, Italian and Catalan speaking countries (e.g. an estimate of 41 states in the world).

In these four languages “immo” is well-known short form the word meaning “real estate”:
- “immo”, short form of “Immobilien” in German;
- “immo”, short form of “immobilier” in French;
- “immo”, short form of “immobiliare” in Italian;
- “immo”, short form of “immoble“ in Catalan. 

Accordingly, the .immo gTLD will be understood and used by an estimate of 240 million Internet users in 41 countries (e.g. France, Germany, Italy, Switzerland, Belgium, Austria, Luxemburg, Lichtenstein, Morocco, Tunisia, Algeria).

“Immo” describes real estate services (e.g. selling, buying, renting and leasing) provided to households and to businesses.

The real estate community is composed of different business segments, concentrated in two principal markets: 
a. The primary market, mostly dedicated to construction services such as property development and home building;
b. The secondary market dedicated to existing properties: 
- Realtors (rental or sale);
- Property traders (purchase and sale);
- Property managers.

i) Goal of the .immo gTLD 

The real estate industry is composed of different business segments, in particular: 
- Commercial and Residential Real Estate Agents and Brokers;
- Rental Property Management Services;
- Real Estate Publishers (Information Media, Classified Media, Management Software);
- Service Providers for Real Estate Professionals;
- Real Estate Mortgage services (Loan, Insurance);
- Homebuilders;
- Real Estate Developers;
- Notaries.

Buying a house or a property is and expensive and sometime lifetime commitment. It is often the largest single purchase and the biggest net asset of a household. National real estate legislations are therefore very restrictive. Business relationships and financial transactions related to the real estate market are strictly controlled. 

Through the application of restrictive eligibility policies defined in collaboration with the real estate community, Starting Dot intends to enforce real estate legislations within the .immo gTLD. 

As a secure, controlled and industry-specific string, the .immo gTLD will thus not only improve the industry’s Web credibility but also generate more transactions. 

Starting Dot has identified at least 600,000 organizations and companies that are eligible to register a domain name under the .immo gTLD and expects to achieve a market penetration of 3.5% after 3 years of operation of the proposed gTLD (which equals about 21,000 domain name registrations). 

ii) Key differentiation factors brought by the .immo new gTLD

The real estate industry and its segments have long been at the forefront of usage of information technology, as reflected by the fact that approximately 90% of German and French real estate agents own a website. 

The .immo gTLD will serve as recognition of the industry’s leadership in information technology. 

Buyers now use the Web to search for real estates. Currently, the most successful realtors are drawing over 50% of clients from Internet sites. The Internet has clearly become a major communication and transaction vehicle for the real estate community and its consumers. 

Existing TLDs however do not enforce such legislations, as anyone is able to sell real estate-related services via Internet. 
The .immo gTLD, on the contrary, will enforce existing legislations and thus provide a unique, safe and industry-specific online platform to conduct business and to search for information related to real estate. 

Due to scarcity of space within the existing domain name system, many established and newly established real estate professionals have not been able to register the domain name they initially wanted. 

The .immo gTLD will offer an entire new pool of domain names that are available for registration. As a common identifier, the .immo gTLD will promote a sense of community identity within the real estate industry. 

iii) Goals of the .immo gTLD in terms of user experience 

BENEFITS OF THE .IMMO GTLD FOR THE REAL ESTATE INDUSTRY

The real estate industry ranks currently among the biggest e-commerce players. The use of websites to promote their business has clearly become the norm in the real estate community. 

Real estate is a highly regulated industry. In most countries, especially in the European Union, an official authorization or business license is required in order to become a real estate professional. Usually, specific diploma requirements are imposed upon real estate professionals. 

Legislations however, are disrupted on the Internet since anyone is able to publish real estate related content within existing TLDs. 

A key aim and utility of the .immo gTLD will be to provide an online platform restricted to real estate professionals and compliant with existing legislations.

BENEFITS OF THE .IMMO GTLD FOR CONSUMERS 

In March 2012, Google AdWords Keyword Tool has registered a total of 80 million requests on Google for the keywords ““immobilien“, “immobilier“, “immo“, “immobilie” and “immobiliare“. 

90% of homebuyers use the Internet as a source of information during their home-buying process. Existing search engines however display search results without any segmentation, creating both a risk for the online consumer and competition disadvantage for real estate professionals. 

Buying a house or property is an infrequent, complex, expensive and a highly regulated transaction. 

Through the implementation of restrictive and transparent eligibility policies, Starting Dot intends to reserve the registration of the .immo gTLD to real estate professionals only. 

The .immo gTLD will be recognized as a security label and therefore provide consumers with a new and safer user experience. 

iv) .immo intended registration policies 

In the operation of its proposed restricted .immo gTLD, Starting Dot intends to implement all current and future ICANN policies.

Accordingly, Starting Dot will follow ICANN’s policies with respect to dispute resolution, including the adoption of the Uniform Dispute resolution Policy, as the same may be amended from time to time. 

In addition, Starting Dot will design a specific dispute resolution procedure to address situations in which there is objectively clear abuse of: 
- A company name;
- A personal name;
- A professional name;
- A name with national or geographic significance.

ELIGIBILITY

Applicants of a .immo domain name will have to be verifiable participants in the real estate industry and each name applied for will have to be a name to which there is a right that has been established through rights registration or use thereof. Such rights can consist of, but are not necessarily limited to, registered or unregistered trademarks, trade names, company names, business identifiers, etc. insofar and to the extent protected by the laws of the country in which the applicant for the .immo domain name resides, has been established or conducts business activities. 

Participation in the real estate industry will have to be certified at the time the registrant applies for or register the domain name, which implies the acceptance of the domain name registration policies. 

Real estate practice is not subject to one single law but to different national laws and in some countries to none. This is also the case in Europe. Admissions to the profession, local customs, and practices of real estate have not been yet harmonized. There is a project of a European Professional Card but it has not been adopted yet. 

Accordingly, only the following property professions are eligible to apply for a .immo gTLD:

a. Commercial and Residential Real Estate Agents and Brokers compliant with industry-specific national laws, provided: 

- Membership in one of the national associations of real estate professionals listed by the Policy Advisory Committee and attached to the .immo domain name registration policies; or
- Professional card.

b. Property Management Services compliant with industry-specific national laws, provided: 
- Membership in one of the national associations of real estate professionals listed by the Policy Advisory Committee and attached to the .immo domain name registration policies; or
- Professional card.

c. Homebuilders and Real Estate Developers, provided: 
- Membership in one of the national associations of real estate professionals listed by the Policy Advisory Committee and attached to the .immo domain name registration policies; or
- Having a subsidiary company that is either a real estate agency or a real estate broker).

d. Notaries, provided: 
- Entitled to practice in the field of real estate under their national law.

e. Real Estate Publishers (Information Media, Classified Media, Management Software), provided: 
- At least 80% of their clients or advertisers belong to one of the above mentioned categories (a, b, c and d);

f. Real Estate Mortgage services (Loan, Insurance), provided:
- These are banks or Insurance offering Housing Loans and Housing Insurances. 

Starting Dot, in consultation with the Policy Advisory Committee may, at any time, extend this list to another real estate business segment. 

Starting Dot believes that these eligibility requirements will be a key impediment for registrants who are seeking to engage in abusive registrations and cyber-squatting.

Starting Dot has also defined a list of reserved and prohibited domain names under the .immo gTLD. Reserved names are domain names reserved for special use or for special organizations. Prohibited names are names that may not be registered under the .immo gTLD. 

RESERVED NAMES 

Unless agreed upon otherwise in writing with ICANN, Starting Dot will comply with the restrictions on registration of character strings set forth at Specification 5 of the Registry Operator Agreement. 

Starting Dot also intends to define and control a list of domain names that have a value for the entire real estate community, in order to delegate them to those registrants who are committing to use these in order to support the community for which the .immo gTLD is initially intended. 

Hence, one character labels and a list of generic names will be reserved by Starting Dot and only released at its sole discretion. 

PROHIBITED NAMES 

The list of prohibited names under the .immo gTLD includes, in particular: 
- Abusive terms;
- Racist terms; 
- Obscene terms;
- Terms relating to crime or offenses. 

THIRD-LEVEL NAMES 

Starting Dot does not intend to allow third-level name registrations under the .immo gTLD. 

ILLEGAL USE AND COMPLIANCE 

Use of a domain name that is barred or prohibited by law or legal proceeding in any jurisdiction, or is considered to be defamatory will permit Starting Dot to revoke the domain name. Policies to this end will be developed by the registry and published in due time following ICANN’s delegation of the .immo gTLD to Starting Dot.

ENFORCEMENT 

The .immo domain name registration policies will contain the following enforcement procedures and processes, in addition to those procedures that have been established in accordance with Consensus Policies such as the Uniform Dispute Resolution Policy:
- Verification of entitlement of the registrant at the time of registration of a domain name, and this on a sample basis; and
- Ongoing verification throughout the term of the domain name registration.

In principle, each new .immo domain name registrant will be verified within 3 month following registration. Starting Dot will verify whether a registrant meets the eligibility requirements and⁄or domain name restrictions on the basis of public information, such as the information displayed on the registrant’s website, as well as other sources (Internet, public registries). When in doubt, the Registry Operator will put the domain name on hold, and contact the registrant and the registrar with the request to provide proof that the registrant is meeting such requirements within a reasonable timeframe (e.g. copy of professional card). 

Furthermore, Starting Dot’s Complaints Point of Contact will handle any complaints in relation to a .immo domain name registration, including where the complainant alleges that a particular registrant does not meet the eligibility requirements or domain name restrictions.

If, following the investigation of a complaint or an ex officio review of the registrant’s compliance with the Registry Operator’s policies, no or insufficient proof is provided by the registrant that all policy requirements have been complied with, Starting Dot shall be entitled to put the domain name on hold or even revoke the domain name. Furthermore, Starting Dot may inform the public that the domain name has been previously used contrary to its registration policies. 
v) Measures for protecting the privacy or confidential information of registrants 

Starting Dot is committed to being a responsible participant in the efforts of the Internet community to balance the need for data privacy with the need to provide access to records that allow the public to identify and contact domain name holders. To that end, Starting Dot will strive to maintain open access to registrant information to the extent compatible with applicable privacy laws. 

In the operation of the .immo gTLD, Starting Dot will offer a thick WHOIS service as set forth in Specification 4 of Registry Operator Agreement. Providing true, current, complete and accurate contact information will be a condition of domain name registration under the .immo gTLD. The use of proxy domain name registration will be prohibited. 

The data collected by registrars during domain name registration will be published in the .immo gTLD WHOIS database. This information will provide the public with the ability to get in touch with the domain name holder for any reason that requires actions to be taken. In this operation, Starting Dot will be compliant with applicable privacy laws. 

In addition, Starting Dot will require registrars to post privacy policies that provide clear and complete notice to registrants of the type of data that will be collected and maintained by Starting Dot, the use of such data in operating the registry service (including display through the WHOIS service), and the registrant’s right to access and correct data maintained by Starting Dot. Clear consent to such data practices will be a prerequisite to the submission of a domain name registration request. 

Starting Dot will take reasonable steps to protect personal data from loss, misuse, unauthorized disclosure, alteration or destruction. Starting Dot will prevent the abuse of data through the .immo domain name registration policies and by implementing technical restrictions set forth in our response to question 26 of this application. 

vi) Marketing and communications strategy to promote the .immo new gTLD 

Starting Dot’s goal is to introduce the .immo gTLD as a “must-have” for all real estate professionals who already have a presence or want a presence on the Internet. 

To achieve its goal, Starting Dot will build awareness of the .immo gTLD on a global basis and educate the community about the benefits of the .immo gTLD. 

Starting Dot intends to promote and implement the new .immo gTLD in all key markets through a dedicated marketing department, managed by a prominent TLD marketing figure. 

Starting Dot’s priority target for the marketing of its .immo gTLD are web-savvy business users, defined as business organizations having one (or more than one) domain name registration in an existing top-level domain. Inside its priority target, Starting Dot has identified three specific segments:
- Top 100 real estate industry players;
- Small and medium businesses unsatisfied with their current Internet domain name;
- Newly established companies or individuals facing the unavailability of the domain name corresponding to their name, brand or trade name in existing TLDs. 

Through its co-operative marketing plan, Starting Dot will encourage registrars to promote the gTLD in their local markets. 

Starting Dot intends to involve supporting real estate-related organizations in the promotion and marketing of the new .immo gTLD.

Finally, a massive awareness campaign via online media (e.g. display advertising, interactive and email marketing) and event marketing (e.g. exhibitions) will establish the credibility of the .immo gTLD in the marketplace. 

Regardless of the marketing or communication vehicle, the messaging will always be consistent: the .immo gTLD will deliver a safer user experience, promote healthy and free competition and offer businesses the ability to expand their reach and increase consumer trust.

i) Multiple applications resolution policies

The .immo gTLD Sunrise Period will be conducted in compliance with ICANN’s specifications. The proposed Sunrise Eligibility Requirements will conform to the following qualification derived from numerous past TLD Sunrise programs: applicants will have to prove ownership of a qualifying mark, as set forth in our response to question 29 of this application. 

Multiple applications for the same domain name, were they to occur, will be resolved by auction, however always bearing in mind that all candidate registrants must meet the eligibility criteria defined in the .immo registration policies. In any case, domain names in the .immo extension will only be awarded eligible applicants ⁄ registrants. 
The Sunrise period will be followed by a Landrush period during which applications may be submitted for any available .immo domain name. The Landrush period will be strictly reserved to: 
- Verifiable participants in the real estate industry; 
- Local governments that wish to register codes for the names of their subdivisions contained on the ISO 3166-2 list in English, French, German or Spanish (as set forth in our response to question 22 of this application), insofar and to the extent allowed by ICANN.

Multiple applications for the same name, if they to occur will be resolved by auction, except in the event of a contention between a verifiable participant in the real estate industry and a local government. In such case, the domain name will we awarded to the local government. 

During the General Availability period, verifiable participants in the real estate industry will have the opportunity to apply for a .immo domain name, on a first-come, first-served basis. 

Reserved domain names may be allocated by Starting Dot as the latter deems fit. 

ii) Cost strategy among registrants 

Domain name registration fees will be higher during the Sunrise and the Landrush period as registration will be open to fewer applicants. 

Reserved names will be subject to a different pricing policy. 

Starting Dot also reserves the right to set up promotional offers, limited in time and under predefined conditions. 

iii) Commitments to registrants regarding the magnitude of price escalation.

Starting Dot understands 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. 
We also understand that the Registry Agreement requires advance written notice of price increase. 

Starting Dot will adhere to these provisions. 

Domain name registration price under the .immo gTLD might increase in the event of: 
- Inflation in the Euro area; 
- Increase of fees charged by ICANN. 

Yes

The .immo gTLD will serve a community restricted to businesses, organizations, associations, and governmental and non-governmental organisations operating in the real estate industry, while targeting in particular German, French, Italian and Catalan speaking countries (e.g. an estimate of 41 states in the world).
In these languages “immo” is a well known as a short-form of words meaning “real estate”:
- “immo”, short form of “Immobilie” in German;
- “immo”, short form of “immobiler” in French;
- “immo”, short form of “immoble” in Catalan;
- “immo”, short form of “immobiliare” in Italian.
“Immo” is generally used to describe real estate services provided to households and businesses (e.g., sales, rental).
Real estate is made up of different business segments, concentrated in two principal markets:
a.The primary market, mostly dedicated to real estate construction services such as property development and home building, refurbishments, etc.;
b. The secondary market dedicated to existing properties:
- Realtors (rental or sale);
- Property traders (purchase and sale);
- Property managers.
Accordingly, the scope of activities covered by the .immo gTLD will include real estate segments:
- Commercial and Residential Real Estate Agents and Brokers;
- Rental Property Management Services;
- Real Estate Publishers (Information Media, Classified Media, Management Software);
- Service Providers for Real Estate Professionals;
- Real Estate Mortgage services (Loan, Insurance);
- Homebuilders;
- Real Estate Developers;
- Notaries.
The overall population within these sectors has been estimated to be in excess of 600,000 entities, representing an equivalent of .immo domain name eligible registrants. Starting Dot expects to achieve a market penetration of at least 3.5% after 3 years of operation of the proposed gTLD (which equals about 21,000 domain name registrations).
The real estate industry is well supported by national and sectorial organization. It is an industry that has defined itself for many decades. Real estate related activities and transactions first appeared in Europe during the 12th century, benefiting from construction booming in newly developed free cities in Great Britain, France, Germany, Italy and Switzerland.
The real estate industry and its segments have long been at the forefront of usage of information technology as reflected by the fact that 90% of real estate agents in Germany and in France have a website to promote their business.
90% of homebuyers use the Internet as a source of information during their home buying process. Accordingly, most successful realtors draw at least 50% of their clients from the Internet.
Given the continued growth of the Internet and the role it plays in the industry, it is in the real estates’ best interest to support the creation of an industry-specific space on the Internet.

