Application number: 1-1007-20096 for Safety Registry Services, LLS

Safety Registry Services, LLS

100 Grainger Parkway
Lake Forest 60045
US

+1 847 535 1000

+1 847 535 0878

Mr. Philip Lodico

Managing Partner

+1 202 223 9252

lodico.sf@fairwindspartners.com

Ms. Aimee Nolan

Associate General Counsel

+1 847 535 1047

aimee.nolan@grainger.com

Limited Liability Company

Laws of the State of Delaware, US

Not Available

W.W. Grainger, Inc.

Courtney D. Carruthers
President
Debra S. Oler
Vice President
John L. Howard
Vice President, Secretary and General Counsel
Michael L. Howard
Assistant Secretary
Paul C. Miller
Vice President
Paul J. Stanukinas
Assistant Secretary
Philip M. West
Treasurer
Ronald L. Jadin
Vice President

Courtney D. Carruthers
President
Debra S. Oler
Vice President
John L. Howard
Vice President, Secretary and General Counsel
Michael L. Howard
Assistant Secretary
Paul C. Miller
Vice President
Paul J. Stanukinas
Assistant Secretary
Philip M. West
Treasurer
Ronald L. Jadin
Vice President

W.W. Grainger, Inc.
Not Applicable

SAFETY

Not Available

Safety Registry Services, LLC (“Safety Registry”) foresees no known rendering issues in connection with the proposed .SAFETY gTLD for which it is applying. This answer is based upon consultation with Safety Registry’s selected back-end provider, Neustar, Inc. (“Neustar”), which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, Neustar analyzed the following data:
-ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and Consequences (SAC009);
-IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”;
-Known software issues which Neustar has encountered during the last decade launching new gTLDs;
-Character type and length;
-ICANN supplemental notes to Question 16; and
-ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance.

18.1.1 Mission and Purpose of .SAFETY
The content of this Answer to Question 18 set forth below which describes the plans for the Applicant’s registry constitutes the “purpose” of the registry as that term is used in Paragraph 1.b. of Specification 9 of the Draft New gTLD Registry Agreement found in Module 5 of the Applicant Guidebook dated January 11, 2012 (the “Purpose”). This .SAFETY gTLD will be brought to market by Safety Registry Services, LLC (“Safety Registryʺ) a wholly owned subsidiary of W.W. Grainger, Inc. (“Grainger”).

The intended mission and purpose of .SAFETY is to serve as a trusted, hierarchical, intuitive namespace for a network of customers, potential customers, corporations, first responders, experts, and other service organizations to interact with peers, and have access to authoritative content, and generally needed and valuable safety information. In furtherance of this goal, Safety Registry aims to publish a Charter and all associated policies, guidelines, and other supporting documentation related to the implementation of the registry consistent with the Purpose, all prior to launch. All second-level domain names registered by Safety Registry on behalf of itself or a parent⁄affiliate will be registered through an ICANN-accredited registrar and will be consistent with the Purpose.

18.1.2 Grainger’s Commitment to Safety
As the largest distributor of safety products in North America, Grainger understands the safety needs of companies and organizations operating facilities safely and helping keep employees safe. Grainger helps them achieve their facility and people-related safety goals by providing products⁄solutions that help to maintain regulatory compliance and reduce the of fines; improve facility safety and reduce accident⁄injury rates; and decrease operating costs such as worker compensation, litigation, and lost productivity. Grainger does this through its 50,000+ safety SKUs in many different safety categories like PPE, First Aid, and Workplace⁄Environmental⁄Public Safety as well as its services capabilities that include safety program management, safety training, customizing of safety products, and managing of safety inventory.

There are a number of Grainger resources that companies and organizations are able to utilize to support their safety efforts such as the online Safety catalog; Strategic Alliances with Safety Product Manufacturers; On the Job Webinar Series; Safety Specialists to answer safety questions; and Quick Tips on key safety topics and issues. Grainger is also a member of some of the leading associations in safety, such as NSC and ASSE, and regularly participates in their tradeshows and conferences.