The real estate (RE) community encompasses over 600,000 entities linked through and structured by national associations corresponding to each business segment. There is no international umbrella organization spanning the entire community. Starting Dot’s supporting associations are therefore all national organizations.
Some industry segments however are neither organized nor represented by national associations, notably:
- Real estate mortgage brokers or issuers;
- Real estate publishers (management software, information media).
Starting Dot has therefore mainly built relationships with segments of the real estate community, which are either structured by national and regional associations or organized by reliable and representative leaders.
Accordingly, Starting has received endorsements from associations representing following professions:
- Professional associations of real estate agents and property managers;
- Online Real Estate Marketplaces;
- Home developers;
- Universities;
- Software publishers.
Real estate brokers and property managers are represented by approximately 15 organizations, present in Austria, France, Belgium, Germany, Italy, Luxembourg and Switzerland. The overall population within these organizations has been estimated to be in excess of 60,000 corporations, representing an estimate of 250,000 professionals.
Seven (7) of these associations have endorsed the .immo gTLD application (as set forth in Appendix ‘App 20-1.pdf’ attached to this answer): Fédération Nationale de l’Immobilier (FNAIM), Union des Syndicats de l’Immobilier (UNIS), Union Suisse des Professionnels de l’Immobilier (USPI), Fédération Française de l’Internet Immobilier (FF2I), Bauträgerverband (BTV), Confédération Européenne de l’Immobilier (CEI), and Immobilienverband Deutschland (IVD).
Within this group, the FNAIM is the most important in terms of size (see appendix ‘App 20-1.pdf’). To become a member of the FNAIM one has to prove:
* Holding a professional card delivered by the Ministry of Home Affairs (this card is granted for 10 years to qualified candidates who either have a bachelor degree or have worked 4 to 10 years in a real estate company);
* Holding an insurance policy;
* Having registered ones business with the local Chamber of Commerce and having been granted a business registration number.
These requirements are common to all organizations endorsing the .immo gTLD application. The goal is to regroup professionals who are qualified by education, training, and⁄or experience, and thus are perfectly capable of performing professional property-related services.
The .immo gTLD has also received an endorsement from the CEI (European Confederation of Real Estate Agents), one of Europe’s largest professional organizations of RE agents, counting over 66,000 members from hundreds of cities in 14 European countries. CEI aims to establish international cooperation, to advise on issues concerning transnational real estate transactions and to influence European ruling. Accordingly, the CEI is fully representative of the RE industry in Europe, in terms size and geographical reach, and its also completely dedicated to improve standards of profession.
The German Real Estate Professional Association (IVD) has also endorsed the .immo gTLD application. The IVD was established in 2004 and is Germanyʹs largest organization of real estate agents, property managers and valuers as well as developers and facility managers. The IVD has more than 6,000 members, 80% of them are Real Estate Agents and Real Estate Managers and 20% of them are Real Estate Valuers.
The .immo gTLD application has the support of numerous online real estate marketplaces. Those Internet companies deliver a free service to the end-user but charge their clients for the display of ads and⁄or classified.
Starting Dot has received the official endorsement of SeLoger.com for the .immo gTLD application. SeLoger.com, leading operator of online portals dedicated property advertisements in France, was able, to establish long-term relations with 24,000 real estate businesses in France, which equals about 80% of the French real estate market. Founded in 1992, it has a portfolio of 2.5 million property advertisements, a reach of 3.1 million unique users per month and an annual income of over €100 million. It is today the 5th largest real estate portal in the world by revenue.
Other major real estate players in France, Italy, Germany, Austria and Switzerland have endorsed the .immo gTLD application (as documented in appendix ‘App 20-2’ here attached): LaVieImmo.com, Immonet.de, Piucase.it and Solocase.it (published by Terra Nova Editore), Homegate.ch and Immobilien.net.
ERESnet GmbH, publisher of Immobilien.net, Europe’s oldest and Austria’s number one real estate portal is also a co-investor in Starting Dot’s application for the .immo gTLD. Starting Dot and ERESnet have signed an agreement anticipating their joint ownership and management of the .immo gTLD following ICANN delegation, as documented in Appendix 48-4 ‘Bond Agreement between Starting Dot and ERESnet’.
The .immo gTLD application is also backed by other major groups of real estate professionals:
- Government Agencies, which play a major role in the development of new legislation governing the real estate industry. Starting Dot’s endorsement from the French Ministry for Ecology, Sustainable Development, Transports and Housing for its .immo gTLD application, is therefore of great value;
- Real estate operators: Even though the real estate market is fragmented, there are a few big integrated operators, like Nexity, ImmoFinanz and Tagerim, which all have endorsed the .immo application. These organizations play a major role in the real estate community as both, opinion leaders and trendsetters. Nexity Group is considered one of the three leading real estate companies in Europe.
- Universities: Preventing non-qualified persons from performing property-related functions, is very important. Many top Universities have therefore opened specific academic programs dedicated to property professions, notably the University of Applied Sciences Vienna (FH Wien) and the Vienna University of Technology (TU Vienna).
- CRM and Management software publishers: Property professionals rely on different software to manage their businesses. Accordingly a new generation of software publishers has emerged these last 10 years. Two of them, Wazzup (Netherlands) and Poliris (France) have endorsed the .immo gTLD application.
Mr. Godefroy Jordan, founder a,d CEO of Starting Dot is also strongly involved in the real estate community. For more than 10 years, he has either worked as a senior executive for or has been a shareholder of Europe’s top online real estate portals (e.g. Logic-Immo.com, Immostreet.fr, Realcity.cz, Logic-Immo.ch).
All organizations backing the .immo gTLD application share Starting Dot’s goals:
- Enforce real estate legislations on .immo domain name registrants;
- Improve quality of online services related to real estate;
- Protect online consumers and thereby improve consumer trust in property professionals.
These goals will be achieved through the .immo gTLD’s eligibility policies, which have been defined in collaboration with the real estate community.
The Policy Advisory Committee will lead representation and community input for the .immo gTLD. When fully constituted, the Policy Advisory Committee will be a 12-person committee made up of organizations that have endorsed the .immo gTLD application.
The real estate community will be strongly involved in the management of the .immo gTLD, as the Policy Advisory Committee will serve as a channel for the community to provide Starting Dot input in to how policies have been implemented, the experience of registrants with these policies, the effectiveness of procedures and opportunities to improve support and services.

Certain services related to the real estate industry, in particular brokerage activities, are in most countries subject to restrictive legislative regulations, especially in the European Union. These regulations aim to protect consumers, both on the supply as on the demand side, and organize and structure the real estate community.
A key aim and utility of the .immo gTLD will be to provide a domain name space compliant with any such real estate legislation.
That level of compliance can only be achieved through a community-based TLD application, as:
- The real estate community will be engaged in the TLD’s policy-making;
- The real estate community will be more inclined to respect policies adopted by its peers.
Through restrictive eligibility policies defined in cooperation with the real estate community, the .immo gTLD will provide a unique and safe online space to conduct business and to search for real estate related content.
Applicants for a .immo domain name registration will have to be verifiable participant in the real estate industry and each name applied for will have to be a name for which such participant holds a right that has been established through registration or use. Such rights can consist of, but are not necessarily limited to, registered or unregistered trademarks, trade names, company names, business identifiers, etc. insofar and to the extent protected by the laws of the country in which the applicant for the .immo domain name resides, has been established or conducts business activities.
Participation in the real estate industry (as defined in the .immo eligibility policies) will have to be certified at the time the registrant applies for or registers the domain name, which implies the acceptance of Starting Dot’s .immo domain name registration policies.
Accordingly, a community-based .immo gTLD will:
- Provide a secure and regulated TLD, dedicated to the real estate industry;
- Promote a sense of community identity within the real estate industry;
- Protect consumers from fraud and abuses.
Starting Dot is convinced that the .immo gTLD will change consumer habits and impose itself as a lasting business solution for real estate professionals.

The words “immobilier” (“real estate ”in French), “Immobilie” (“real estate” in German), “immobiliare” (“real estate” in Italian) and “immobile” (“real estate” in Catalan) have all the same Latin root, “immobilis”, which is the negative form of the Latin adjective “mobilis” meaning “which cannot be moved or removed”.
As is it a well-known short-form of words meaning real estate in several languages, “immo” has been included in names of most organizations that have endorsed the .immo gTLD application:
- Fédération Nationale de l’Immobilier (FNAIM);
- Union des Syndicats de l’Immobilier (UNIS);
- Union Suisse des Professionnels de l’Immobilier; (USPI);
- Fédération Française de l’Internet Immobilier (FF2I);
- Confédération Européenne de l’Immobilier (CEI);
- Immobilienverband Deutschland (IVD);
- ImmoFinanz;
- ImmoABS.
“Immo” is also commonly used in the real estate industry as part of a real estate professional’s brand or trade name.
Several major media groups or classified, for instance, have included “immo” in their brand or domain name:
- logic-immo.com (France);
- explorimmo.com (France);
- lavieimmo.com (France);
- immobiliare.it (Italy);
- immobilmente.com (Italy);
- immobilien.de (Germany);
- immoscout24.com (Germany);
- immonet.de (Germany);
- immowelt.de (Germany);
- immostreet.ch (Switzerland);
- immoweb.be (Belgium);
- immo.at (Austria);
- immodirekt.at (Austria);
- immobilien.net (Austria).
Likewise, major property developers have included “immo”, “im” or the corresponding word meaning real estate in their brand or domain name:
- Promogim (France);
- Tagerim (France);
- Bouygues-immobilier.com (France);
- Westimmo (Germany);
- IVG Immobilien (Germany);
- GSW Immobilien (Germany).
“Immo” is also recognized by consumers as a short-name meaning real estate. As an example, in March 2012, Google AdWords Keyword Tool has registered:
- 25m requests for the keyword “Immobilien”;
- 20m requests for the keyword “immobilier”;
- 17m requests for the abbreviation “immo”;
- 14m requests for the keyword “Immobilie”;
- 4m requests for the keyword “immobiliare”.
Even though “immo” has a meaning in 41 countries, only 8 of them have major real estate industries:
- Austria (European Union);
- Belgium (European Union);
- France (European Union);
- Germany (European Union);
- Italy (European Union);
- Luxemburg (European Union);
- Quebec (Canada);
- Switzerland.
According to a study conducted by the European Union (Eurostat, 2006), the real estate industry turnover has hit 290 billion in the above-mentioned EU member countries.
In 2006, the real estate industry in these 8 target countries was made up of 540,000 companies that employed 1.4 million people. These facts clearly demonstrate the economic importance of the real estate industry.
Given the extensive usage of the short-name “immo” by real estate professionals and the size and scale of the real estate industry, Starting Dot is convinced that:
- The .immo gTLD will gain general acceptance among real estate professionals;
- The .immo gTLD will have a large and steady registrant base of real estate professionals.

Starting Dot will manage the .immo gTLD for the benefit of the real estate community at large, but with a specific focus on Austria, Belgium, France, Germany, Italy, Luxembourg, Quebec and Switzerland, where the “immo” word is commonplace for members of the professional real estate community.
Benefits attainment of a restricted TLD will require equitable and substantive evaluation of domain name requests to weed-out non-eligible applicants while ensuring the availability of the TLD for its intended registrants.
Thanks to the expertise of its founding directors and to their relationships with major players of the real estate industry, Starting Dot is perfectly suited to endorse this responsibility.
Two main mechanisms will ensure stakeholders that the .immo gTLD will be managed in the community’s best interest:
- The establishment of a twelve-seat Policy Advisory Committee including members of the real estate community that have endorsed the .immo gTLD application. Following organizations have already announced their intention to participate in the Policy Advisory Committee: FNAIM, IVAD, UNIS, USPI, FF2I, CEI;
- Restrictive eligibility policies defined in collaboration with the community, highlights of which are provided below.
The Policy Advisory Committee will serve as a channel for the community to provide Starting Dot input in to how policies will have to be developed, have been implemented, the experience of registrants with these policies, the effectiveness of procedures (both technical and non technical) and opportunities to improve support and services.
For transparency’s sake, minutes of the committee’s bi-annual meetings will be posted on the .immo gTLD main website (www.dot-immo.com). To ensure representativeness, meeting venues will rotate among European countries. During the first year meetings will be held on a monthly basis.
Starting Dot intends also to encourage community input via its website.
Starting Dot will also enforce the community-based purpose of the .immo gTLD through following registration policies.
In the operation of its proposed restricted .immo gTLD, Starting Dot intends to implement all current and future ICANN policies.
Accordingly, Starting Dot will follow ICANN’s policies with respect to dispute resolution, including the adoption of the Uniform Dispute resolution Policy, as the same may be amended from time to time.
In addition, Starting Dot will design a specific dispute resolution procedure to address situations in which there is objectively clear abuse of:
- a company name;
- a personal name;
- a professional name;
- a name with national or geographic significance.
ELIGIBILITY
Applicants of a .immo domain name will have to be verifiable participants in the real estate industry and each name applied for will have to be a name to which there is a right that has been established through rights registration or use thereof. Such rights can consist of, but are not necessarily limited to, registered or unregistered trademarks, trade names, company names, business identifiers, etc. insofar and to the extent protected by the laws of the country in which the applicant for the .immo domain name resides, has been established or conducts business activities.
Participation in the real estate industry will have to be certified at the time the registrant applies for or register the domain name, which implies the acceptance of the domain name registration policies.
Real estate practice is not subject to one single law but to different national laws and in some countries to none. This is also the case in Europe. Admissions to the profession, local customs, and practices of real estate have not been yet harmonized. There is a project of a European Professional Card but it has not been adopted yet.
Accordingly, only the following property professions are eligible to apply for a .immo gTLD:
a. Commercial and Residential Real Estate Agents and Brokers compliant with industry-specific national laws, provided:
- Membership in one of the national associations of real estate professionals listed by the Policy Advisory Committee and attached to the .immo domain name registration policies; or
- Professional card.
b.Property Management Services compliant with industry-specific national laws, provided:
- Membership in one of the national associations of real estate professionals listed by the Policy Advisory Committee and attached to the .immo domain name registration policies; or
- Professional card.
c. Homebuilders and Real Estate Developers, provided:
- Membership in one of the national associations of real estate professionals listed by the Policy Advisory Committee and attached to the .immo domain name registration policies; or
- Having a subsidiary company that is either a real estate agency or a real estate broker).
d. Notaries, provided:
- Entitled to practice in the field of real estate under their national law.
e. Real Estate Publishers (Information Media, Classified Media, Management Software), provided:
- At least 80% of their clients or advertisers belong to one of the above mentioned categories (a, b, c and d);
f. Real Estate Mortgage services (Loan, Insurance), provided:
- These are banks or Insurance offering Housing Loans and Housing Insurances.
Starting Dot, in consultation with the Policy Advisory Committee may, at any time, extend this list to another real estate business segment.
Starting Dot believes that these eligibility requirements will be a key impediment for registrants who are seeking to engage in abusive registrations and cyber-squatting.
Starting Dot has also defined a list of reserved and prohibited domain names under the .immo gTLD. Reserved names are domain names reserved for special use or for special organizations. Prohibited names are names that may not be registered under the .immo gTLD.
RESERVED NAMES
Unless agreed upon otherwise in writing with ICANN, Starting Dot will comply with the restrictions on registration of character strings set forth at Specification 5 of the Registry Operator Agreement.
Starting Dot also intends to define and control a list of domain names that have a value for the entire real estate community, in order to delegate them to those registrants who are committing to use these in order to support the community for which the .immo gTLD is initially intended.
Hence, one character labels and a list of generic names will be reserved by Starting Dot and only released at its sole discretion.
PROHIBITED NAMES
The list of prohibited names under the .immo gTLD includes, in particular:
- Abusive terms;
- Racist terms;
- Obscene terms;
- Terms relating to crime or offenses.
THIRD-LEVEL NAMES
Starting Dot does not intend to allow third-level name registrations under the .immo gTLD.
ILLEGAL USE AND COMPLIANCE
Use of a domain name that is barred or prohibited by law or legal proceeding in any jurisdiction, or is considered to be defamatory will permit Starting Dot to revoke the domain name. Policies to this end will be developed by the registry and published in due time following ICANN’s delegation of the .immo gTLD to Starting Dot.
ENFORCEMENT
- The .immo domain name registration policies will contain the following enforcement procedures and processes, in addition to those procedures that have been established in accordance with Consensus Policies such as the Uniform Dispute Resolution Policy:
- Verification of entitlement of the registrant at the time of registration of a domain name, and this on a sample basis; and
- Ongoing verification throughout the term of the domain name registration.
In principle, each new .immo domain name registrant will be verified within 3 month following registration. Starting Dot will verify whether a registrant meets the eligibility requirements and⁄or domain name restrictions on the basis of public information, such as the information displayed on the registrant’s website, as well as other sources (Internet, public registries). When in doubt, the Registry Operator will put the domain name on hold, and contact the registrant and the registrar with the request to provide proof that the registrant is meeting such requirements within a reasonable timeframe (e.g. copy of professional card).
Furthermore, Starting Dot’s Complaints Point of Contact will handle any complaints in relation to a .immo domain name registration, including where the complainant alleges that a particular registrant does not meet the eligibility requirements or domain name restrictions.
If, following the investigation of a complaint or an ex officio review of the registrant’s compliance with the Registry Operator’s policies, no or insufficient proof is provided by the registrant that all policy requirements have been complied with, Starting Dot shall be entitled to put the domain name on hold or even revoke the domain name. Furthermore, Starting Dot may inform the public that the domain name has been previously used contrary to its registration policies.

Not Available

No

As requested by ICANN and the Governmental Advisory Committee (GAC), Starting Dot will reserve, within its proposed .immo gTLD, names formed with the following labels from initial registration: 

a. Two-character labels. All two characters labels will be initially reserved. The reservation of a two-character label string may be released if Starting Dot reached an agreement with the relevant government or country code manager. Starting Dot may also propose release of these reservations if measures have been implemented to avoid confusion with corresponding country codes. 

b. Country and Territory Names. The country and territory names contained in the following internationally recognized lists: 

i) 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; 
ii) 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 
iii) The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names. 

Starting Dot may only release these reservations if it has reached an agreement with the corresponding government or if the release proposal has been subjected to GAC’s review and has received ICANN’s approval. 

Given the fact that with the .immo gTLD, Starting Dot is reaching out to the international architectural scene, it has a vested interest in giving its registrants and Internet users a clear and predictable naming scheme in the .immo gTLD. Since various stakeholders may be looking for certain architectural achievements on the basis of their geographic location or destination, Starting Dot will control registration of domain names that contain geographic names other than the ones listed in Specification 5 of Registry Operator Agreement:

i) Codes for the names of the principal subdivisions (e.g. provinces or states) of all countries coded in ISO 3166-1 contained on the ISO 3166-2 list, in English, French, German and Spanish, will also be reserved from initial registration within the .immo gTLD. Local governments will be given the opportunity to register these subdivision names during the Landrush period. In case a local government falls into the eligibility criteria defined in the .immo domain registration policies, it will be allowed to actually use the domain name, otherwise the domain name will only be blocked. Starting Dot will inform corresponding local governments of this opportunity, via email, 3 month prior to the launch of the Landrush period. If a local government fails to register its subdivision names, Starting Dot will release these names for registration under the .immo gTLD.

ii) Starting Dot will also design a specific dispute resolution procedure to address situations in which there is objectively clear abuse of names with national or geographic significance at the second level of the new .immo gTLD. 
In any case the registration, delegation and use of domain names corresponding to geographic names will at all times be done in the best interest of the country, region or city, including their respective interests concerning tourism, architecture and art, and in order to directly and indirectly promote their activities, products and services in the geographic locations of which the name has been registered. 

Question 23: Registry Services

KSregistry has been chosen as technical backend for registry operations because of the companyʹs extensive knowledge of the domain industry and technical infrastructure. The parent company of KSregistry, Key-Systems GmbH, has extensive knowledge in the area of handling gTLDs (as of today all gTLDs are already supported) as well as more than 200 different ccTLDs (including com.br, de, jp, be, co.uk, us, etc.). This experience also covers IDN relevant topics as well as DNSSEC and industry best practice elements. Having participated in the early days of the IDN testbed of Verisign, which included the transition to the punycode standard in 2004, KSregistrysʹ parent company gained insight into transitioning processes and all aspects of IDNs. The KSregistry shared registry system (“SRS”) is based on the MetaRegistry platform, which is in use as the domain management platform of Key-Systems. The scalability of the system has been proven in 2007 by handling the transition of the former Namestore ccTLD system for countrycodes (other than CC and TV) from VeriSign to Key-Systems, as well as the growth of the customer base of Key-Systems. With more than 1,800 reseller-registrars and over 3 million domain names under management, the systemsʹ scalability is proven with the number of domains under management and the number of simultaneous connections from different reseller-registrars. With more than 5 years of experience in running and maintaining an EPP server KSregistry can guarantee the compliance and stability required to run a gTLD EPP service in accordance with the ICANN specifications. The KSregistry staff has repeatedly assisted gTLD and ccTLD operators in improving their systems.

These technical and operational specifications for the Registry TLD consist of the following parts:

The EPP-based KSregistry (KSR) platform provides a stable, DNSSEC and IPv6-enabled SRS that is scalable, state-of-the-art, and secure. 

All registry services will be provided by the KSregistry in a responsible manner adhering to all ICANN requirements for TLD operations. KSregistry has already been chosen as the new technical registry service provider by the operators of the following ccTLDs : dotDM, dotTC, dotVG and dotGD. 

The goal is to operate an ICANN compliant technical registry platform meeting industry best practice standards to allow registrations under the applied for new top level domain.

All registry services described in our responses to questions 23-44 are managed in a contract based on a fixed yearly fee plus a per domain name fee per year as detailed in our response to Q46 and to Q50a and appendix ‘App 50-1.pdf’.

Thus KSregistry has been mandated to manage all technical tasks related to operating our TLD, and will further support us with their legal resources, as described inter alia in our responses to question 27,31,35,39,43,44 as well as 28 and 29.

Hence, the responses to question 23-44 have been developed together with KSregistry.

All ICANN accredited registrars that meet the registry operators established eligibility criteria must use EPP (see section A below) to interact with the registry and manage their sponsored domain names. 

All fundamental registry services will be subject to the SLAs as defined in question 24. All services are continuously monitored for compliance with the SLAs and to discover increased system load and performance issues prior to affecting the experience of the registrars or end-usersʹ of the .immo gTLD.

The registry will implement several blacklists to ensure compliance with ICANN guidelines, including but not limited to Specification 5 of the New gTLD agreement specifications.

All domain name availability checks and registrations will be checked against the implemented blacklists and eligible registration guidelines to ensure standard compliance and policy guidelines (such as hyphens in third and fourth place are only allowed for valid IDN registrations ʺxn--ʺ).

Two character labels, country and territory names as stated in ISO 3166-1 and all successors thereto, will be blocked and only released if a written confirmation of such a release is granted by the applicable governments. Detailed descriptions on the handling of reserved domain names can be found in answer to question 22.

None of the registry services are offered in a manner that is unique to the .immo gTLD. They are offered as standard registry services as is the case for established gTLDs today, and no new services are defined for the .immo gTLD.

KSregistry will support the .immo gTLD in accordance with the policies established by ICANN and the applicant leveraging a fully operational registry infrastructure supported by experienced professional staff and fully provisioned to immediately launch this and a number of other gTLDs to meet or exceed the Service Levels required in the ICANN contract.

Standard Policies and Dispute Resolution

Domain name registration in the zone are subject to the Uniform Dispute Resolution Policy (UDRP), PDP, URS and all successors thereto.

Inter-registrar transfers are subject to the ICANN transfer policy as described in

http:⁄⁄www.icann.org⁄en⁄transfers⁄policy-en.htm and the transfer dispute policy as described in http:⁄⁄www.icann.org⁄en⁄transfers⁄dispute-policy-12jul04.htm.

The registry operator is committed to using best practice standards as described by industry members and ICANN. 

Data Escrow Service

To ensure compliance with the Data Escrow requirements the registry will be using Group NCC to act as the third party data escrow agent (see answer 38 for details). All data uploaded to the escrow agent will follow the specifications published at http:⁄⁄tools.ietf.org⁄html⁄draft-arias-noguchi-registry-data-escrow-02 or any successor RFC.

The purpose of the third party data escrow service is to allow a registry data transition in the case that the registry provider fails to fulfill its SLA or is incapable of continuing the registry operations in a manner defined by ICANN.

Reports will be generated on a regular basis to be used for reportings to ICANN.


A. Receipt of Data from Registrars

A.1 Extensible Provisioning Protocol (EPP)

For the purpose of data exchange with the registrar, EPP is used in combination with an SSL encryption on a dedicated port. The registry will issue an SSL certificate for usage by the registrars.

Our EPP specifications follow the existing RFCs and will comply with all relevant successor standards. RFCs considered for the EPP protocol are: RFC 3735, 5730 – 5734, 5910 and 3915.

The following commands will be available for registry operation:

- CreateDomain, CreateContact, CreateHost
- ModifyDomain, ModifyContact, ModifyHost
- InfoDomain, InfoContact, InfoHost
- DeleteDomain, DeleteContact, DeleteHost
- CheckDomain, CheckContact, CheckHost
- TransferDomain
- RenewDomain

Check commands will be available for accredited registrars to check availability of contact handles, host objects, and domain names.

CreateContact will be used to create contact handles used for subsequent domain registrations and modifications. 

CreateHost will be used to create host objects serving as nameservers.

CreateDomain will enable all ICANN accredited registrars to create a domain name under the .immo gTLD of this application.

Several ʺInfoʺ commands will be available to provision status information on domains, contacts and host objects to the accredited registrars.

See attached fig. Q23_Figure1.pdf.

Detailed EPP descriptions can be found in the answers to the questions 25, which are incorporated here by reference.

A.2 Production and Operational Testing and Evaluation (OT&E) EPP Servers

There will be two EPP servers to interact with the registry. One will be for production purposes and the other for testing and evaluation (referred to as the OT&E server) of new software versions and EPP client implementations. The production server consists of at least two load balanced servers (n+1). Each new stable production release will be released on the OT&E EPP server at least 30 days in advance. To increase security, a registrar IP address limitation is in place for the EPP servers (both production and OT&E).

A limitation on the allowable commands per time interval will prevent the registrar from affecting other clients in the SRS environment in regard to performance issues and increased system load.

Each registrar in the SRS environment will be entitled to up to five sessions from two different IP addresses. The registrar will be forced to update the registry password for the EPP servers and registrar extranet (see below) at least once every six months.

A.3 Registrar Extranet and SFTP Area

In addition to the EPP system the registrar can chose to interact with the registry through the registry specific registrar extranet and SFTP area. Access to the SFTP area will be secured by protocol specific encryption mechanisms. Aside from the EPP registrar-registry interaction, the registry extranet is mainly used to adjust registrar specific settings such as accounting, default values for RDDS (WHOIS), and reporting. Different tiers of access are granted to the registrars for this purpose. Access can be limited on a per user and group basis to either read only or write operations for the following objects: domains, hosts, contacts, user and group rights, accounting lists and current account statement.

The registrar extranet will enable registrars to update their IP address range and passwords for the EPP production, OT&E and SFTP areas. When changes are made to the IP address range a support agent will contact the registrar to verify the changes prior to the implementation. The registry will provide marketing material and⁄or detailed reports to all registrars on a regular basis via the registrar specific SFTP area.

Documents will be generated on a regular basis for all registrars and can be found in the SFTP area. These include transaction reports, monthly billing details, and detailed lists on domain names with a status of PendingDelete, domain names under registrarsʹ management, and contacts used.

Access to the registry extranet and SFTP area is also limited to a set of IP addresses as defined by the registrar during the accreditation process.

A.4 Support Case Handling

Each support case received by the KSregistry system either by email (ticket system) or phone will be subject to a passphrase authentication scheme. The passphrases are given during the registrar accreditation process and will be used to identify authorized persons belonging to the registrar. This will thwart any social hacking attempts by unauthorized users.

Support will be handled through 3 different locations:

- USA, VA, Leesburg: 8 am – 5 pm EST ⁄ UTC⁄GMT -5 hours
- Germany, St. Ingbert: 7 am – 6 pm UTC⁄GMT
- Mexico, Monterey: UTC⁄GMT -6 hours

Supported languages are: English, German, Spanish, French, Polish and Mandarin Chinese. 

Registrar technical support will be available through a dedicated technical support team 24 x 7 x 365. The support team is committed to delivering support by utilizing best practices and industry standards.

A.5 Provisioning of Zone Status Information to Registrars 

Registrars can query the status of a domain name with the “InfoDomain” command or through RDDS. In order to query status information on an existing host-object the command “InfoHost” is used.

The registry operator will inform registrars by email in the cases of unplanned (emergency) or scheduled maintenance. 

Information on planned system maintenance will be sent to all accredited registrars at least 30 days prior to the deployment in the OT&E and production system. Registrars will also be informed in the event that system performance drops below normal operational standards and in the event of unforeseen system outages. 


B. Dissemination of TLD Zone Files

Nameserver operations for the .immo gTLD will comply with RFCs 1034, 1035, and 2182 and all future successors and updates thereto. Additional details on the dissemination of TLD Zone Files can be found in answers to question 35 of this application, which are incorporated here by reference.
Distribution of zone files among all secondary nodes will be handled by a dedicated hidden master.

Updates to the primary master node will be performed every 15 minutes and distributed to a secondary master node (operated by PCH.NET, an external service provider specialized in providing anycast DNS services). For additional stability, the two hidden primary servers (master nodes) will be used in two different geographic locations. All other anycast and unicast nodes will query the secondary master node for zone file updates and update their records accordingly. Several checks will ensure the integrity of the distributed zone file before it is uploaded to the master node. Zone transfers will use the AXFR⁄IXFR zone file transfer method after successful verification of the newly generated zone. The distribution of new zone files will be continuously checked with each of the client nodes.


C. Dissemination of Contact or Other Information Concerning Domain Name Registration

A port 43 RDDS (WHOIS) server (RFC 3912) will be available for legitimate WHOIS lookups. The service will be load balanced on a cluster system updated in near real time. Query limitations on a per IP and subnet basis will apply to prevent system abuse. IP addresses stated in the ICANN RADAR section will be entitled to an increased query limit to facilitate inter-registrar transfers. A website WHOIS will be available on the registryʹs website to facilitate legitimate WHOIS queries using a normal browser. All services will be provided in full compliance with the ICANN requirements and applicable law. Additional details will be described as part of the answer to question 26 (RDDS) and question 44 (IDN).

In order to prevent system abuse of the website whois, a Completely Automated Public Turing test to tell Computers and Humans Apart (CAPTCHA) will be used. Each IP address will be entitled to up to six lookups per minute and up to 360 lookups per hour. Each subnet will be entitled to 12 lookups per minute and up to 720 lookups per hour.

IP Addresses listed in the ICANN RADAR section will be entitled to 20 lookups per minute and up to 1200 lookups per hour. For clients using Ipv6, appropriate limitations will be in place to prevent data mining and abusive WHOIS queries.

Information used for WHOIS lookups will be distributed to the WHOIS server cluster using default SQL replication mechanisms. A dedicated read-only database (load balanced) will be used to store all relevant data at the location of the WHOIS server. To prevent any unauthorized access to the database all external communications to the database are blocked.
The WHOIS output will contain information such as domain names and contacts associated with the domain name registration, dates such as registration date and expiration date, status of a domain name, and host objects.

Example Request: Query for domain “example.string” (please refer to Q26 section 8 for additional information concerning the WHOIS output)
Example Response:
Domain Name: EXAMPLE.STRING
Domain ID: 213232132-TLD
WHOIS Server: WHOIS.example.string
Referral URL: http:⁄⁄www.example.string
Updated Date: 2011-07-22T01:44:02Z
Creation Date: 2011-06-01T23:45:33Z
Registry Expiry Date: 2012-06-01T23:59:59Z
Sponsoring Registrar: EXAMPLE REGISTRAR
Sponsoring Registrar IANA ID: 1234567890
Domain Status: clientTransferProhibited
Registrant ID: 123456-STR
Registrant Name: EXAMPLE REGISTRANT
Registrant Organization: EXAMPLE ORGANIZATION
Registrant Street: 123 EXAMPLE STREET
Registrant City: SOMEWHERE
Registrant State⁄Province: AP
Registrant Postal Code: 12345
Registrant Country: EX
Registrant Phone: +1.5555522222
Registrant Fax: +1.55555544444
Registrant Email: EMAIL@EXAMPLE.STRING
Admin ID: 392839283-STR
Admin Name: EXAMPLE REGISTRANT ADMINISTRATIVE
Admin Organization: EXAMPLE REGISTRANT ORGANIZATION
Admin Street: 123 EXAMPLE STREET
Admin City: SOMEWHERE
Admin State⁄Province: AP
Admin Postal Code: 12345
Admin Country: EX
Admin Phone: +1.5555551212
Admin Phone Ext: 1234
Admin Fax: +1.5555551213
Admin Fax Ext:
Admin Email: EMAIL@EXAMPLE.STRING
Tech ID: 392811183-STR
Tech Name: EXAMPLE REGISTRAR TECHNICAL
Tech Organization: EXAMPLE REGISTRAR LLC
Tech Street: 123 EXAMPLE STREET
Tech City: SOMEWHERE
Tech State⁄Province: AP
Tech Postal Code: 12345
Tech Country: EX
Tech Phone: +1.1235551234
Tech Phone Ext: 1234
Tech Fax: +1.5555551213
Tech Fax Ext: 93
Tech Email: EMAIL@EXAMPLE.STRING
Billing ID: 112811183-STR
Billing Name: EXAMPLE REGISTRAR BILLING
Billing Organization: EXAMPLE REGISTRAR LLC
Billing Street: 123 EXAMPLE STREET
Billing City: SOMEWHERE
Billing State⁄Province: AP
Billing Postal Code: 12345
Billing Country: EX
Billing Phone: +1.1235551234
Billing Phone Ext: 1234
Billing Fax: +1.5555551213
Billing Fax Ext: 93
Billing Email: EMAIL@EXAMPLE.STRING
Name Server: NS01.EXAMPLEREGISTRAR.STRING
Name Server: NS02.EXAMPLEREGISTRAR.STRING
DNSSEC: signedDelegation
DNSSEC: unsigned0


D. Internationalized Domain Names (IDNs)

The applicant will offer IDNs and is in compliance with with RFCs 5890, 5891, 5892, 5893 and their successors and the ICANN IDN Guidelines at 〈http:⁄⁄www.icann.org⁄en⁄topics⁄idn⁄implementation-guidelines.htm〉, as they may be amended, modified, or superseded from time to time. The registry will publish and keep updated its IDN tables and IDN registration rules in the IANA repository of IDN practices as specified in the ICANN IDN guidelines.
Full detailed description of IDN handling can be found in answers to question 44, which are incorporated here by reference.

The following languages will be supported for the .immo gTLD:

- German

See respective language table “Q44_Figure6.pdf” - attached to the answer of question 44.


E. DNS Security Extensions (DNSSEC)

DNS Servers will provide DNSSEC capability according to RFCs 5910, 4641, 4034 and all successors and updates thereto. EPP DNSSEC specifications will be implemented according to RFC 4310. Zones will be signed on the signing server and distributed to the hidden master nameservers which will then distribute them to the secondary servers. A full detailed description of DNS and DNSSEC related topics can be found in answers to question 43, which are incorporated here by reference.


F. Additional Proposed Registry Services

Clients with a legitimate interest in accessing the registry zone file will be entitled to access this file once a day. For this purpose a dedicated SFTP access will be granted and the zone file will be uploaded once a day. This service will be subject to an additional agreement fully executed between the interested party and the registry.


G. List of Attachments

- Q23_Figure1.pdf - List of supported EPP commands ⁄ EPP object relationship

Question 24: Shared Registration System (SRS) Performance

The KSregistry (KSR) system is a domain registry system capable of registering domain names managed by multiple registrars. In addition to the SRS system, KSR provides RFC conforming interfaces for EPP, RDDS (WHOIS), DNS, and DNSSEC. KSR is capable of running any IDN string as well as IPv6. KSR uses recognized and proven technologies such as MySQL database software and BIND DNS servers, as well as industry standard backup and monitoring solutions.

KSR uses a thick registry model wherein all contact details are stored in a central location by the registry. All services are set up as a fully redundant solution (n+1). Additionally, there are two geographically separate data centers (Tier 3, all components are available at least n+1), one active and one which is designed to function as a warm-standby solution to ensure a maximum of data security and business continuity. All SRS and DNS related information is replicated in real-time between the data centers. 

KSRʹs modular design allows for quick and easy installation or removal of system components at any time. This ensures KSRʹs ability to react to any business needs or system loads in an appropriate manner at all times. 

KSR is managed by trained personnel only. Its operations follow well-defined business and security processes which are based on the ITILv3 standard and in accordance with ISO 27001. 

KSR has a NOC and support team available at two different locations (St. Ingbert, Germany and Munich, Germany) which allows 24 x 7 x 365 monitoring of all systems and provides customers with an easy way to reach KSR personnel regarding any issue they may have. 

The SRS is protected against unauthorized access. Data integrity is ensured by both physical and software security and protection mechanisms.
All these measures together are the basis for running a robust and reliable SRS and are in compliance with Specification 6 and 10.


A. Detailed KSR Description

The following section refers to attachment Q24_Figure1.pdf.

Figure 1 contains a high level functional overview of all KSR components which are described below. All described services and functions are in compliance with Specification 6 and 10 based on their design and setup.

For all of the services listed below the following applies:

The application servers (e.g. EPP, DNS, and RDDS) are set up as a cluster to guarantee a high-availability solution. The sizing of the servers and the databases are calculated to meet the needs of each business case. Additionally, the system is set up to be scalable so that an increase of domains or registrars can be easily handled by installing additional hardware as needed. 


A.1 Services Integrated into KSR

Domain Name System (DNS)

The Domain Name System (DNS) is a hierarchical distributed naming system for computers, services, and any other resource connected to the Internet or a private network. The registry will be set up with a mix of anycast and unicast name servers. This service is provided by an external provider called PCH.NET which has over 10 years of experience in this area. This partnership with PCH.NET ensures a 100% guaranteed uptime of the service and worldwide DNS coverage. DNS and zone file creation is performed periodically (every 15 minutes), uploaded to the primary hidden master name server, and spread to the anycast clouds (PCH.NET) within 180 seconds. The communication between the primary hidden master name server and the DNS cloud is facilitated by zone transfer {AXFR (Asynchronous Full Transfer Zone)⁄IXFR (Incremental Zone Transfer)} to the worldwide anycast net.

DNS Security Extensions (DNSSEC)

DNSSEC adds security to the Domain Name System. DNSSEC helps in preventing cache poisoning or man in the middle attacks. This helps to protect usersʹ personal and⁄or financial information from being compromised on the Internet. This additional security helps in protecting end users and the reputation of brands.

Extensible Provisioning Protocol (EPP) 

The EPP gives registrars the ability to fully automate the management of their domain names. KSR uses EPP as a protocol for registering and managing domain names in a very standardized way. KSR is in compliance with RFCs 3735 and 5730-5734 as well as with Specifications 6 and 10 of the registry agreement. EPP compliance is ensured by technical validation (XML validator) and through the change management process which includes a quality assurance program.

Web Interface

The web interface provides the registrars the ability to manage their domain names through a comfortable user interface and grants access to reports and accounting information.

RDDS (WHOIS)

The Whois is a data directory service which grants public free access regarding domain information. The RDDS (WHOIS) service is provided as a web-based directory service via port 43 in accordance with RFC 3912. This service provides different information depending on the request. The data this will offer includes, but is not limited to:

- Domain name
- Address information on the registrant, administration-, technical-, and billing contacts.
- IP addresses of the name servers
- The identity of the registrar
- Domain creation and expiration dates

There will be a searchable Whois accessible via the web interface. This service will only be available to registrars in respect to confidential data. In order to prevent any abuse of the provided data, additional limitations on the service include IP-based limitations and masking of critical customer data.

SFTP ⁄ SCP Access to the File Store 

The SFTP area grants access to all reports which are available in the KSR. Communication is only possible over an encrypted connection, such as with SFTP or SSH, protecting registrars from unauthorized access to their data. In addition to command line access, KSR offers access through the https-based web interface.

Escrow

KSR generates two types of deposits: full and differential. The escrow data provides all SRS-related information to an escrow agent as required for running a registry in compliance with the approved registry services.

The escrow file is generated in compliance with the format specifications as described in Specification 2. The file will be transferred (SFTP) to the escrow agent as a compressed (ZIP RFC 4880) and encrypted file.

KSR is working with the escrow agent NCC Group.

The required data for generating the deposits are always stored in both data centers at all times. This enables the KSR to generate these files even in disaster scenarios.

Reports

The KSR system generates all ICANN reports on a monthly, weekly, or daily basis. In addition to the ICANN related reports, reports for the registrars are created which contain invoicing and domain portfolio information:

- Per-registrar transactions report (Specification 3)
- Registry functions activity report (Specification 3)
- Up-to-date registration data (escrow format as described in Specification 2)
- Thick registration data in case of a registrar failure, de-accreditation, court order, etc. (escrow format as described in Specification 2)
- Technical and operational reports describing performance specifications (Specification 10)
- Registrar based domain and contact reports
- Monthly invoicing reports
- Name server reports
- Data escrow (full and differential as required in Specification 2)


Internationalized Domain Name (IDN)

An IDN is an internet domain name that contains at least one label that is displayed in software applications, in whole or in part, in a language-specific script or alphabet. 