Grainger has a long history of supporting and serving community organizations through its philanthropy. It has been recognized by the U.S. Chamber of Commerce for its leadership in partnering with the American Red Cross to recruit and train volunteers from the business community to respond to disasters. Grainger is the national founding sponsor of the Ready When the Time Comes disaster volunteer program in the U.S. and Canada. Graingerʹs strong commitment to community safety is evident in its ongoing service and partnership in emergency preparedness with a spectrum of corporate, not-for-profit, and government organizations.

18.1.3 Potential Business Model
Safety Registry does not intend to apply for a community designation under ICANN’s Applicant Guidebook criteria, however, it is committed to operating .SAFETY with a relatively narrow Charter and focus.

Depending upon the reception of .SAFETY, Safety Registry envisions the creation of a Safety Network that could serve as an independent membership organization. Membership in the Safety Network could be a prerequisite to being eligible to register a .SAFETY domain name. While Grainger intends to commit to the initial funding and launch of .SAFETY, it views this future creation of the Safety Network as an important step in the long-term independence, viability, and credibility of .SAFETY. Through the Safety Network, Safety Registry aims to vet the potential registrant pool to ensure that .SAFETY will be a trusted and authoritative namespace of safety-related information, including guidelines and requirements. As currently planned, all members of the Safety Network will also be bound by the Charter, and will be required to abide by the rules and standards set forth in order to maintain registration rights of a .SAFETY domain. Eligible entities may include, but are not limited to the following:

Manufacturers⁄resellers of safety products (even if they are competitors of Grainger)
Public safety departments
Fire departments
Educational institutions
Hospitals
Non-governmental organizations

18.1.4 Registry Launch Phases
To facilitate the strategic and sustainable development of .SAFET, Safety Registry currently envisions a three-stage rollout:

Stage 1
This initial stage will likely involve Safety Registry reserving ICANN and GAC required reserved domain names along with a limited number of second-level domain names for future registry use. In addition, Safety Registry would register a limited number of generic second-level domain names to develop information portals to begin to seed the registry with relevant content in order to attract traffic.

During this initial phase, Safety Registry, with support from Grainger’s IT personnel, plans to run a number of tests to ensure seamless and more secure access to .SAFETY websites, and interoperability with various software and Web-based applications. The registration and use of these domain names are intended to be within the scope of Section 1B of Specification 9, regarding the maintenance, operation, and purpose of the gTLD.

Stage 2
Once all testing has been successfully completed, select partners meeting the Charter⁄ membership requirements mentioned above will likely be eligible to register .SAFETY domain names. This may include, but is not limited to, government agencies, NGOs, and other service organizations with a dedicated mission and leading presence in the safety industry, such as Occupational Safety and Health Administration (OSHA), National Institute for Occupational Safety and Health (NIOSH), The Red Cross, and International Organization for Standardization (ISO), key universities in the safety arena, and other national and international organizations of similar stature.

Depending upon the reception of .SAFETY within the safety community, Safety Registry will begin evaluating the creation of the independent Safety Network discussed above. In undertaking this analysis, Safety Registry endeavors to enlist the support of Grainger and the current registrants within the gTLD.

Stage 3
Based on experiences gained through the first stages of operation and the analysis undertaken in Stage 2, Safety Registry intends to either retain its role as a trustee of the .SAFETY Charter, or it will transition this governance aspect of the registryʹs operation to the Safety Network. Either way, Safety Registry is presently committed to the future expansion of the namespace for the benefit of the safety community. It is currently anticipated that any creation or transition of rights to the Safety Network would not take place until after the third year of operation.