KSR has fully integrated IDNs in the SRS and related DNS, DNSSEC, RDDS (WHOIS), and EPP services. The domain registration must be submitted in PUNY code (ascii-encoding) with the appropriate language tag. There is no different handling or billing between the IDN and ASCII domains. 


B. Network Diagram

See attached fig. 2 in Q32_Figure1.pdf for the detailed network overview.

B.1 Hardware (Number of Servers)

Network Components:

- Two (2) or more firewalls (Vyatta) (load balanced) Vyatta 6.3
- Two (2) or more network switches frontend (Juniper), EX2200, EX4200
- Two (2) or more network switches transfer (Juniper), EX2200, EX4200
- Two (2) or more network switches backnet (Juniper), EX2200, EX4200
- Two (2) or more load balancer (Keepalived) and SUSE Linux Enterprise High Availability Extension

B.2 Server Components

Typical components for all servers:

Server: IBM compatible Linux server
Processor: INTEL 64bit multicore CPU
Memory: Up to 64 GB ECC DDR2 RAM modules
Disk: Internal RAID 5 for operating system and software, additional intern RAID 5 for data, iSCSI support 
Network Adapter: Average 4 100⁄1000 mbit network interface

- Two (2) or more webservers for the web interface (load balanced)
- Two (2) or more EPP server (load balanced)
- Two (2) or more RDDS (WHOIS) servers (load balanced)
- Two (2) or more SFTP servers (load balanced)
- Two (2) or more tools servers (cron, batch) (n+1 redundant with failover)
- Two (2) or more database servers (load balanced)
- Two (2) or more storage servers (load balanced)
- One (1) BIND hidden master
- One (1) Generator
- One (1) Signer ⁄ HSM

Full detailed hardware description can be found in attached fig. Q32_Figure3.pdf.

The listed hardware satisfies the SLA requirements as described in Specification 10.


C. Description of Inter-Connectivity with Other Registry Systems

The modular design of the KSR solution has the advantage of being very flexible and highly scalable. The SRS, EPP, and RDDS (WHOIS) services communicate through an internal API which protects the system from direct database access while providing real-time information to all SRS related services. 

The DNS and DNSSEC information is provided every 15 minutes to the primary hidden master name server and then spread to the anycast⁄unicast cloud within 180 seconds. The communication between the primary hidden master name server and the DNS cloud is facilitated by AXFR⁄IXFR.

The escrow data (full and differential deposit) is generated, zipped, and encrypted once a day and sent to the escrow agent in compliance with Specification 2.

The complete SRS database information is shared between both data centers (primary site, warm-standby). This is achieved by real-time data synchronization. In addition, the SRS program code and binaries are also shared between both data centers at any given time. Only one of the two data centers is actually running in production mode at a time, while the other one is always on standby but not active until needed.

The two data centers are connected through a VPN connection which is used for synchronization of the services described above. In the unlikely event of the complete loss of one data center, the KSR can be switched from one site to another within minutes and with no data loss. The DNS⁄DNSSEC is secure and highly available due to its worldwide setup.

The systemʹs complete inter-connectivity is integrated into the system monitoring and ensures the readiness of the failover locations at any time. In addition to monitoring, a controlled failover testing from the production data center to the warm-standby data center is performed once a year.

These measures ensure compliance with registry continuity in Specification 6.


D. Frequency of Synchronization Between Servers

The frequency of the server synchronization depends on the service being synchronized. Some services are synchronized in real-time while others are synchronized at fixed periods.

The database is set up as a cluster solution (with n+1 redundancy) in each data center. Since only one data center is running in production mode at a time, the other data center is connected to the production database by real-time replication. This guarantees a complete set of SRS⁄DNS information at all sites.

As the DNS⁄DNSSEC is generated from the database information, KSR always has the complete zone file information available at all data center sites. The zone file itself is generated every four minutes and uploaded to the primary hidden master name server. From there, the zone file is distributed to 95% of all DNS servers worldwide within 180 seconds.

The RDDS (WHOIS) is retrieved from the database in real-time and is available at both data center locations at all times. 

Like RDDS, the EPP interface retrieves and submits its information in real-time and is also connected to the database.

In addition to storing the complete registry-related data in the database, KSR also distributes the complete SRS source and binary codes to both data center locations at all times. This is achieved by a central repository which is synchronized at every location.

The combination of synchronization of source and binaries of each SRS-related service and the centralized database allows the KSR solution to switch from one data center to the other within 30 minutes. During a failover, the DNS service remains unaffected by the switch.

The data escrow files are generated in accordance with the registry Specification 2.

- Full Deposit: Each Sunday by 23:59 UTC
- Differential Deposit: Monday through Saturday by 23:59 UTC

These measures ensure the compliance with registry continuity in Specification 6.


E. Synchronization Scheme (warm-standby)

The setup of the system includes two geographically separate data centers configured as a warm-standby system (one active, the other in warm-standby, see fig. 1 in attachment Q24_Figure1.pdf). If the production data center is hit by a disaster which results in the complete loss of the data center, the warm-standby system can be brought online within minutes to completely take over.

The complete SRS data (domains, contacts, DNS, etc.) is always available at both data centers at any given time, safeguarding the SRS data from being lost. This is achieved by the setup of the SRS databases as clusters and distributed over both data centers. The cluster is synchronized in real-time.

Using PCH.NET as a partner for DNS⁄DNSSEC, KSR always has ten different locations available worldwide.

These measurements ensure the compliance with Specification 6.


F. Project Resources and Roles

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain industry. This deep industry knowledge and experience has been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR), and is evident in many trusted persons serving in different roles throughout the company.

All employees, contractors, and consultants that have access to or control of the KSregistry system are trusted persons.

Each role is staffed with multiple human resources for backup and capacity purposes.

Prior to commencement of employment in a trusted role, KSregistry GmbH performs the following background checks on a prospective candidate:

- Criminal records bureau check
- Verification of previous employment
- Check of professional references

F.1 Role Descriptions

All of the following roles have a backup available in each separate location in Germany (St. Ingbert and Munich).

Security Role

The Chief Security Officer (CSO) is dedicated to the security role. The CSO is the person responsible for the security of a companyʹs communications and other business systems. The CSO is involved in both the business (including people) and technical aspects of security. CSO responsibilities include training of personnel regarding security awareness, developing secure business and communication practices, purchasing security products, and ensuring that security practices are followed. The CSO has a stand-in backup available.

Designated Engineering Role

The designated engineering role includes the software developers of the entire SRS and all related interfaces such as EPP, RDDS (WHOIS), escrow, etc. All engineers are also integrated into 3rd level support of the SRS and related interfaces. 

System Administration Role

The system administrators take care of the infrastructure of the SRS system. This includes the entire network, hardware and system installations as well as the cluster setup of the databases and all data backups which are made. 

The NOC team is composed of system administrators. This team is responsible for clean, well-documented, and reliable data center operations. All access to the data center is restricted to members of the NOC team and persons accompanied by members of the NOC team only. There is an emergency team of at least two people at all times. This team is reachable 24 hours a day, 365 days a year.

Security Administrator

Members of this role define HSM domains⁄tokens and administer HSM users and the overall HSM policy. Security administrators guarantee a working HSM domain for DNSSEC signing.

Support Role

The support role covers the first and second levels of support (Service Desk). All registrars and SRS customers may contact the support role as the first line of contact. Requests can be submitted via email or phone and can be placed 24 x 7. The support role is located in two geographically separate locations, one in Germany and the other in Mexico. If problems are traced back to an erroneous system behavior as the cause, all available data are gathered and a problem report is generated and handed over to the change management team. 

DNS⁄DNSSEC Role

The DNSSEC administrator role is staffed with at least two persons. Members of this role are responsible for the overall Open DNSSEC setup and maintenance. This includes the connection to the HSM cluster as well as compliance to the HSM policy for the DNSSEC domain. 

Quality Management Role

The Quality Management (QM) role takes care of each software component which is integrated into the SRS system and related interfaces. After a development cycle is finished, the QM performs full integration testing of the entire system. The testing is performed entirely on a separate testing system (OT&E) which mirrors the production system. The QM ensures the production readiness of each and every software upgrade, including emergency software patches. No software or system change will be promoted to production without the explicit approval of the QM. 

Change Management ⁄ Project Management Role (CM⁄PM)

The CM and PM role ensures that all steps in the development and system change processes are assessed, approved, implemented, and reviewed in a controlled manner. They also chair the Change Advisory Board (CAB) and the Emergency Change Advisory Board (ECAB). These boards are comprised of selected people from other functions within the company. The CM⁄PM reviews and closes requests for change and reports to management. 

F.2 Project Resources

The table in (fig. 2 in attachment Q24_Figure2.pdf) shows how the roles described above are planned for the SRS system. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, management, and development required. All human resources are only engaged in the domain industry and are experts in their area.

However, as the resources are shared and are not dedicated exclusively to one SRS project, the columns contain the number of resources available for this role and the percentage of all people working for this specific TLD. This percentage is the guaranteed time the resources for this SRS project assure.


G. List of Attachments

- Q24_Figure1.pdf
- Q24_Figure2.pdf
- Q32_Figure1.pdf
- Q32_Figure3.pdf

Question 25: Extensible Provisioning Protocol (EPP)

AS ICANN NOW INFORMS US, CERTAIN BRACKET-SYMBOLS (ʺ〈ʺ and ʺ〉ʺ) CONTAINED IN THIS ANSWER CANNOT BE PROPERLY DISPLAYED IN TAS. THE FULL ANSWER TO THIS QUESTION IS THEREFORE ATTACHED AGAIN AS A PDF FILE, AS ADVISED BY ICANN TO ENSURE PROPER READABILITY CAN BE SAFELY MAINTAINED. THE TEXT VERSION BELOW IS LEFT FOR REFERENCE ONLY, PLEASE REFER TO THE PDF FOR THE CORRECTLY FORMATTED ANSWER.

Key Systems GmbH first gained experience working on the client side of the Extensible Provisioning Protocol(EPP) with the .Info registry (launched in 2001). This deep industry knowledge and experience has been transferred to KSregistry GmbH. Launched against early Internet Drafts, a great deal was learned in the first years leading to important protocol revisions. Some of these included changes to prevent the formation of orphaned glue records in an EPP registry and the ability to affect mass internal host updates with a single request. Most importantly, EPP brought the required functionality of populating registration contact data in the registry, allowing the subsequent implementation of a centralized or “thick” Whois service.

EPP was largely motivated by the growth in the number of accredited registrars that occurred beginning in 1999. Technologists working on EPP believed that the emergence of many new TLD registries was imminent and sought to ease the client-to-server implementation work that would flood the registry⁄registrar community if a standardized protocol was not developed through which to interact with domain registries. The effort was largely successful, although there has been extensive distinct diversion among overlapping EPP extensions between different registries over the years.

These many EPP extension difference first led KSregistry (KSR) to write a EPP proxy server in May 2009. The KSR RFC compliant EPP server implementation has been serving over 300 large and small registrars, passing up to 7000 EPP transactions per minute to over 280 registries. Some of these well known registries include: com, net, org, biz, info. 

KSR EPP Server Interface

The EPP server is set up as a cluster to guarantee a high availability solution. The sizing of the servers and databases are calculated to meet the needs of each business case. The system is set up in a scalable way so that an increase of domains or registrars can be handled by adding hardware as needed. The KSR EPP API is offered over TCP on port 700 with mandatory SSL session enforcement for registrars for automated interaction with username and password.
To increase security, a registrar IP address limitation is in place for the EPP servers (both production and OT&E).This API also supports a secure web-based (over https) EPP client for registrarsʹ manual use only. The web-based graphical interface interacts with the EPP server through standard EPP XML queries. The EPP XML responses are in turn displayed in the web interface. This allows the registrars to perform registry transactions through the web-based interface.

The KSR EPP Interface is capable of supporting up to 5000 read transactions per minute and 2000 write transactions (concurrently). It is provisioned in a highly redundant,duplicative environment using stateless, multiple application instances. Please see Q. 31 for details on expected transaction volumes for the .immo gTLD registry.


A. RFC Relevance to KSregistry (KSR)

A.1 RFC 5730

This RFC is a base protocol document for EPP. EPP is an XML-text object based client-server protocol, atomic in its transactions, and developed to support multiple transports and lower level security protocols. There are no partial failures; all commands either succeed or fail definitively. Object-to-object associations are standard with limited application of parent-child relationships where delegate relationships are necessary for affected functionality, such as internal host data and its relationship to domain objects. The KSR registry fully implements the service discovery, commands, responses, and the extension framework described. 

A.2 RFC 5731

This RFC explains the mapping of the primary EPP registry object, the domain object. It reviews associated attributes and states of the domain object as well as child object relationships (hosts). It also details associations with other contact objects. KSR complies with the full XML examples and descriptions and applies flexibility where permitted. For example, 5731 allows operators to implement the info command with different responses for a “sponsoring registrar” and a “non-sponsoring registrar” in regards to most domain object attributes. KSR implements this as a base protocol document for EPP.

A.3 RFC 5732

KSR implements this as a base protocol document for EPP. KSR notes this RFC describes the mapping of relationships to host objects, which are by definition subordinate to the superordinate domain name object. Host objects that are defined as internal or in the namespace of the registry must be related to a superordinate domain object to be created. Internal hosts, as full child objects, face restrictions associated with the management of their superordinate domain object. External hosts are hosts belonging to another domain namespace and as such are not subordinate in the present namespace. Internal hosts can have a glue or an A record associated with them, external hosts refer to another namespace or zone for the associated A record. 

A.4 RFC 5733

Another base RFC implemented in the KSR server, this RFC describes the contact object mappings in EPP. Contact objects are used to contain related data surrounding the standardized contacts types in TLD registries including attributes such as contact type, country, telephone numbers, email addresses, etc. As a standalone object, a contact object can be created and associated with no domain objects or with any number of domain objects available in the registry. This is used commonly by registrars to update common contact information associated across large numbers of domains in a single transaction. Like the domain object, it can be secured with a passphrase or “authinfo” code. Contact object data represents the definitive data source for authoritative RDDS (WHOIS) in new TLDs. 

A.5 RFC 5734

KSR will implement this RFC as the preferred industry transport and in compliance with ICANNʹs requirements. Early implementations of EPP were considered over BEEP. This RFC describes a standard implementation of TCP incorporating TLS. As mentioned earlier, EPP can be implemented over multiple transports. The transport of choice for the EPP registry community has been TCP. Implementers are encouraged to take precautions against denial of service attacks through the use of standard technologies such as firewall and border router filters. IANA awarded port 700 as the dedicated port for the server side. There is no dedicated port assignment for the client side. 

A.6 RFC 5735

KSR will implement this RFC as applicable to any extensions it utilizes as this RFC provides specific and detailed guidance on EPP extensions. An important principle in creating extensions to, as opposed to modifying, the EPP protocol was to fully preserve the integrity of the existing protocol schema. Additionally, a valid extension itself should be extensible. Another important requirement in the RFC is to include announcements of all available extensions in the EPP server greeting element before establishing an interactive client session. 

A.7 RFC 3915

KSR will support this extension since the .immo gTLD implements the grace period implementation known as the Redemption Grace Period or “RGP”. When RGP is in use, domains are deleted into the RGP where Registrars may request a restoration of the domain. This is a billable event and requires a three-step process: placement of the domain into a pending restore state, submission of a restore report explaining why the domain is being restored, and finally the restoration of the domain. The RFC extends the domain update command, adds related domain statuses, such as ʺredemptionPeriodʺ and ʺpendingRestore,ʺ and extends the responses of domain info and other details. The RFC provides a lifecycle description of the RGP and defines the format and content for client to server submission of the associated restore reports. 

A.8 RFC 5910

KSR will support DNSSEC from the initiation of the .immo gTLD and therefore will also support this extension from initiation of the registration process. DNSSEC is a mechanism for cryptographically verifying that each delegate zone in the DNS hierarchy has been referred to or is referring to its genuine parent or child zone respectively. Since TLD zone files are generated from authoritative registry data, this extension specifically provides the ability to add elements to the domain-create and domain-update functions and to the domain-info responses, allowing registrars to submit associated delegated signer information of the child zone indicating it is digitally signed and that the parent zone recognizes the indicated key as a valid zone key for the child zone.

 
B. Extensions used by KSR and Related Internet Drafts

B.1 Draft-tan-epp-launchphase-01 (Launch Phase Mapping for the EPP)

KSR intends to use this EPP internet draft to facilitate Sunrise phases during the initiation of the .immo gTLD registry. This internet draft proposes an extension mechanism that supports the organization of Sunrise related domain applications. The extension considers the following elements:

〈lp:phase〉
This element allows a Sunrise application submission to be marked by the EPP client as a particular Sunrise application type, in respect to running different types of Sunrise applications during a concurrent submission period. KSR will use this to identify Sunrise A and Sunrise B application types. 

〈lp:status〉
This element allows the EPP server to assign one of a number of statuses indicating what stage the Sunrise application is in. These statuses can be expressed through the domaininfo command response and, optionally, through the RDDS service if applicable. The statuses listed below can be assigned uniquely or in combinations where appropriate:

〈pvrc〉
The Pre-Validation Result Code, an opaque string issued by a third-party validation agent

〈claimIssuer〉
contains the ID of a contact object (as described in RFC 5733 [RFC5733]) identifying the contact information of the authority which issued the right (for example, a trade mark office or company registration bureau)

〈claimName〉
identifying the text string in which the applicant is claiming a prior right

〈claimNumber〉
the registration number of the right (ie trademark number or company registration number)

〈claimType〉
indicates the type of claim being made (eg trademark, symbol, combined mark, company name)

〈claimEntitlement〉
indicates the applicantʹs entitlement to the claim (ie, owner or licensee)

〈claimRegDate〉
the date of registration of the claim 

〈claimExDate〉
the date of expiration of the claim

〈claimCountry〉
indicates the country in which the claim is valid

〈claimRegion〉
indicates the name of a city, state, province or other geographic region in which the claim is valid. This may be a two-character code from [WIPO.ST3] 

The complete draft is described in attachment Q25_Figure3.pdf.

B.2 Draft-obispo-epp-idn-00 (Internationalized Domain Name Mapping Extension for the EPP)

KSR intends to use this EPP internet draft to facilitate the usage of provisioning Internationalized Domain Names (IDNs). This internet draft extends the EPP domain name mapping to provide additional features that are required to implement registrations of domain names in character sets other than ASCII.

The extension considers the following element in both the domain create request and the domain-info response:

〈idn:language〉
This element allows for association of a domain name to a language tag, as defined in the code division of the Unicode code chart.

This element allows the registrar submitting the registration to identify a language tag associated with a punycode registration. The language tag refers the server to consider a declared set of table- and⁄or algorithmic-driven policies regarding a set and⁄or combination of defined unicode points, including variations of the punycode registration. 
Insert Attachment with entire RFC including full xml schema examples 

The complete draft is described in attachment Q25_Figure4.pdf.


C. KSR EPP Server 

C.1 KSR EPP Command and Elements and Overview

Attachment Q25_Figure1.pdf contains the table with the supported EPP commands and the EPP object relationship.
Note: There are at least 2 name servers required for an active domain. Otherwise, the domain will be in the inactive status.

C.2 EPP Compliance Assurance:

KSR is committed to ensuring and maintaining compliance with the aforementioned EPP RFCs and, to this end, employs numerous mechanisms as listed below:

Quality Assurance Program

KSR runs a robust Quality Assurance (QA) program with multiple dedicated QA engineers. KSR has developed complete unit, regression, and stress based automated test suites for positive and negative use case testing. The test suites are self-developed and optimized for the relevant use cases. KSR reviews its use cases regularly with the entire development and registry operations teams for consideration as additional test cases. Additionally, KSR hosts periodic events where we bring together registrar engineers to discuss these use cases and seek new cornerstone cases that registrars may be able to offer from their experiences and points of view. 
KSR provides its QA team with a robust production grade testing environment with client load emulation capabilities that far exceed the load (through rate limiting) permitted on the KSR production environment. 

OT&E

All new candidate EPP application versions will be released to a pre-candidate Registrar Operational and Testing Environment (OT&E) before promotion. Minor revisions, defined as new optional functionality, will have a minimum 30 day period in OT&E. Major changes, defined as requiring changes on the registrar client side, will have a minimum 90 day period in OT&E.

Inline XML Validator

The KSR EPP application uses the following XML validator in its server implementation. (Perl library XML::LibXML) XML errors or malformed XML will fail EPP transactions with the client atomically and the server will detail the failure state in the returned error message as well as the incorrect XML.

Third Party Validation

KSR is partnered with another Registry Service Provider (RSP), Internetwire, and has a bilateral agreement for each party to independently test and verify each otherʹs EPP RFC compliance. KSR may also opt to engage other third parties for compliance testing.


D. Resources and Roles

D.1 Resources

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain industry. This deep industry knowledge and experience has been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR), and is evident in many trusted persons serving in different roles throughout the company.

All employees, contractors, and consultants that have access to or control of the KSregistry system are trusted persons.

Each role is staffed with multiple human resources for backup and capacity purposes.

Prior to commencement of employment in a trusted role, KSregistry GmbH performs the following background checks on a prospective candidate:

- Criminal records bureau check
- Verification of previous employment
- Check of professional references

D.2 Roles

Designated Engineering Role

The designated engineering role includes the software developers of the entire SRS and all related interfaces (EPP, RDDS (Whois), escrow, etc.). All engineers are also integrated into 3rd level support of the SRS and related interfaces. The members of the engineering role are located in two geographically separate locations in Germany (St. Ingbert and Munich).

System Administration Role

The system administrators take care of the infrastructure of the SRS system. This includes the entire network, hardware, and system installations, as well as the cluster setup of the databases and all data backups which are made. Further, the installation of the hardware security module is performed by this role. This includes network setup, operating system installation, and HSM activation.

Support Role

The support role covers the first and second levels of support (service desk). All registrars and SRS customers may contact the support role as the first line of contact. Requests can be submitted via email or phone and can be placed 24 x 7. The support role is located in two geographically separate locations: one in Germany and the other in Mexico.
The first level of support receives all incoming requests from registrars and SRS customers and establishes the first contact. All problems that arise due to improper usage of the system or a misunderstanding of procedures will be resolved by the first level support. In addition, the first level points the customers to the online wiki and knowledge bases to prevent such requests in the future.

The second level support takes care of all problems which could not be solved by the first level. If problems are traced back to an erroneous system behavior as the cause, all available data are gathered and a problem report is generated and handed over to the change management team.

Quality Management Role

The Quality Management (QM) role takes care of each software component which is integrated into the SRS system and related interfaces. After a development cycle is finished, the QM performs full integration testing of the entire system. The testing is performed on a separate testing system (OT&E) which mirrors the production system. The QM ensures production readiness of each and every software upgrade, including emergency software patches. No software or system change will be promoted to production without the explicit approval of the QM.

Change Management (CM) ⁄ Project Management (PM)

The CM and PM role ensures that all steps in the development and system change processes are assessed, approved, implemented and reviewed in a controlled manner. This role filters requests so that only useful, valid and approved changes are implemented. They are also responsible for managing development efforts and changes to ensure that the changes are applied in accordance with predefined processes. They also chair the Change Advisory Board (CAB) and the Emergency Change Advisory Board (ECAB). These boards are comprised of selected people from other functions within the company. The project and change management role reviews and closes requests for change and reports to management. 


The table in (fig. 2 in attachment Q25_Figure2.pdf) shows how the roles described above are planned for the SRS system. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, management, and development required. All human resources are only engaged in the domain industry and are experts in their area.

However, as the resources are shared and are not dedicated exclusively to one SRS project, the columns contain the number of resources available for this role and the percentage of all people working for the .immo gTLD. This percentage is the guaranteed time the resources for this SRS project assure.


E. List of Attachments

- Q25_Figure1.pdf
- Q25_Figure2.pdf
- Q25_Figure3.pdf
- Q25_Figure4.pdf
_ Q25_IMMO.pdf

Question 26: RDDS (WHOIS)

The KSregistry (KSR) provides both web and command line (port 43) publicly accessible RDDS (WHOIS) which offers a central location for all authoritative TLD related information when registering or modifying a domain name. The RDDS (WHOIS) information is reflected in real-time to the public. 
The RDDS (WHOIS) service is a public service for interested stakeholders such as registries, registrars, individuals, law enforcement, and trademark owners that require detailed information on one of the following categories of information:

- Domain name including status, creation, and expiration date
- Information on domain registrant, administration, technical and billing contact
- Name server and IP address
- Registrar information

This information will provide the public with the ability to get in touch with the domain holder for any reason that requires action to be taken (e.g. trademark issues, violations with registry policies, offensive content, etc.). In addition to the search capabilities, the service has methods of limiting abuse.

The RDDS (WHOIS) service is in compliance with RFC 3912 and Specifications 4 and 6 of the registry agreement and global best practices.

KSR is already running a RDDS (WHOIS) server in full compliance with RFC 3912. The service has been in place for over 11 years without any major incidents. Experienced personnel are on board for operating and maintaining the RDDS (WHOIS) service.


A. Searchable RDDS (WHOIS)


The KSR RDDS (WHOIS) includes a web-based searchable service for registrars only which reveals more detailed information, satisfying the requirements for a score of 2.

Fig. 2 in attachment Q26_Figure2.pdf shows the complete list of all possible queries which can be made.

For security reasons and legal restrictions some search capabilities are only available in the registrar web-based RDDS (WHOIS). This includes partial match capabilities regarding the registrantʹs postal address.


B. Abuse Protections

There are technical restrictions in place for all RDDS (WHOIS) types to prevent the abuse of the data from such methods as data mining or DDOS (Distributed Denial of Service). Following best practices, KSR protects the web-based whois service with CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) and port 43 whois service with IP limitations. 

In addition to these technical restrictions, the registry policy disallows data mining or comparable approaches of collecting data.


C. Technical Overview

The RDDS (WHOIS) service is set up as a two server cluster with a redundant load balancer in front of it to ensure a highly available solution (n+1 redundancy). 

The server software is running on a SuSE Linux Enterprise Server and is configured to be scalable, allowing KSR to be extended by simply adding additional servers to the setup during regular operations.

The sizing of the servers and the databases are calculated to meet the needs of the individual business case and are able to handle a sustained and significant load. The available RDDS (WHOIS) servers are always active at one regional site and may be switched to another regional site within minutes as necessary. There are two different sites available for running the RDDS (WHOIS) service.

- Primary Site: St. Ingbert, Germany
- Secondary Site: Munich, Germany

All sites have a permanent highly secure VPN connection to the (current) primary site in order to synchronize the complete SRS, EPP, DNS⁄DNSSEC, escrow and RDDS (WHOIS) related database information. All network traffic between the VPN gateways will be encrypted using 1024 bit RSA keys. The complete availability of KSR information at all times allows for a safe failover from the primary site to the secondary or disaster site within minutes.

The RDDS (WHOIS) information data is stored in a MySQL database which is setup as an active⁄active database cluster. This cluster is permanently replicated to all other sites. The RDDS (WHOIS) data is also stored daily by the KSR backup system. The backups are also sent to the secondary site.

In addition to the performance aspect of the RDDS (WHOIS) service, the KSR detects abusive usage levels such as those that occur from excessive numbers of queries from one source. This is accomplished by checking the source IP of the request on the port 43 RDDS (WHOIS). The web-based RDDS (WHOIS) comes with an additional CAPTCHA mechanism in order to prevent abuse.

Further protections to the WHOIS service from incidents like DDOS (Distributed Denial Of Service) attacks are assured by an IDS (Intrusion Detection System) which provides KSR overall protection.

Daily generated escrow data files containing all RDDS (WHOIS) related data are stored at the NCC Group as the KSR escrow provider. 

The full RDDS (WHOIS) architecture is described in fig. 1 in attachment Figure Q26_Figure1.


D. Quality Measurements and Validation of Compliance with Specifications 4 and 10

KSR takes several measurements in order to ensure ongoing Service Level Agreement (SLA) checking, RFC compliance, and compliance with Specifications 4 and 10 of the registry agreement. For the following, KSR refers to the RDDS (WHOIS) as RDDS (Registration Data Directory Services) in order to describe the collective of RDDS (WHOIS) and web-based RDDS (WHOIS) services. 

In order to facilitate the registry performance specification (Specification 10), the following checks are performed on the RDDS (WHOIS) periodically:

- RDDS availability
- RDDS query RTT 
- Web-based RDDS query RTT 
- RDDS update time
- RDDS test 

All available RDDS (WHOIS) search patterns are randomly checked with a data parser compliant with RFC 3912 and Specification 4 in order to check if the data output satisfies the given requirements.

A non-registry partner also validates RFC 3912 compliance. KSR also performs backwards RFC compliance checks on the non-registry partner through its registry partnership with Internetwire. All software enhancements or corrections go through the change management process. This includes full regression testing with the complete SRS system. Provided that all quality tests and the change is approved by the Change Management Board (CMB), a change will be made in the OT&E system. Once the testing phase in the OT&E is done and no problems are found while testing with the registrars, the software change of the new version will be made in production.


E. System Capacity

KSR sizing calculations have been performed to assess the hardware resources necessary to support the expected volume of transactions from the business case for the .immo gTLD and are based on available statistics from the monthly ICANN registry reports of existing gTLDs like .Com, .Org, .Info and the ccTLD .Be. 

Taking into account that the KSR is setup and designed to host multiple strings, the maximum number of this specific string does not fully load the maximum capacity of the system.

KSR is capable of handling up to the following volumes as a maximum with the current capability of the hardware:

For this the .immo gTLD the expected number of domain name registrations will be significantly less than 9,000 over a period of 3 years.

Max. RDDS (WHOIS) capacity of KSR: 200,000,000 queries⁄month

If the system reporting and alerts indicate that the current volumes of data or transactions is reaching 75% of the maximum capacity of the system, the system will be upgraded by adding additional servers to the setup. This can be done during regular operations without requiring any downtime.

KSR used the gathered statistics to derive blended base and peak transaction volume expectations per domain. Calculations of traffic presented below are derived strictly from peak transaction volumes in support of conservative estimates and the intent that a margin of error should result in over-provisioning registry services, versus under-provisioning. 

First Year:
RDDS up to 78 queries per domain per month

For a 9K domain name registry:
RDDS up to 702,000 queries per month

Note: benchmark calculations from values from public registry data are raised by 50% for RDDS in the first year in respect to related registry launch activities.

Second Year:

RDDS up to 52 queries per domain per month

For a 9K domain name registry:
RDDS up to 468,000 queries per month


F. Hardware Specifications

The hardware specifications are based on the analysis from the system capacity numbers.

KSRʹs primary and secondary data center were chosen to fit a common architecture, providing the following benefits:

- at least TIER III certification
- n+1 redundancy on power supply, cooling network 
- at least one 1 Gbit uplink provider
- latest fire prevention system
- 10 Gbit internal network transfer for KSR systems 

The detailed hardware list is described in the table in fig. 3 in attachment Q26_Figure3.pdf.

RDDS plans are consistent with the technical, operational, and financial approach as described in the application


G. Roles and Resources

G.1 Resources

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain business. This deep industry knowledge and experience has also been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR) and is evident in many trusted persons serving in different roles throughout the company.

The table in (fig. 4 in attachment Q26_Figure4.pdf) shows how the roles described above are planned for the SRS system. All resources at KSregistry are dedicated to the registry business. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, managing, and development required. All resources are engaged in the domain industry only and are experts in their field.

However, as the resources are shared and are not dedicated exclusively to one SRS project, the columns contain the number of resources available for this role and the percentage of all people working for this specific TLD. This percentage is the guaranteed time the resources for this SRS project assure.

G.2 Roles

Engineering Role

The designated engineering role includes the software developers of the entire SRS and all related interfaces (EPP, RDDS (WHOIS), escrow, etc.). All engineers are also integrated into 3rd level support of the SRS and related interfaces. The members of the engineering role are located in two geographically separate locations in Germany (St. Ingbert and Munich).

System Administration Role

The system administrators take care of the infrastructure of the SRS system. This includes the entire network, hardware, and system installations, as well as the cluster setup of the databases and all data backups which are made. Further, the installation of the hardware security module is performed by this role. This includes network setup, operating system installation, and HSM activation.

The members of the administration role are spread across two geographically separate locations inside of Germany (St. Ingbert and Munich).

Quality Management Role

The Quality Management (QM) role takes care of each software component which is integrated into the SRS system and related interfaces. After a development cycle is finished, the QM performs full integration testing of the entire system. The testing is performed on a separate testing system (OT&E) which mirrors the production system. The QM ensures production readiness of each and every software upgrade including emergency software patches. No software or system change will be promoted to production without the explicit approval of the QM.

Change Management (CM) ⁄ Project Management (PM)

The CM and PM role ensures that all steps in the development and system change processes are assessed, approved, implemented and reviewed in a controlled manner. This role filters requests so that only useful, valid and approved changes are implemented. They are also responsible for managing development efforts and changes to ensure that the changes are applied in accordance with predefined processes. They also chair the Change Advisory Board (CAB) and the Emergency Change Advisory Board (ECAB). These boards are comprised of selected people from other functions within the company. The project and change management role reviews and closes requests for change and reports to management. 


H. Whois Output Fields

Query on domain name data displays the following information:

Domain Name
Domain ID
WHOIS Server 
Referral URL
Domain Last Updated Date 
Domain Registration Date
Domain Expiration Date
Sponsoring registrar
Sponsoring registrar IANA ID
Domain Status
Registrant, Administrative, Technical and Billing Contact
Information including
Contact ID
Contact Name
Contact Organization
Contact Address, City, State⁄Province, Country
Contact Postal Code
Contact Phone, Fax, E-mail
Name Servers associated with this domain
DNSSEC information

Example Request: Query for domain “example.string”
Example Response:
Domain Name: EXAMPLE.STRING
Domain ID: 213232132-TLD
WHOIS Server: WHOIS.example.string
Referral URL: http:⁄⁄www.example.string
Updated Date: 2011-07-22T01:44:02Z
Creation Date: 2011-06-01T23:45:33Z
Registry Expiry Date: 2012-06-01T23:59:59Z
Sponsoring Registrar: EXAMPLE REGISTRAR
Sponsoring Registrar IANA ID: 1234567890
Domain Status: clientTransferProhibited
Registrant ID: 123456-STR
Registrant Name: EXAMPLE REGISTRANT
Registrant Organization: EXAMPLE ORGANIZATION
Registrant Street: 123 EXAMPLE STREET
Registrant City: SOMEWHERE
Registrant State⁄Province: AP
Registrant Postal Code: 12345
Registrant Country: EX
Registrant Phone: +1.5555522222
Registrant Fax: +1.55555544444
Registrant Email: EMAIL@EXAMPLE.STRING
Admin ID: 392839283-STR
Admin Name: EXAMPLE REGISTRANT ADMINISTRATIVE
Admin Organization: EXAMPLE REGISTRANT ORGANIZATION
Admin Street: 123 EXAMPLE STREET
Admin City: SOMEWHERE
Admin State⁄Province: AP
Admin Postal Code: 12345
Admin Country: EX
Admin Phone: +1.5555551212
Admin Phone Ext: 1234
Admin Fax: +1.5555551213
Admin Fax Ext:
Admin Email: EMAIL@EXAMPLE.STRING
Tech ID: 392811183-STR
Tech Name: EXAMPLE REGISTRAR TECHNICAL
Tech Organization: EXAMPLE REGISTRAR LLC
Tech Street: 123 EXAMPLE STREET
Tech City: SOMEWHERE
Tech State⁄Province: AP
Tech Postal Code: 12345
Tech Country: EX
Tech Phone: +1.1235551234
Tech Phone Ext: 1234
Tech Fax: +1.5555551213
Tech Fax Ext: 93
Tech Email: EMAIL@EXAMPLE.STRING
Billing ID: 112811183-STR
Billing Name: EXAMPLE REGISTRAR BILLING
Billing Organization: EXAMPLE REGISTRAR LLC
Billing Street: 123 EXAMPLE STREET
Billing City: SOMEWHERE
Billing State⁄Province: AP
Billing Postal Code: 12345
Billing Country: EX
Billing Phone: +1.1235551234
Billing Phone Ext: 1234
Billing Fax: +1.5555551213
Billing Fax Ext: 93
Billing Email: EMAIL@EXAMPLE.STRING
Name Server: NS01.EXAMPLEREGISTRAR.STRING
Name Server: NS02.EXAMPLEREGISTRAR.STRING
DNSSEC: signedDelegation
DNSSEC: unsigned0

Query on name server name data displays the following information:

Name Server Host Name
Name Server IP Addresses if applicable 
Sponsoring registrar
Name Server Creation Date
Name Server Last Updated Date 

Example Request: Query for name server ns1.example.string
Example Response:
Server Name: NS1.EXAMPLE.STRING
IP Address: 192.0.3.123
IP Address: 2001:0DB8::1
Registrar: Example Registrar, Inc.
Creation Date: 2011-06-01T23:45:33Z
Updated Date: 2011-07-22T01:44:02Z

Query on registrar displays the following information:

Registrar ID
Registrar Name
Registrar Status
Registrar Address, City, State⁄Province, Country
Registrar Postal Code
Registrar Phone, Fax, E-mail
Registrar Creation Date
Registrar Last Updated Date
Administrative, Technical Contact
Information including
Contact Phone, Fax, E-mail

Example request: Query for registrar Example Registrar, Inc.
Example response:
Registrar Name: Example Registrar, Inc.
Street: 4231 King Street
City: London
State⁄Province: XY
Postal Code: 123445
Country: XR
Phone Number: +1.3105559999
Fax Number: +1.3105559911
Email: registrar@example.string
Admin Contact: Pete Registrar
Phone Number: +1.3105551213
Fax Number: +1.3105551213
Email: pete@example-registrar.string
Technical Contact: Karlo Schlapp
Phone Number: +1.5610555222
Fax Number: +1.33105551111
Email: karlo@example-registrar.string


I. List of Attachments

- Q26_Figure1.pdf
- Q26_Figure2.pdf
- Q26_Figure3.pdf
- Q26_Figure4.pdf

Question 27: The Registration Life Cycle of a Domain Name

The .immo gTLD operates with an open registrant policy and only offers one to ten year registration and renewal periods. The KSR platform also supports the handling of multiple year periods, as is it capable of managing multiple registrars, as described in the following.

A. Registration Life Cycle Periods

The registration life cycle of a domain name includes the following periods: available, add-grace period, registered, expired, auto-renew grace period, redemption grace period, pending delete, and released. This life cycle offers the possibility for different business cases, such as domain auctioning, drop catching, and domain tasting. As the .immo gTLD operates with an open registrant policy, auctioning, drop catching, and domain tasting may occur. It also includes the domain deletion excess fee in order to avoid massive abuse of the add-grace period. The complete registration life cycle is shown in attached fig. Q27_Figure1.1.pdf.