Depending upon the decision following the analysis referenced above, there are a number of potential funding options to ensure the continued secure and stable operation of the .SAFETY registry including, but not limited to: dues from the Safety Network to fund the registry on a cost recovery basis; an additional funding from Grainger, or a combination of both. Notwithstanding any potential expanded use of .SAFETY, Safety Registry currently anticipates implementing a throttle mechanism to ensure that any expansion is controlled and responsible. This mechanism is explained in more detail in the response to Questions 46.

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

Safety Registry believes that the proposed .SAFETY gTLD has the potential to offer the following benefits to Internet users, customers, and potential customers:

1) Establish a leading source of information and an online marketplace for the millions of Internet users, businesses, governments, and others that consume, rely upon, and interact with safety information as well as safety-related products and services on the Internet;

2) Provide short and memorable domain names for the provision of relevant safety content to the Internet population. The domains may facilitate the ease by which customers and potential customers can locate critical information or products online;

3) Potentially minimize the social costs and harm to Internet users by reducing incidents of phishing and malware often associated with mistypes of domain names in the .COM space;

4) Potentially minimize the social costs and harm to customers by giving them access to safety-related information and products via a trusted and reputable namespace in .SAFETY.

5) Incorporate enhanced intellectual property rights protection mechanisms (RPMs), specifically an additional safeguard to enhance the chances that any initial reserved⁄allocated names for use by Safety Registry that are in connection with the management and operations of the gTLD do not violate any potential third-party rights.

6) The incorporation of Registrant Eligibility (i.e., who is eligible to register domain names within the .SAFETY gTLD); Name Selection Criteria (i.e., ensuring that the domain name corresponds to a trademark, service mark, or business name); and Authorized Usage policies that will be established in accordance with the .SAFETY Charter prior to launch.

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

Through the .SAFETY gTLD, Safety Registry intends to develop a leading online resource that will provide Internet users, customers, potential customers, corporations, and first responders with the framework to access and interact with experts and peers, relevant content, and generally needed and valuable safety information.

Safety Registry will also ideally be able to provide access to safety-related products and online content in a gTLD that aims to minimize piracy, cybersquatting, and other malicious activities. Providing customers and potential customers with a more secure online arena is of paramount importance to Safety Registry and Grainger, and the .SAFETY gTLD will be used to further that goal.

Safety Registry is driven by the same core values as its parent company, Grainger, and it plans to leverage this experience to bring a spirit of public service to the .SAFETY gTLD.

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

Unlike most generic gTLDs that ICANN has approved over the last decade, which have largely been operated by Internet startups, Safety Registry’s parent company, Grainger, is an established global company with the ability to leverage its existing network of businesses, partners, and customers in the safety space to increase the profile of the .SAFETY gTLD. While most registries have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD, Grainger intends to provide Safety Registry with the ability to leverage its large market share, strong reputation, longstanding commitment to philanthropy, and existing relationships with various organizations and businesses in the safety community to achieve its goals.

While some of ICANN’s new gTLDs have previously been the subject of claims regarding increased spam and phishing activities, from its launch, .SAFETY will aim to be a trusted source of safety-related content, goods, and services for Internet users. Safety Registry looks to follow the established good business practices of its parent company, Grainger, to create a network of sites and information with safeguards designed to minimize fraud and other illegal activity.

As a gTLD dedicated to the safety community, the primary driving factors behind the .SAFETY gTLD application are differentiation and innovation. Today, the Internet is plagued with fraudulent sites, harmful viruses, and misinformation. .SAFETY aims to protect customers and potential customers of safety-related information, services, and products by establishing a trusted network of websites and content related specifically to safety issues, services, and products.

The success of the .SAFETY gTLD will not be measured by the number of domains registered, but rather by the levels of customersʹ and potential customers’ recognition that are placed in the .SAFETY gTLD. Using this benchmark, Safety Registry strives to build recognition and trust through the usage of the .SAFETY gTLD that rise to the level of that found in the .EDU and .GOV gTLDs.