A.1 Available

The domain name is available for registration. Each registrar can register the domain name using a create domain command. The first registrar which submits the domain registration order and has sufficient funding will receive the domain name. After the successful registration of the domain name, the add-grace period will begin. An available domain name cannot be transferred, deleted, updated, or restored and will not be included in the zone file.

A.2 Add-Grace Period (AGP)

The AGP starts after the successful registration of the domain name and lasts for five days. During this period the registrar can submit a delete domain command to delete the domain name and will receive a complete refund of the registration fee. This refund does not include non-refundable fees of the registration process. However, the AGP follows the Internet Corporation for Assigned Names and Numbers (ICANN) AGP consensus policy to charge the registrar for excessive deletion activity during this period. During the AGP, the domain name is considered registered and therefore offers the same possibilities available during the registered period described below. A domain name in the AGP is included in the zone file and may not be transferred. The registrar license and agreement prohibits a domain name holder from changing registrars within the first 60 days of the initial registration, enforced by the SRS. If a domain name is renewed during this period and then subsequently deleted, the owning registrar will only receive a refund for the initial registration fee.

A.3 Registered
A domain name can be registered for a period of one to ten years. During this period the domain name can be transferred to another registrar using the transfer domain command if the requesting registrar has sufficient funding to pay the transfer domain fee. The transfer of a domain name will extend the registration period for one year, but cannot exceed ten years total registration period. The domain name can be renewed any time by the owning registrar using the renew domain command if the owning registrar has enough funding for the domain renewal fee. However, the maximum registration period of ten years can never be exceeded. A registered domain name is included in the zone file if associated with any host objects.

A.4 Expired

If the domain name passes its expiration date without being renewed by the owning registrar, the domain name will enter the auto-renew grace period. An expired domain name is included in the zone file if associated with any host objects.

A.5 Auto-Renew Grace Period (ARGP)

During this period the owning registrar has the possibility to delete the domain name using the delete domain command and receive a refund of the domain renewal fee. The ARGP lasts for 45 days. A transfer to another registrar is possible if the requesting registrar has enough funding for the domain transfer fee. A transfer process will extend the domain registration period for one year, but cannot exceed ten years total registration period. If the registration period is already ten years, the transfer will not extend the registration period. After 45 days without a renewal, the domain name will enter the redemption-grace period. During the ARGP the domain name will still be in the zone file if associated with any host objects.

A.6 Redemption Grace Period (RGP)

If a domain name enters the RGP it will be excluded from the zone file and the domain name will no longer resolve. During this period no renewal, transfer, or new registration of the domain name is possible. The RGP lasts for 30 days. During this time the owning registrar can restore the domain name. The registrar can submit an extended update domain command (restore) to reactivate the domain name if the registrar has enough funding for the restore domain fee. If a domain is restored it will enter the registered status with a registration period of one year. It will be included into the zone file with the associated host objects that were used before entering the redemption grace period. If a domain name passes the 30 days of redemption grace period (75 days total after expiration) the domain name will enter the pending delete period and can no longer be restored.

A.7 Pending Delete

In the pending delete period the domain name is set for deletion. The period lasts for five days and prohibits any process from occurring regarding the domain name. It will not be included in the zone file. After five days the domain name will be released and available for new registration through a valid domain registration order.

A.8 Released

The domain name is deleted from the SRS and enters the available period. The domain name will be immediately available for registration to all registrars.

B. Domain Name Operations

B.1 Create Domain

A registrar uses the create command to register a domain name. Before a domain name can be created the registrar should use the check command to determine if the domain name is available. The domain name will be registered for the period specified by the registrar. This period may be from one to ten years (the default is one year). Upon registration of a domain name the registrarʹs credit is immediately debited by the registration fee multiplied by the number of years requested. The registry operator may also add an initial setup fee for a new registration. To be included into the zone file, the domain name must have at least two but no more than thirteen name servers. The registrant may add an authentication code for the domain during the creation or a randomly generated authentication code will be set for the domain name.

B.2 Delete Domain

The delete domain command allows the owning registrar of the domain name to delete it. A request to delete a domain name will cause all child name servers of the domain name to also be deleted. A domain must not be deleted if it has child name servers hosting other domains. When a domain name is deleted outside of the AGP it goes into the redemption-grace period status for 30 days. When a domain name is deleted within the AGP it is deleted immediately from the SRS and the zone file and will be available for a new registration.

B.3 Transfer Domain

The transfer process begins when a registrar initiates a transfer with a transfer domain command, the correct authentication code, and sufficient funding in his account for the transfer domain fee. The domain will be flagged in the SRS as being requested for transfer (“pendingTransfer” status). The current registrar has five calendar days to approve or reject the transfer request. If the losing registrar explicitly approves the request the domain is transferred and one year is added to the expiration date. However, the registration period cannot exceed ten years total and will be capped at a maximum of ten years. If the losing registrar explicitly denies the request, then the transfer is immediately canceled and the requesting registrar will receive a refund of the transfer fee. If the gaining registrar mistakenly sends a transfer request, they may cancel the request as long as the transfer is pending. In this case the requesting registrar receives a refund of the transfer fee. Once one of these three actions is complete the SRS creates a poll message to all participating registrars for the domain name. If no action is taken within five days, the request is automatically approved by the SRS batch system. Once a transfer is requested the losing registrar has the response options to reject, approve, or do nothing (auto approve). After the successful transfer of a domain name the old authentication code will be replaced with a new randomly generated authentication code.

B.4 Update Domain

The update command enables the owning registrar of the domain name to perform four different update operations on the domain name: Update the name servers, the authentication code, the associated contacts, and the statuses of a domain name. Possible statuses that can be updated include “clientHold”, “clientDeleteProhibited”, “clientUpdateProhibited”, “clientTransferProhibited”, and “clientRenewProhibited”. If an update command removes all name servers of a domain name, it will no longer be included in the zone file and will receive the status “inactive”.

B.5 Renew Domain

The renew domain command allows the registrar of the domain name to extend the registration period if they have enough funds for the renew domain fee multiplied by the number of years the registration period will be extended. The request for a renewal should contain the period to identify the number of years to be added to the registration period. If not provided, the SRS uses a default value of one year. The renewal request should contain the current expiration date to ensure that the domain name will not be renewed multiple times if the request was submitted multiple times due to connection problems between the SRS and the registrar. If no expiration date is given, the SRS will automatically use the current expiration date as the default value. The SRS will renew the domain name for the period specified by the registrar and returns the new registration expiration date.

B.5 Restore Domain

The restore domain command enables a registrar to restore a deleted domain name after the AGP. In order to successfully restore a domain, the registrar must submit a restore domain command and have sufficient funding for the restore domain fee. The restore operation adds the “pendingRestore” status to the domain name until completion of the request. A successful restore will extend the registration period of the domain name by one year but is capped at a total registration period of ten years. After the restore operation, the domain name will be added back into the zone file as long as there is at least one name server and no “clientHold” or “serverHold” status associated. If the restore operation fails, the domain will stay in the RGP until it enters the pending delete period and the registrar will receive a refund of the restore domain fee.





C. Domain Name Statuses

To ensure the registration domain life cycle there are several domain statuses that can be seen by everyone using the RDDP (WHOIS) or by any registrar using the extensible provisioning protocol (EPP). These statuses are very important in identifying the current period a domain name is in, or identifying the problems a registrar can encounter while managing a domain name (e.g. a failing transfer request caused by a “serverTransferProhibited” status). A foreign registrar may also be interested in the statuses of a domain name to identify when a specific domain name will be available for registration again (drop catching). Domain name statuses include EPP and RGP domain name statuses as referenced in RFC 3915. Depending on the life cycle period of a domain name, it can have an EPP and a RGP status at the same time. In some cases these two statuses can be different.

These domain statuses are compliant with the RFCs 3915, 5730-5734, and 5910. The domain statues are:

- addPeriod

- autoRenewPeriod

- inactive

- ok

- pendingRestore

- pendingDelete

- pendingTransfer

- redemptionPeriod

- serverDeleteProhibited

- serverHold

- serverRenewProhibited

- serverTransferProhibited

- serverUpdateProhibited

All server statuses are always set by the SRS. However, the owning registrar also has the ability to assign statuses to a domain name, offering the same functionality as the server statuses. These statuses are:
- clientDeleteProhibited

- clientHold

- clientRenewProhibited

- clientTransferProhibited

A domain name may have more than one status at a time, but must have at least one status. Some statuses prohibit other statuses on the same domain name.

C.1 ok

This is the default status of a domain name that has no operations or prohibitions. This value is set and removed by the SRS system as other status values are added or removed and cannot be combined with any other status. The SRS sets this status upon initial creation. A domain name with this status may be updated with any “client” statuses and will be included in the zone file if there is at least one name server associated with it.

C.2 inactive

If the delegation information has not been associated with the domain name, this status is applied. This is the default status when a domain name has no associated host objects for the DNS delegation. This status will be set by the SRS when all host-object associations are removed.

C.3 clientHold

The owning registrar may set the domain name to this status to prevent the domain name from being included in the zone file. 

C.4 clientUpdateProhibited

If a domain name status is “clientUpdateProhibited” it cannot be updated using an update domain command. The name servers, authentication code, contacts, and other statuses of the domain name cannot be updated until this status is removed. 

C.5 clientTransferProhibited

The owning registrar can set this status to a domain name to prevent any other registrar from successfully requesting a transfer for this domain name.

C.6 clientDeleteProhibited

If a domain name status is “clientDeleteProhibited”, it cannot be deleted from the SRS using the delete domain command. The domain can still expire after the registration period has passed. 
C.7 clientRenewProhibited

If a domain name status is “clientRenewProhibited”, it cannot be renewed explicitly by the registrar using the renew domain command. It can still be automatically renewed by the SRS batch system if the owning registrar has set the renewal mode of the domain name to auto renew.

C.8 serverHold

The SRS administrator may set the domain name to this status to exclude it from the zone file. 

C.9 serverUpdateProhibited

The SRS may set the domain name to this status to prevent any updates using the update domain command. The name servers, authentication code, contacts, and the domain name statuses cannot be updated until this status is removed. 

C.10 serverTransferProhibited

The SRS may set the domain name to this status to prevent any registrar from successfully requesting a transfer for this domain name.

C.11 serverDeleteProhibited

The SRS may set the domain name to this status. If a domain name status is “serverDeleteProhibited” it cannot be deleted from the SRS using the delete domain command. This status is slightly different from the “clientDeleteProhibited” as the domain will not even be deleted after the redemption-grace period.

C.12 serverRenewProhibited

The SRS may set the domain name to this status. If a domain name status is “serverRenewProhibited”, it cannot be explicitly renewed by the owning registrar using the renew domain command. It can still be automatically renewed by the SRS batch system. 

In addition, the SRS batch system may set the RGP pending period statuses as listed below. In EPP, the RGP pending period statuses are represented as substatuses of the EPP statuses.

C.13 redemptionPeriod

The SRS sets the domain name to this status when a domain is deleted after the AGP. Only the restore domain operation is allowed on a domain with the “redemptionPeriod” status.

C.14 pendingRestore



The SRS sets the domain name to this status when a restore is requested. If a domain name status is “pendingRestore”, then no additional restore request can be successfully submitted.

C.15 pendingDelete

The SRS sets the domain name to this status once it has been in “redemptionPeriod” for 30 days. A domain name remains on “pendingDelete” status for five days before it is finally deleted from the SRS.

C.16 pendingTransfer

The “pendingTransfer” status is automatically set when a domain transfer is requested by a registrar. A domain name remains in “pendingTransfer” status until the transfer is approved, automatically approved through the SRS batch system, rejected, or canceled by the requesting registrar.

C.17 addPeriod

This period is entered after the initial registration of a domain name. If the domain name is deleted by the owning registrar during this period he will receive a refund of the domain registration fee in compliance with ICANNʹs AGP consensus policy.

C.18 autoRenewPeriod

This period is set after a domain name registration period expires and is renewed automatically by the SRS. If the domain name is deleted by the owning registrar during this period he will receive a refund of the domain renewal fee.

D. Reserved Premium Domain Names

The registry operator reserves the option to define specific domain names as reserved or premium domain names. These domain names will be in compliance with the described registration life cycle with the addition of a manual registration process through the registry operator support and legal team. Special fees may be accounted for those domain names to reflect manual processing.

E. Roles

The table in attached fig. 27_Figure_5.1.pdf shows how the roles described above are planned for the SRS system.

Support Role
The support role of the registry operator will review these reports. If there is a logical problem, an engineer will be assigned to solve the problem. The support may manually correct or influence the life cycle of a domain name if necessary. The registry operatorʹs support role will also take care of any submitted registrar problems regarding the registration life cycle, either through the telephonic support or the ticket system.

Legal Role

All legal issues and dispute cases will be manually reviewed and processed by the legal role of the registry operator in compliance with the registry operatorʹs policy. The legal role may manually correct or influence the life cycle of a domain name if necessary.

Administration Role

The ticket system and the telephone system where the registrars submit their problem requests will be set up and maintained by the administrators. 

Designated Engineering Role

Each technical issue that is assigned by a supporter will be reviewed and solved by an engineer. Another task of the engineering role is the development of the tools that enable the support and legal roles to influence and maintain the domain life cycle.

F. List of Attachments

- Q27_Figure1.1.pdf
- Q27_Figure5.1.pdf

Question 28: Concerns on Abuse Prevention and Mitigation

The Applicant’s proposed use for the .immo gTLD will include robust protection mechanisms designed to preclude any abusive registrations within the space. 

Accordingly, the Applicant will adopt a comprehensive system including the screening of second-level domain name strings and ongoing monitoring for appropriate use of websites active within the space. Furthermore, the Internal Domain Use⁄Registration Policy as described in Question 18 above will ensure a high level of security for the .immo gTLD.

The Applicant will additionally:
- Develop a trusted method of communication for all correspondence between the Applicant and the .immo gTLDʹs registrars, to ensure that all registrant contact information, including WHOIS records, is complete and remains current, and that all requests for registration within the space may be easily verified for authenticity.
- Implement effective mechanisms for identifying and addressing abusive practices.
- Establish a point of contact for third-party reporting of abusive practices.
- Ensure accurate WHOIS data by implementing and enforcing a strict registration and validation policy. The Registry-Registrar Agreement will furthermore include the obligation of accredited registrars to validate and verify each registration request.
- Determine and implement a streamlined practice for addressing and removing orphan glue records.
- Publish on its website and include as binding registry policy an Anti-Abuse Policy, described in detail below, which provides applicable definitions of abuse and outlining steps Starting Dot will take to address any such situations.

A. Point of Contact for Abuse Complaints

The abuse email inbox will be routinely and continuously monitored several times per day. Complainants will be provided with a responsive communication containing an auditable tracking or case number.

The abuse point of contact will be easily reachable through various channels, including email, telephone and fax, responsive and effective, tasked with answering email quickly, empowered to take effective action, and guided by well-defined written criteria that will be established upon award of the .immo gTLD. This role-based function will be performed by a team of trained and qualified in-house counsels. Initially, at least one designated employee from the Applicant’s legal department will be tasked with overseeing the .immo gTLD as part of his⁄her duties. One or more additional employees will be trained in the role as well, in order to provide “back up” assistance as needed. The abuse point of contact will be supported by Nathalie Dreyfus, Trademark Attorney, from the Law Firm Dreyfus & Associés, of Paris, France, with whom the abuse point of contact will consult and coordinate the correct management of disputes and reported abuse. The abuse point of contact will further consult with the registry service provider in order to coordinate technical reactions necessary to respond to or mitigate abusive behavior in a timely manner. Nathalie Dreyfus is a UDRP Panelist with the WIPO Arbitration and Mediation Center, the National Arbitration Forum (NAF), the Belgian Center for Mediation and Arbitration (CEPINA), the Asian Domain Name Dispute Resolution Center (ADNDRC) and the Czech Arbitration Court and has a first-class knowledge of ICANN and its structure. With regard to the estimated number of registrations and the Registration Restrictions, these allocated resources will be sufficient to handle the expected initial volume of abuse complaints. Abuse complaint metrics will be tracked and reviewed carefully each year, and adequate resources will be expended to ensure appropriate trending of those metrics, thus providing the abuse point of contact with sufficient resources.Given the Applicant’s belief that infrastructure protection, rights protection, and user security are of paramount importance for a TLD owner, the Applicant expects to ensure sufficient resources for this critical role, and to do whatever is reasonably necessary to ensure a secure and trusted zone.

Given the Applicant’s belief that infrastructure protection, rights protection, and user security are of paramount importance for a TLD owner, the Applicant expects to ensure sufficient resources for this critical role, and to do whatever is reasonably necessary to ensure a secure and trusted zone.

B. Anti-Abuse Policy

The Applicant will develop and implement upon launch of the .immo gTLD an Anti-Abuse Policy (AAP). The AAP will be made binding for all registrants by contractually obligating registrars through the Registry-Registrar Agreement to pass on the AAP as part of their registration agreements. The AAP will also be published prominently on the Registry website alongside the abuse point of contact and with instructions on how to best report any suspected violations of the AAP to the registry.
The AAP will be based on and expand upon existing registry policies to ensure best industry practice is followed. The goal of the AAP is to limit significant harm to internet users, to enable the Applicant or accredited registrars to investigate and to take action in case of malicious use of domain names and to deter registrants from engaging in illegal or fraudulent use of domain names.
The Applicant defines abuse as an action that causes actual and substantial harm, or is a material predicate of such harm, and is illegal, illegitimate, or otherwise contrary to Company policy.
“Abuse” includes, but is not limited to, the following:
- Use of a domain to defraud or attempt to defraud members of the public in any way
- Use of a domain to distribute or publish hateful, defamatory, or derogatory content based on racial, ethnic, or political grounds, intended or generally able to cause or incite injury, damage or harm of any kind to any person or entity
- Use of a domain name to publish content threatening or invading the privacy or property rights of a third party
- Use of a domain name to publish content that infringes the trademarks, copyrights, patent rights, trade secrets or other intellectual property rights, or any other legal rights of the Applicant or any third party, or any action infringing on the named rights
- Violation of any applicable local, state, national or international law or regulation
- Use of a domain name for the promotion, involvement in or assisting in, illegal activity of any kind, as well as the promotion of business opportunities or investments that are not permitted under applicable law
- Advertisement or offer for sale any unlawful goods or services in breach of any national or international law or regulation
- Use of domain names to contribute to the sale or distribution of prescription medication without a valid prescription as well as the sale and distribution of unlicensed or unapproved medication
- Distribution of Child Pornography or other content depicting minors engaged in any activity of a sexual nature or which may otherwise harm minors
- Use of domain names to cause minors to view sexually explicit material
- Any use of domain names with regard to spam in any form, including through e-mail, instant messaging, mobile messaging, or the spamming of Web sites or Internet forums, as well as advertising for a domain name through spam
- Initiation or intentional participation in denial-of-service attacks (“DDoS attacks”)
- The use of domain names in phishing activities, tricking Internet users into divulging personal data such as usernames, passwords, or financial data
- The use of domain names in pharming , such as DNS hijacking and poisoning
- The use of domain names for the intentional distribution of spyware, botware, keylogger bots, viruses, worms, trojans or other forms of malware
- The use of a domain name in unauthorized fast flux hosting, disguising the location of internet addresses or Internet services. Fast flux hosting may be used only with prior permission of the Applicant
- The use of domain names to command and control botnets, i.e. a network of compromised computers or “zombies”
- The use of domain names in activities intended to gain illegal access to other computers or networks (“hacking”), as well as any activity to prepare for such system penetration
In accordance with best practices in current generic Top Level Domains, the Applicant reserves the right to either directly or through the issuing of a request to an accredited registrar deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion:
           1.         to protect the integrity and stability of the .immo gTLD and⁄or prevent the abuse of any .immo domain name
           2.         to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process
           3.         to avoid any liability, civil or criminal, on the part of the Applicant, as well as its affiliates, subsidiaries, officers, directors, and employees
           4.         per the terms of the Registry Agreement or
           5.         to correct mistakes made by the Applicant, Registry Service Provider or any Registrar(s) in connection with a domain name registration
The Applicant also reserves the right to place a domain upon registry lock, hold or similar status name during resolution of an investigation or dispute.

C. Handling of Abuse Reports

All abuse reports received by the abuse point of contact will be tracked internally in a ticketing system to ensure accountability and ease of reference, and a tracking number will be provided to the reporter. Each report will be carefully reviewed and evaluated regarding its credibility, to determine whether the reported issue is an abuse concern and to assess the required action(s), if any. The Applicant will work in tandem with the sponsoring registrar as well as the Registry Service Provider to rapidly address potential threats or abuse complaints, investigate all reasonable complaints, and take any appropriate action(s) thereto.
As standard practice, the Applicant will forward all credible and actionable reports, including the accompanying evidence, if any, to the sponsoring registrar, with a request to investigate the issue further and to take appropriate action. The sponsoring registrar has a direct relationship with the registrant and therefore possesses further information not available to the Applicant, such as payment details, sales history, and IP addresses of the customer, reseller data (if applicable) and other specific data unique to the customer. In case the registrar determines in the course of the investigation that the use of the domain name violates the applicable terms of use, ICANN policies or the AAP, the registrar is expected to take action within reasonable time. The Applicant further reserves the right to act directly and immediately in cases of obvious and significant malicious conduct.
The Applicant will implement valid court orders or seizure warrants from courts, arbitration tribunals, or law enforcement agencies of applicable jurisdiction as a top priority. The Applicant will further work closely with law enforcement agencies if necessary.
Based upon the applicable registration policies and restrictions, the Applicant does not expect further measures to be required to effectively prevent or stop malicious use. In case of an unexpected volume of credible abuse complaints, the Applicant will take advantage of additional resources such as spam databases and blocklists, anti-phishing feeds, analysis of registration data, and DNS queries.

D. Orphan Glue Records:

According to the ICANN SSAC paper SAC048 at: http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf orphan glue records are defined as follows:
 “By definition, orphan records used to be glue records. A glue record becomes an ‘orphan’ when the delegation point NS record referencing it is removed without also removing the corresponding glue record. The delegation point NS record is sometimes referred to as the parent NS record.”

An orphan glue record can occur whenever a domain is placed in ServerHold or ClientHold status. In these cases, the domain is removed from the zone file but existing name servers of this domain will be kept in the zone file so that other sites which are still using these name servers are still kept functional.

Example:
“example.string” is deleted from the zone file by setting to ServerHold status, but “ns1.example.string” will be kept in the zone file.

Prevention of Orphan Glue Records During Domain Deletion

Deleting a domain name is only possible if there are no glue records used by other domains associated with the domain being deleted.

If there are glue records available but not used by other domains in the registry, the glue records will be deleted prior to the domain deletion. Whenever there are glue records available which are still in use, this has to be resolved first. If there are no glue records at all the domain can be deleted instantly.

Solving the problem of glue records for domains which are supposed to be deleted can be done by checking the zone file. The zone file reveals the domains which are using the name servers. Once the required information is available, the named registrars must be contacted and new name servers should be set for the remaining domains in order to release the glue records.

In cases where glue records are being used in a malicious way, the abuse point of contact has to be contacted. The abuse point of contact will check this issue and take any appropriate actions, which may result in removing relevant records from the zone file in case the abuse complaint is valid.E. Preventive Countermeasures

Pharming is an abusive practice used to gain illegal access to personal and confidential internet user information by diverting internet traffic through the manipulation of the information between the recursive resolver name server and the client software (e.g. web browser) (DNS-cache poisoning). Since pharming is commonly accomplished by redirecting traffic at the recursive DNS level, mitigation is most effective at the ISP level.

However, as an added countermeasure, the Registry Service Provider (KSregistry) will sign the domain zone using DNSSEC, as detailed in the answer to question 35, allowing the relying party to establish a chain of trust from the DNS root down to the domain name, thus validating DNS queries in the zone.

Registrars will be encouraged to use a DNSSEC enabled DNS hoster and to provision the related delegation signers (originating from the DNS hoster) to KSregistry’s SRS via EPP. This way it will be possible for the relying party to validate DNS queries and to protect from DNS tampering to a certain degree.

DNSSEC is a set of records and protocol modifications that provide authentication of the signer of the DNS data, verification of integrity of the DNS data against modification, non-repudiation of DNS data that have been signed, and authenticated denial of existence of DNS records. DNS data secured with DNSSEC are cryptographically signed and incorporate asymmetric cryptography in the DNS hierarchy, whereby trust follows the same chain as the DNS tree, meaning that trust originates from the root and is delegated in the same way as the control of a domain. When a domain name in the .immo gTLD is requested by a browser, the signature is validated with the public key stored in the parent zone.


F. Promoting Accurate WHOIS Data

The Applicant is committed to maintaining the .immo gTLD space as a safe, secure online environment. A key component of such a plan is the creation and upkeep of accurate WHOIS records for the registry. As indicated in detail in the above answer to Question 26, the Applicant will develop strong safeguards to verify the accuracy and privacy of the data stored in the WHOIS database, and will ensure that such records will be publicly-available to the extent required by ICANN regulations.

The WHOIS records for the .immo gTLD will constitute a “thick” WHOIS, combining all applicable data and information for domain name registrants in a central location. The individual registrars offering .immo domain names will be responsible, under the terms of the Registry-Registrar Agreement, for providing and promptly updating the WHOIS database with current, accurate and complete information. The Registry Service Provider will be responsible for monitoring such information and records to ensure that registrars comply with the contractual agreements to provide accurate data, including the use of field-valid telephone and fax numbers and the use of country names as defined under ISO 3166. The Applicant shall expressly reserve the right to cancel or suspend any domain name registrations within the space should a registrant fail to provide accurate or complete WHOIS information.

At all times, ICANN’s WHOIS Data Problem Reporting System (WDPRS) will be available to anyone wishing to file a complaint regarding the accuracy or sufficiency of WHOIS records within the .immo gTLD.


G. Registrant Authentication

The registrar will be responsible for making sure that only authenticated registration requests will be submitted to the registry, ensuring the accuracy of the WHOIS. Effectively, this will ensure that all WHOIS data is 100% accurate and pre-validated.

The Applicant will accordingly maintain strict control over the registration and use of.immo domain names. Only authorized personnel will be able to release a name from reservation and register it for use through an ICANN-accredited registrar. Likewise, only authorized Company personnel will be able to make DNS changes or alterations to the WHOIS data for the domain names. The Applicant will require multiple unique points of contact to request and⁄or approve update, transfer, and deletion requests, and will require notification of multiple, unique points of contact when a domain has been updated, transferred, or deleted.

These checks will include a clear, written policy detailing the steps by which such corporate authority may initiate the request for a domain name registration in the .immo gTLD. The concerned registrar(s) will have the ability to register domain names in the .immo gTLD only upon receipt of the proper corporate approval. Furthermore, there will be strict policies in place to prevent unauthorized changes to name servers, WHOIS or other DNS information, including registration of third- and higher-level subdomains.

In the event that the Applicant decides to license the use of .immo domain names or subdomains to affiliates, additional levels of corporate approval may be required in order to ensure the proper use of such domain names.


H. Licensed Domain Names

The Applicant may, from time to time and in its sole discretion, elect to license the use of .immo domain names to its affiliates. The Applicant will ensure that any such licensed affiliates will have only a limited license to use the allocated domain name, subject to continuing compliance with all policies in place during that time. Should the Applicant elect to offer such license arrangements, additional corporate approval may be required to ensure internal responsibility for overseeing and enforcing the terms of the license. 
Any licensee(s) must warrant they will not assign the license or sublicense any subdomain without

- securing the sublicenseeʹs agreement to any and all terms required by the Applicant, including the Acceptable Use Policy and all other applicable policies
- obtaining the Applicant’s prior consent in writing


I. Ensuring Proper Access to Domain Functions

The Registry will be operated using a comprehensive and detailed authentication system designed to implement a wide range of registry functions for both internal operations and as external registrar access. Registrar access will be limited by IP address control lists and TLS⁄SSL certificates, as well as verification processes for proper authentication and appropriate limitations to restrict access to the sponsored objects.

Each domain name will be assigned a unique AUTH-INFO code. The AUTH-INFO code is a 6- to 16-character code assigned by the registrar at the time a domain is created and which can be modified by the registrar at any time. Its purpose is to aid in the identification of the domain owner so that proper authority can be established. For example, a registrar-to-registrar transfer can be initiated only by using the correct AUTH-INFO code, to ensure that domain updates (update contact information, transfer, or deletion) are undertaken by the authorized registrant. Access to the domain’s AUTH-INFO code, stored in the registry, is limited to the sponsoring registrar and is accessible only via encrypted, password-protected channels.

Further security measures are anticipated and will be implemented in the new space, but are currently treated as confidential for security reasons. Accordingly, a full explanation of these mechanisms may be found in the response to Question 30(b).


J. References and Attachments

http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf

Question 29: Rights Protections Mechanisms

AS ICANN NOW INFORMS US, CERTAIN BRACKET-SYMBOLS (ʺ〈ʺ and ʺ〉ʺ) CONTAINED IN THIS ANSWER CANNOT BE PROPERLY DISPLAYED IN TAS. THE FULL ANSWER TO THIS QUESTION IS THEREFORE ATTACHED AGAIN AS A PDF FILE, AS ADVISED BY ICANN TO ENSURE PROPER READABILITY CAN BE SAFELY MAINTAINED. THE TEXT VERSION BELOW IS LEFT FOR REFERENCE ONLY, PLEASE REFER TO THE PDF FOR THE CORRECTLY FORMATED ANSWER.

Rights holder protection is a core element of STARTING DOT’s (subsequently “the Applicant”) approach to the management of new TLD spaces. We have built our comprehensive rights-protection plan by carefully reviewing the many mechanisms developed during the launch of other recently introduced and already established TLDs in order to learn from previous experience and find innovative solutions to certain common issues. Our outsourced registry service provider, KSregistry GmbH, will comply with all required management and gateway mechanisms needed for the .immo new gTLD. Thus, the outsourced registry service provider and the Applicant will jointly undertake the following actions:

- Implement appropriate registration enforcement mechanisms during the various critical phases of the registry launch
- Execute a well-defined Sunrise period in compliance with ICANN requirements, which will include implementation of the Trademark Clearinghouse notification system
- Implement a professional Trademark Claims program, utilizing the Trademark Clearinghouse and drawing upon models of similar programs used successfully in previous TLD launches
- Enlist a third party Trademark validation service, as necessary, during the Sunrise period in conjunction with using the Trademark Clearinghouse
- Commit to operating the URS (Universal Rapid Suspension) Policy as described in the draft Registry Agreement
- Commit to operating and implementing the UDRP (Uniform Domain Name Dispute Resolution Policy) when and as needed in our capacity as the Registry Service Provider for the space
- Comply with the new Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
- Comply, as a named party, with findings issued in any Trademark Post-Delegation Dispute Resolution Procedures (PDDRP)
- Embed all rights protection elements that require compliance support or involvement with Registrars and⁄or their resellers into the Registry-Registrar Accreditation Agreement for all domains of the .immo new gTLD
- Ensure the inclusion of all ICANN-mandated and TLD-specific rights-protection mechanisms in the Registry-Registrar Agreement entered into by ICANN-accredited registrars authorized to register names in the .immo gTLD, including oversight of all provisions to be included in the end-user Registration Agreements in effect as between the registrar and registrants of the .immo gTLD.

The following provides a brief outline of the steps the Registry Service Provider intends to implement in conjunction with the Registry Operator for the proper function of the .immo gTLD.


A. Trademark Clearinghouse

The Trademark Clearinghouse is a new service offering provided for under the ICANN New gTLD program. It will provide a mechanism to notify trademark holders of qualified Sunrise applications for textual strings that present an identical match to their trademarks. The Clearinghouse system will be comprised of the following elements:

- Registration of marks in the Clearinghouse by trademark holders will be validated by the Clearinghouse operator, utilizing trademark filings and other rights as applicable under the established policies for the Trademark Clearinghouse
- An asynchronous comparison of marks submitted during Sunrise with the Trademark Clearinghouse
- Should an exact match be identified between an applied-for textual string and a mark registered in the Clearinghouse database, notification will be provided to the relevant mark holder and the Sunrise applicant in the manner and means specified in the Applicant Guidebook

The Company will comply with all required elements of the Trademark Clearinghouse system, and will utilize a trademark validation agent as necessary to assist with the Sunrise procedure.


B. Sunrise Procedure

B.1 Sunrise Mechanism

The .immo gTLD Sunrise period will be conducted in compliance with ICANN specifications. 

The Applicant will develop a fully compliant Sunrise policy, which will define what domains may be applied for during Sunrise applications and detail all dispute policies, including its SDRP (Sunrise Dispute Resolution Policy), for challenging the validity of Sunrise registration. The elected SDRP dispute provider will be a member of ICANN’s list of approved UDRP providers. The Applicant will consult with both the dispute provider and expert legal counsel in drafting and finalizing the Sunrise Policy.

The Sunrise period will run for a minimum of 30 days prior to the general availability of domain names and will include a minimum two week quiet period. The registration functions will not be available during the quiet period while we work to complete related Trademark Clearinghouse matches and related notifications.


C. Eligible Rights

The proposed Sunrise Eligibility Requirements (SERs) will conform to the following qualifications derived from numerous past TLD Sunrise programs:

C.1 Ownership of a qualifying mark

See Section 7.2, number (i): The registry will recognize and honor all

- Word marks that are nationally or regionally registered and for which proof of use (which can be a declaration and a single specimen of current use) was submitted to, and validated by, the Trademark Clearinghouse
- Trademarks not in the Clearinghouse but that are verified by a third party Trademark validation contractor and conform to the following standards:
 * the Domain Name is identical to the textual or word elements of the trademark or service mark registration on which the registration of the Domain Name is based; AND
 * the trademark or service mark registration on which the registration of the Domain Name is based is of national effect; AND
 * the trademark or service mark registration on which the registration of the Domain Name was based was issued (registered) prior to [a cutoff date to be determined]
- Representation that all provided information is true and correct
- Provision of data sufficient to document rights in the trademark


D. Application Process

All submissions during Sunrise will be accepted as applications only and not a full registration until the Trademark has been validated to conform per the SERs listed above, and the Sunrise applicant has been determined to meet the eligibility requirements for registration in the .immo gTLD. As mentioned above, the name space will follow a open-registrant model. Multiple applications for the same string, were they to occur, would be allowed from multiple Trademark holders. Contention would be resolved through auction were there to be more than one qualifying applicant. Following winning an auction, or if there is a single qualifying applicant, the application would be promoted to a full domain registration.

D.1 Field Submission and Validation Safeguards

To support the Sunrise process the registry system will apply requirements to data submissions, in the registry application. KSregistry will use the data fields⁄extensions from the DotAsia and DotXXX launches. The field types listed below are mandatory during Sunrise submissions and are not able to be updated once an application has been submitted in order to avoid manipulation of the validation process. Please see the related EPP extension 〈Q25_Figure3.pdf〉 attached to the Question 25 response.

〈claimName〉

The word mark of the trademark, as noted in the trademark or service mark registration record.

〈claimNumber〉

The registration number (not the application number) of the trademark.

〈claimRegDate〉

The date the trademark was registered. This is the date that the trademark was granted.

〈claimCountry〉 〈claimRegion〉

The two-letter code for the nation or national jurisdiction the trademark was registered in. Allowable values will be limited to identify national trademark registries and regional trademark registries (such as the Benelux and EU trademark registry registrations).

〈claimEntitlement〉

Whether the applicant (corresponding to the Registrant Contact) holds the trademark as the original “owner,” “co-owner,” or “assignee”.

D.2 Trademark Validation and Safeguards

As mentioned previously we will employ a third party Trademark validator to examine Sunrise applications. The Trademark Validator will have the ability to request additional data or clarifying materials about any Sunrise Application, including additional direct verification of the Sunrise applicant’s identity in respect to the cited trademark.

The contracted party will be globally experienced in intellectual property law and will employ the following stepped process and functions:

Examination of Trademark

Trademarks will be validated against either the Trademark Clearinghouse, or against a National Trademark Database from a qualifying country. This is required for a Sunrise application to be considered “qualified or validated”.

Deterrents

In policy documents, training materials, and FAQs, we will communicate clear language indicating that administration fees associated with filing Sunrise applications are NOT refundable. The administration fee will be designed to recover validation costs and should financially dissuade frivolous applications.

D.3 Contending Applications, Sunrise Auctions

The Registry will complete all Sunrise application validations following the close of the Sunrise period. There are only three possibilities for outcome and subsequent actions:

- One valid application for a given string:
 * The domain will be awarded to that applicant
- Two or more valid applications for the same string:
 * The domain will be offered to the applicants at auction. The highest bidder will be awarded the domain.
- No valid applicants for a given string:
 * The domain will be offered in subsequent phases of the Registry but without Trademark requirements.

D.4 Additional Considerations

Sunrise auctions may take some time to conduct and likely will run over other later phases such as Landrush. In the event no applicant bids at auction, the first valid application received will be awarded the domain.

Domains awarded under Sunrise will be locked (Sunrise lock status) for at least 60 days following the procedure to support parties wishing to file a Sunrise Challenge.

Once a Sunrise domain is awarded, it will be promoted to a full registration and the relevant RDDS (WHOIS) data will be published as per standard Registry RDDS (WHOIS) policy.

Conflict of Interest restrictions will be applied to employees, contractors, consultants and significant investors of the Registry disallowing participation in Sunrise auctions. See also the answer to Question 28.


E. Sunrise Challenges

The Sunrise Dispute Resolution Process (SDRP) will allow challenges based on the following four grounds:

1. at the time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect
2. the domain name is not identical to the mark on which the registrant based its Sunrise registration
3. the trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect)
4. the trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not applied for on or before ICANN announced the applications received

We see that ICANN’s Module 4, “Trademark Clearinghouse” document, paragraph 6.2.5 says “The Clearinghouse will maintain the SERs, validate and authenticate marks, as applicable, and hear challenges.” We are not sure exactly what “hearing challenges” means. If it means that the Clearinghouse Provider is the only party that can adjudicate Sunrise Challenges, then of course the .immo gTLDʹs Sunrise Challenges will go there to be heard. Otherwise, we will retain the services of a well-known dispute resolution provider such as WIPO to receive and adjudicate the Sunrise Challenges. All applicants and registrars will be contractually obligated to follow the decisions handed down by the dispute resolution provider.

After any Sunrise name is awarded to an applicant, it will remain under a “Sunrise Lock” status for at least 60 days so that parties will have an opportunity to file Sunrise Challenges. During this Sunrise Lock period the domain name will not resolve and cannot be modified, transferred, or deleted by the sponsoring registrar. The domain name will be unlocked at the end of that lock period only if it is not the subject of a Sunrise Challenge. Challenged domains will remain locked until the dispute resolution provider has issued a decision, which the registry operator will promptly execute.


F. Continuing Rights Protection Mechanisms in the Specific TLD Space

Following the conclusion of the Sunrise period for the .immo gTLD, certain rights protection mechanisms will continue to be active. These mechanisms are the dispute resolution policies, which shall include the URS, UDRP, Trademark PDDRP, a Trademark Claims service and any other policies ICANN may enact from time to time via the adoption of Consensus Policies.