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

Safety Registry envisions that the .SAFETY gTLD can provide a single, more secure ecosystem experience for customers, potential customers, and many organizations worldwide that seek safety-related information, products, and services via existing online, print, mobile, and social platforms. Internet users and the general public will be able to access authoritative safety-related information from trusted sources within the .SAFETY gTLD. By providing the foundation of this trusted ecosystem, domain name registrants in the .SAFETY gTLD will likely be able to share in the benefits of this collective resource.

Through a collection of core generic domain names and geographically designated domain names, the .SAFETY gTLD plans to provide users with a seamless and more secure experience with all related content.

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

In line with the mission stated in 18.1.1 above, Safety Registry plans to initially have safeguards in place to ensure that only approved agencies, organizations, and businesses operating in the safety industry are able to register second-level domain names in the .SAFETY namespace. However, as stated above, Safety Registry reserves the right to extend registration rights to potentially a broader class of registrants.

In addition, Safety Registry intends to provide for three base line policies that will be identified in the Charter and which must be fully designed and implemented prior to the launch of the registry. These policies include: Registrant Eligibility (i.e., who is eligible to register domain names within the .SAFETY gTLD); Name Selection Criteria (i.e., ensuring that the domain name corresponds to a trademark, service mark, or business name); and Authorized Usage policies. These policies are set forth in greater detail in the response to Questions 28, 29, and 30 of this application.

While these are the likely initial policies that Safety Registry will adopt for the operation of the .SAFETY gTLD, it recognizes that minimizing online harm to users of websites within the .SAFETY namespace will require diligence and a continued evolution of the policies. Therefore, Safety Registry is evaluating the potential creation of a policy advisory body that could draw upon a representative composition of the community to recommend best practices.

As noted above, depending upon the reception of the .SAFETY gTLD within the broader community, Safety Registry and Grainger envision the creation of a Safety Network that could serve as an independent membership organization, membership in which could be a prerequisite prior to being eligible to register a .SAFETY domain name. Grainger views this future creation of the Safety Network as an important step in the long term independence, viability, and credibility of the .SAFETY gTLD. If the Safety Network is to be created, the policy advisory board functions may shift to Safety Network.

Safety Registry endeavors to implement all of ICANN’s consensus policies and other Rights Protection Mechanisms (“RPMs”) identified in the Applicant Guidebook. In addition, Safety Registry intends to provide best-in-class safeguards that will evolve over time.

At the time of completing this application, Safety Registry has identified an RPM that will allow trademark owners to challenge domain names initially reserved by the registry (e.g., generic and geographic names identified in Section 18.1.1). This process will likely be modeled after the dotAsia Pioneer Policies adopted by dotAsia in connection with its launch, see http:⁄⁄www.wipo.int⁄amc⁄en⁄domains⁄gtld⁄asia⁄.

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

Safety Registry recognizes that this is an evolving area of law for which there are no international standards. However, due to the fact that domain names within the .SAFETY namespace will be registered to members of the aforementioned Safety Network, Safety Registry has an interest in maintaining accurate and current domain name information, and making it readily available in connection with each .SAFETY domain name.

In addition, Safety Registry intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators. The template Registry Agreement states “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (“Personal Data”) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use Personal Data in a way that is incompatible with the notice provided to registrars.ʺ

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

As noted in 18.2.3, most of the generic gTLDs that ICANN has approved have primarily been operated by Internet startups created solely for the provision of domain name registration services, e.g., .INFO (Afilias), .BIZ (Neustar), and .TRAVEL (Tralliance). Grainger is an established global company with the ability to leverage its extensive network of partners, suppliers, customers, and related websites to establish the .SAFETY gTLD. While most registries have primarily been dependent upon ICANN-accredited registrars to market and promote their gTLD, Safety Registry will leverage current and future relationships both inside and outside of the Safety Network to increase the profile of the .SAFETY gTLD.