F.1 Uniform Rapid Suspension (URS)

The registry operator will implement decisions rendered under the URS on an ongoing basis.

As per the URS policy, STARTING DOT will receive notice of URS actions from ICANN-approved URS providers. These e-mails will be directed immediately to our support staff, which is on duty 24 x 7 x 365. The support staff will be responsible for executing the directives from the URS Provider, and all support staff will receive training in the proper procedures.

As per ICANN’s URS guidelines, within 24 hours of receipt of the Notice of Complaint from the URS Provider, our staff will lock the domain, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will continue to resolve. The support staff will accomplish this by associating the following EPP statuses with the domains and relevant contact objects:

- ServerDeleteProhibited, with an EPP reason code of “URS”
- ServerTransferProhibited, with an EPP reason code of “URS”
- ServerUpdateProhibited, with an EPP reason code of “URS”

Our support staff will then notify the URS Provider via e-mail immediately upon locking the domain name.

Our support staff will retain all copies of the e-mails from the URS providers. We will assign each case or order a tracking or ticket number. We will use this to track the status of each opened URS case through to resolution via a database.

Our support staff will then execute further operations upon notice from the URS providers. Each URS provider is required to specify the remedy and required actions of the registry operator, with notification to the registrant, the Complainant, and the Registrar. We will set up the necessary DNS re-pointing required by the URS guidelines.

The guidelines state that if the Complainant prevails, the “registry operator shall suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original web site. The nameservers shall be redirected to an informational web page provided by the URS Provider about the URS. The WHOIS for the domain name shall continue to display all of the information of the original Registrant except for the redirection of the nameservers. In addition, the WHOIS shall reflect that the domain name will not be able to be transferred, deleted or modified for the life of the registration.”

F.2 Uniform Dispute Resolution Policy (UDRP)

Although UDRP actions are typically implemented at the Registrar level, it’s conceivable that a court order may be directed to the Registry through the APOC. Such an order would be escalated to the support and⁄or legal department contacts as required. Support staff would quickly affect a mandated transfer, if so ordered, or an order requiring the lock-down of a domain name. The Registry’s legal counsel would also typically verify the court order. Registry functionality outlined in the answer to Question 27 describes the necessary functionality required by Registrars to support their UDRP commitments, and the Applicant is committed to meeting these standards.

F.3 Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP)

The Applicant would be the defending party in a Trademark PDDRP. The Applicant commits to abiding by the directives of the Trademark PDDRP Provider assigned by ICANN, up to and including the cessation of all registration activities and cancellation of the Registry Agreement with ICANN.

F.4 Trademark Claims Service:

For at least the first 60 days of general registration, the Applicant will enable a Trademark Claims service for trademarks recorded in the Trademark Clearinghouse, which will provide a real-time notice to a party attempting to register a domain name if it matches a trademark in the Clearinghouse and notify trademark holders when domain names are registered that match marks in the Clearinghouse.

G. Contractual Operation of Provision via the Registry-Registrar Agreement

The Registry-Registrar Agreement will be signed by all registrars interested in offering registrations under the .immo gTLD. This agreement will contractually bind such registrars to follow certain registry-mandated procedures, and will include inter alia the following provisions:

- The registrar will ensure that the relevant Registrar-Registration Agreements between itself and any prospective registrant in the TLD space will incorporate all registry-mandated policies, restrictions, and guidelines
- The registrar will comply with all eligibility and registration restriction criteria established by the registry in issuing registrations within the .immo gTLD. The registrar shall not register a domain name to an individual or entity who does not meet the eligibility criteria for registration within the TLD
- The registry shall have the authority to refuse or reject any registration request received for a domain name within the TLDʹs space, or to cancel, transfer, delete, suspend, revoke, or otherwise modify a registration within the space, for the following reasons:
 * The domain name was registered through a registrar error or oversight, the provision of inaccurate data, fraud, or mistake, and the registrant is determined to be ineligible to register domain names within the TLD
 * The request for registration was not made in the proper format, did not contain sufficient information under ICANN and⁄or registry requirements, or such information was not properly updated as required by ICANN and⁄or registry requirements
 * In order to rectify or correct any mistake or error made by the registry or registrar in the registration of the domain name
 * In order to comply with any request received from law enforcement, a court order, arbitral panel decision, appropriate dispute resolution provider, or to comply with any applicable laws or regulations
 * For the purpose of protecting the stability, safety and integrity of the registry, the TLD infrastructure, or the stability of the DNS
 * In order to avoid any civil or criminal liability on the party of the registry, its affiliates, subsidiaries, officers, directors, representatives, employees, contractors, and stockholders
 * In order to establish, assert or defend the rights of the registry or any third party
 * For any other reason provided for in either the Registry-Registrar Agreement or the Registrar-Registrant Agreement.


H. Preventative Safeguards

The Applicant will implement several additional mechanisms to prevent misuse of the TLD space, including the introduction of best practices, standards, and a comprehensive monitoring system.

H.1 Best Practices - Reducing Opportunities for Behaviors such as Phishing or Pharming

The extensive mark requirements and trademark validation procedures during the Sunrise phase will prevent the registration of effective phishing domains during the start-up period.

In our answer to Question 28 (“Abuse Prevention and Mitigation”) above, we described our strong anti-abuse program, which is proven to shut down phishing and pharming and has provisions for rapid takedown of domain name abuses. The system prompts notification of relevant registrars for rapid take-down action should phishing activity be identified. Please see the full explanation of this system above under Question #28.

This program will deter bad actors from operating within the space by reducing the effectiveness of their attempts to initiate phishing domains, without infringing upon the rights of legitimate registrants. Since pharming is commonly accomplished by redirecting traffic at the recursive DNS level, mitigation is effective at the ISP level.

H.2 Monitoring of the Success of Abuse Prevention Programs

Every six months, the Anti-Phishing Working Group (APWG) publishes its latest Global Phishing Survey, which is made publicly available on the Group’s website. This study contains an analysis of phishing per TLD. The Applicant will review the performance of our anti-abuse program by using the APWG reports and other metrics developed within the security community. The Applicant notes that, according the APWG’s available data for 2011, only around 12% of malicious phishing sites contained a brand name (or misspelled variant) in the relevant domain name, and that in the 2010-2011 data only 5,700 brand-targeted phishing sites were known worldwide. Accordingly, phishing represents a very small percentage of brand-targeted domain name registrations, and the Applicant believes its adopted best practices and restrictive registration policies will mitigate the risk of bad actors entering the TLD space.

H.3 Ongoing Rights Protection Resources

The maintenance of the new TLD space and the ongoing monitoring and RPM mechanisms will require dedicated resources and staff from both the registry service provider and the Registry Operator. KSregistry maintains a team of experts dedicated to these procedures, which draws from a wide pool of experience and includes engineers, developers, security, and enforcement personnel. The Applicant additionally has in place state-of-the-art technical equipment and software systems, and is capable of implementing the proposed mechanisms.

STARTING DOT likewise is fully staffed and ready to undertake the procedures outlined in this application and maintains a dedicated team for the oversight and management of the .immo new gTLD, consisting of a Customer Support Team of three employees (1 manager and 2 assistants), dedicated to the whole portfolio of TLDs of STARTING DOT.

Question 30 (a) - Security Policy

KSregistry GmbH, as the registry backend provider of the KSregistry system (KSR), attaches great importance to the security of the entire registry infrastructure as well as business and customer data. Having more than ten years of experience in the domain business, Key-Systems has imparted extensive expertise about threats, possible vulnerabilities, and suitable countermeasures to its new subsidiary KSregistry GmbH. In case of an attack, the entire staff working on the KSR is trained to react quickly to any security issue that may arise. Distinct escalation plans with clear roles for each employee at KSregistry GmbH are defined for any possible incident. All team members have access to these plans at any time, according to their security clearance and role.

These plans and security rules are subject to a regular audit schedule and are documented in KSregistry GmbHʹs security policy, which includes the Registry Information Security Policy that covers the basic registry services. These services include, but are not limited to, the safety of the technical backend (covering items such as EPP and RDDS, DNS and DNSSEC policies, an ESCROW policy, SFTP, etc.).


A. Security Policy

KSregistry GmbH has established a security policy that contains the complete Registry Service Policy, covering the basic registry services. The Registry Service Policy is complimented by policies regarding technical, organizational, and personnel issues for:

- Network structure
- Network and system access
- Wireless networks
- Malware
- Setup of servers and client systems
- System and software updates
- Firewall and IDS
- Removable media
- DNSSEC
- Backups and ESCROW
- Physical Security
- Emergencies and Monitoring
- Continuity

Additional policies cover the behavior of employees concerning passwords, remote access, general communication and allowed tools and describe the handling of general procedures, audits, maintenance and monitoring. These policies are described in detail and attached to AGB question 30b. 

The security policy drafted by KSregistry GmbH is based on an extensive threat analysis and is thus tailored closely to the registry services. The introductory investigation of both common and rare security issues to the registry service and to the business in general is accompanied by examples with representative solutions and references to the corresponding policies. 

Based on the analysis, certain notable aspects of the policy, as determined by the threat analysis, are (a more complete description of the policy is detailed in answer 30b):

- To prevent unauthorized access to internal and external services as well as data of all possible security levels, all employees are only provided with the access rights needed for their assigned role and obliged to follow a strict policy regarding the strength, the periodical change and the storage of their password. Updates or new software installations can not be deployed by engineers themselves but must be managed by the change manager, who reviews the quality management reports and determines deployment procedures
- The administration is also split into different roles to prevent too much access being given to one single point. Access to servers is only possible with individual user rights, there are no superuser logins. All actions on the servers are logged and monitored. All servers are secured against external manipulation by physical separation and limitation to internal IP addresses as far as possible. The network is also separated into different layers depending on each layerʹs function and security level with each layer having its own security measures installed, including firewalls that check every request traveling from one layer to another
- The object data stored by KSregistry GmbH is secured in several, geographically distributed data centers with high security standards and which are constantly being backed up to prevent the danger of data loss and to guarantee continuity
- Denial of Service attacks are countered by measures appropriate to the target within the infrastructure. The DNS infrastructure of KSregistry GmbH is widespread and reliable to withstand attacks and is additionally secured against manipulation by DNSSEC. Attacks against other services are immediately identified by the Intrusion Detection System and repelled by the firewall and its corresponding rules
- Authorized registrars connect to services offered by KSregistry GmbH via encrypted communication. The EPP gateway can be only used with SSL or TSL and an additional check is made for correct authorization credentials for each connection. Each writing operation is logged which allows the reconstruction of every past transaction
- The registrarsʹ frequency of usage of the non-public services is generally monitored to prevent flooding and to guarantee reliable and stable services for all other registrars
- All software used by KSregistry GmbH, both developed in-house and acquired from third-party providers, is not deployed until it has been intensely tested by the quality management team. All registry systems, both hardware and software, are under constant monitoring from at least two different locations, and quick reaction times from the Administration Team, the ERT and the engineers are guaranteed 24 X 7 with defined emergency plans and procedures for all kinds of security issues or misbehavior of any component of the infrastructure. The monitoring is fully redundant on system and network level with different software solutions being used to additionally eliminate possible malfunction. Two leading enterprise monitoring solutions are used with the services running on separate hardware. All checks within the monitoring are continuously optimized by engineers and administrators, especially after software updates which are followed by determined check reviews

Regular audits of policies and procedures ensure a steady state of preparation for the entire team and allow for fast and appropriate escalation procedures. In case of an emergency incident, the administration will be very quickly mobilized by the monitoring and then follow the defined emergency procedures by either solving the problem immediately or activating the responsible roles within the company. Procedures and guidelines for any possible incident have been defined from the preceding threat analysis and describe:

- all required steps such as data restoration from backups or fail over to a secondary data center;
- the affected, involved, and responsible roles; and
- the necessary details for the concluding report

After the incident, the involved team members file an accurate report which they forward to the role responsible for the corresponding policies, who then checks the policies for complete coverage. The policies then undergo a review by the responsible team members and the Chief Security Officer (CSO) of KSregistry GmbH to determine necessary changes based on the report. In case of changes, the CSO is responsible for a final review and the supervision of the policy revisions. Policy reviews are also triggered prior to software updates, the introduction or change of processes, or changes to the infrastructure in general. This procedure guarantees that the policies are continuously up to date and that their coverage is complete. 

The beginning and end of employment of a team member also follow defined routines especially the assignation and termination of access rights, respectively. Each policy contains strict rules for enforcement and the measures taken in case of policy violation. The CSO of KSregistry GmbH holds the general responsibility for policy compliance. The security policy describes additional responsibilities of certain roles and the corresponding policies and lists all affected roles within the company. 

The KSregistry GmbH develops these policies alongside the ISO⁄IEC 27001 requirements, accompanied by the code of practice given in the ISO⁄IEC 27002 (source: http:⁄⁄www.iso.org⁄iso⁄catalogue_detail?csnumber=42103). More details can be found in section B. The backup strategy is a TIER 4 strategy following the best practice guide by IBM redBooks (source: http:⁄⁄www.redbooks.ibm.com⁄abstracts⁄tips0340.html?Open).


B. Independent Assessment

As a merchant using credit card payment systems, KSregistry GmbH is obligated to meet the requirements defined by the Payment Card Industry Data Security Standard (PCIDSS). Validation of compliance is done annually by an externally Qualified Security Assessor. For KSregistry GmbH this validation is provided by the IT security experts from Acertigo AG located in Stuttgart, Germany. Security requirements of the standard are reviewed using a Self Assessment Questionnaire covering the following control objectives: build and maintain a secure network, protect cardholder data, maintain a vulnerability management program, implement strong access control measures, regularly monitor and test networks, and maintain an information security policy. The review of the questionnaire is accompanied by vulnerability scans for all systems which are also carried out by Acertigo quarterly. The resulting reports document a constant security level and certify compliance to the PCIDSS standard, thereby also meeting the security requirements for the registry services. 

The PCI security scans facilitate the identification of vulnerabilities and misconfigurations of web sites and all infrastructures with public services including, for example, mailservers and internet access for employees. Acertigo determines active IP addresses and services by probing a complete list of external IP addresses relevant to the PCIDSS (provided by KSregistry GmbH) and also ensures that only services intended for external use are accessible. The list includes web, application, and mail servers, as well as domain name servers and virtual hosts. Acertigo also scans for open IP addresses outside the scope given by KSregistry GmbH to ensure the integrity of the scans. The IDS of the KSR is configured to allow access to all systems for the IP addresses from which the scans originate.

Since the introduction of the PCIDSS, KSregistry GmbH has constantly been compliant to the standard. The quarterly scan reports are reviewed by KSregistry GmbH administrators and the chief security officer and necessary measures are taken immediately. In addition to the benefits for the security of KSregistry GmbHʹs proprietary software, the scans also help to keep third-party software up to date and add another level of malware detection to the already established detection system.

While its policies already cover a part of the ISO⁄IEC 27001 standard and are are compliant to it, the KSregistry GmbH is also working towards an official certification. This implies the implementation of an Information Security Management System (ISMS) compliant to ISO⁄IEC 27001 and includes changes to and extensions of the security policies and procedures. Part of the requirements of the ISMS are periodic internal audits which will be executed by the ʹsafe and secure systems – evaluation and verificationʹ department of the DFKI GmbH (the German Research Center for Artificial Intelligence), the leading German AI research institute and an officially approved ISO⁄IEC 27001 auditor. The DFKI GmbH will also certificate the complete compliance to ISO⁄IEC 27001 until the end of 2012 and subsequently provide periodical assessment reports.


C. Commitments

KSregistry GmbH, the registry backend technology provider for the domain registrar Key-Systems, benefits from Key-Systemsʹ more than ten years of experience in the domain business and its associated processes (with some team members working even longer in this field). As an ICANN accredited registrar and member in several work groups and technical boards representing a range of registries, Key-Systems is developing all systems in keeping with the requirements of registrars, registrants, and brandowners worldwide. 

These requirements are covered by our security policy in general and are implemented in certain policies as our registry service policy or other specifically mentioned policies. The customers of KSregistry GmbH can rely on:

- Secure storage and handling of confidential customer data, with clearly defined access rules for virtual access in our “Network and System Access Policy” and physical access in our “Physical Security Policy”
- All objects are stored in one secured, central registry database as KSregistry GmbH supports a thick registry system
- A reliable and widespread DNS system, additionally secured by DNSSEC with its rules being defined in our “DNSSEC Policy”
- Secure communication from the registrants, over the registrars to the registry
- A guarantee that no changes to the registry technology will be made if these changes bear a risk of malfunction, as described in our specific “System and Software Update Policy”

KSregistry GmbH will also enforce the policies distributed on all levels of usage of the registry system. The complete staff is trained and audited in every policy the team member is affected by and constantly aware of the great importance of a secure system.

The registry operator is obligated to inform the registrars about all important agreements, general terms and conditions, events and notifications, and must also include these in its own registration agreement that is passed to the registrants. KSregistry GmbHʹs extensive documentation of the registry system interfaces such as EPP is provided as white-label and can be forwarded from the registry to registrars or even registrants if desired.

Accredited registrars should nominate persons who are authorized to contact the KSregistry GmbH 24⁄7 support in urgent emergency cases. These individuals have to prove their identity with a previously agreed passphrase. It is the registrars responsibility to provide support for their registrants and to decide if support requests have to be escalated to the registry at any time benefiting from KSregistry GmbHs Support described above.


D. gTLD Specific

KSregistry GmbH guarantees a high level of security that is also reviewed and refined on a regular basis. The security policies and procedures comply with the general requirements of a technical registry operator with no need for deviation for the .immo gTLD . If any changes to the description of the .immo gTLD should occur in the future, KSregistry GmbH is able to rapidly adapt new policies and procedures as required.


E. Resources and Roles

E.1 Trusted Roles

Key-Systems GmbH has gathered experience in various roles in the domain business for more than ten years and has access to extensive knowledge in the domain business. This deep industry knowledge and experience has also been transferred to KSregistry GmbH, the technical provider of the KSregistry system (KSR) and is evident in many trusted persons serving in different roles throughout the company.

All employees, contractors, and consultants that have access to or control of the KSregistry system are regarded as trusted persons.

The following Trusted Roles are used for managing the KSR solution:

- Security Role: Chief Security Officer (CSO)
- Designated Engineering Role
- System Administration Role
- Security Administrator Role 
- DNS⁄DNSSEC Role
- Operational Role
- Support Role
- Quality Management Role
- Change Management ⁄ Project Management Role 
- Financial ⁄ Controlling Role
- Legal Role

Each role is staffed with multiple human resources for backup and capacity purposes.

Prior to employment in a Trusted Role, KSregistry GmbH performs the following background checks on a prospective candidate:

- Criminal Records Bureau check
- Verification of previous employment
- Check of professional references

Complete role descriptions are given in the security policy in answer 30b.

E.2 Project Resources

The table in fig. Q30a_Figure1.pdf shows how the roles described above are planned for the SRS system. All resources at KSR are dedicated to the registry business. The calculations differ between the project phase and the years after the operational start. The project phase requires more resources as there is much planning, managing, and development required. All resources are engaged in the domain industry only and are experts in their field.

However, as the resources are shared among the TLDs operated through KSR and are not dedicated exclusively to one SRS project, the columns in the attached figure contain the number of human resources available for this role and the percentage of time those people are working for this specific string. This percentage is the guaranteed time the resources are allocated to each SRS project.


F. List of attachments

- Q30a_Figure1.pdf