Through the initial phases of use, the .SAFETY gTLD will aim to allow Safety Registry to properly and sustainably develop the .SAFETY gTLD in such a manner as to ensure that the .SAFETY gTLD is viewed by Internet users as a trusted source for authoritative information, content, and products related to safety. Moreover, appropriate outreach and communication efforts will likely be done in conjunction with the initial stages of the rollout to market the .SAFETY gTLD to Internet users.

While Safety Registry will initially rely upon Grainger in the initial outreach and communication, the long-term independence, viability, and credibility of the .SAFETY gTLD may rely upon the aforementioned Safety Network to serve as a trustee of the Safety Charter. Moreover, as the registry will likely operate on a cost recovery basis, the members of the Safety Network may consider ensuring that there is a diverse and representative membership to share in this future ongoing operation of the registry.

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

Over the past decade, ICANN has approved fifteen new gTLDs that have historically been classified as either generic (.INFO, .BIZ, .NAME) or sponsored (.ASIA, .COOP, .TRAVEL, .JOBS, etc.) gTLDs. It is anticipated that in this current new gTLD application round, many large international corporations will take the opportunity to register generic strings as top-level domains.

Safety Registry’s plan presented here, which is a new approach to the operation of a gTLD and different from the approach of gTLDs that were approved in the 2001 and 2004 rounds of expansion, removes the risk and uncertainty of prior gTLDs by relying on these defining factors:

-.SAFETY is planned as a gTLD well within the registration range of those having more than a decade of gTLD industry development and experience;
-.SAFETY will rely on an experienced back-end provider; and
-Safety Registry will push to leverage the leading position of its parent company, Grainger, in the safety industry to bring the .SAFETY gTLD to market.

In addition, Safety Registry believes that the safeguards set forth in the Applicant Guidebook and the additional RPM identified in Section 18.2.5 are primary drivers to help minimize potential negative social costs.

Moreover, it is intended that all registrants within this gTLD will comply with the membership criteria established by Safety Registry, and⁄or be a member of the Safety Network if it is created. This requirement will hopefully create a legal obligation of the registrant to comply with all the Charter requirements, including but not limited to Registrant Eligibility, Name Selection Criteria, and Authorized Usage policies. These requirements will aim to establish that only authoritative and trusted organizations and individuals operating within the safety industry are entrusted to register domain names. This operating rule to limit registration will help to establish a more trusted online environment for customers and potential customers to access authoritative safety-related online content, and by default, will minimize social costs. This environment aims to provide customers and potential customers with a single, trusted source for safety-related information, goods, and services with a lower risk of fraud and⁄or scams.

18.3.2 What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

Safety Registry believes that the proposed operation of the .SAFETY gTLD as set forth in this application has no anticipated negative consequences or cost implications to customers or potential customers. To the contrary, the proposed operation of this registry may lead to direct and quantifiable benefits to customers and potential customers.

Due to the restrictive nature of the .SAFETY gTLD, there is no need for other trademark and brand owners to defensively register second-level domains in the .SAFETY gTLD. Safety Registry intends to limit registration to approved entities and individuals operating and involved in the safety industry.

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

If such instances should arise, Safety Registry believes that a phased equitable allocation approach modeled after those that ICANN has previously approved in connection with numerous ICANN Registry Service Evaluation Process (“RSEP”) requests would probably be the most prudent path forward, e.g., RFP, auction, and then first-come, first-serve.

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

Safety Registry does not envision any advantageous pricing, introductory discounts, or bulk registration discounts because these marketing⁄commercial initiatives are inconsistent with the mission and Purpose of the .SAFETY gTLD as a trusted online source identifier.

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

Safety Registry aspires to provide domain name registration services in accordance with the periods set forth in the Registry Agreement and to provide domain name registrants with pricing notice and predictability. However, as noted in the proposed business model (18.1.3), Safety Registry intends to limit domain name registration services to only those registrants that agree with Charter⁄membership requirements. Should a Safety Network be created as envisioned above, membership in this organization would likely be a pre-requisite prior to being able to register in the .SAFETY gTLD. Therefore, failure to comply with these requirements in either scenario would likely result in the suspension and⁄or cancellation of the domain name registration.

Safety Registry acknowledges that the current template Registry Agreement requires that the Registry Operator “shall offer registrars the option to obtain registration periods for one to ten years at the discretion of the registrar.” However, Safety Registry does not plan to offer any refunds should a domain name registration be canceled for non-compliance with the Charter and or other membership criteria.

No

Not Available

No

22 Safety Registry Services, LLC has Properly Researched this Topic

Safety Registry Services, LLC (“Safety Registry”) is keenly aware of the sensitivity of national governments in connection with protecting country and territory identifiers in the DNS. Safety Registry is also very aware of the benefit to customers and potential customers that second-level geographic indicators can have in restricted registries, such as the one that is the subject of this application. In preparation for answering this question, Safety Registry reviewed the following relevant background material regarding the protection of geographic names in the DNS:

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

22.1 Initial Reservation of Country and Territory Names

Safety Registry aims to initially reserve the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and at all other levels within the .SAFETY gTLD at which Safety Registry will provide registrations. Specifically, Safety Registry plans to reserve:

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

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

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

22.2 Fair & Non-Misleading Use of Geographical Identifiers

Safety Registryʹs parent company, W.W. Grainger, Inc. (ʺGraingerʺ), is a leader in the distribution of maintenance, repair, and operating (“MRO”) supplies and related information. Grainger had net sales of nearly $8.1 billion in 2011, and operates with over 700 branches across the globe that serve small to large business customers. Grainger’s products can be purchased worldwide, and Grainger content is accessible in multiple TLDs, including the .COM gTLD and the .CN, .CA, and .MX ccTLDs.

In providing content, products, and services available online, Grainger makes regular use of ccTLDs in providing customers and potential customers with a geographical and intuitive namespace to navigate for relevant content, examples of which include AcklandsGrainger.ca.

Grainger currently operates a number of websites using a combination of second-level and top-level domain names. A representative sampling of Graingerʹs websites that incorporate geographical identifiers into domain names include:

GraingerChina.com
GraingerIndia.com
Grainger.cn
Grainger.com.mx
GraingerMexico.com
GraingerColombia.com
Grainger.ca
GraingerIndonesia.com
Grainger.tw

The above representative list of examples demonstrates fair and non-misleading use of geographical identifiers. As such, Safety Registry believes that the .SAFETY gTLD can provide an online, single source-identifying location for its current and future customers worldwide, as well as enhance and supplement the domain names that Grainger has used in different markets around the globe.

Safety Registry would like to provide a hierarchical and intuitive framework for the .SAFETY namespace by using geographical identifiers in second-level domain names. This use of geographical identifiers to the left of the gTLD and as part of the domain names themselves is believed to have a direct and material impact on search engine algorithms and their corresponding query results. Safety Registry will evaluate if this type of hierarchical and intuitive use of a second-level domain name within a gTLD will provide increased functionality and drive innovation, as premised by ICANN.

22.3 The Legal Protection of Geographical Identifiers

The World Intellectual Property Organization (WIPO) authored an authoritative resource on the current state of the law in connection with the protection of geographical identifiers, its 2001 “Report of the Second WIPO Internet Domain Name Process: The Recognition of Rights and the Use of Names in the Internet Domain Name System” (“WIPO Report”). Section six of the WIPO Report was devoted exclusively to the protection of Geographical Identifiers.

From its analysis of the well established framework against the misuse of geographical identifiers at the international, regional, and national levels, WIPO identified the following two elements for the protection of geographical identifiers: (i) a prohibition of false descriptions of the geographical source of goods; and (ii) a more extensive set of rules prohibiting the misuse of one class of geographical source indicators, known as geographical indications (See WIPO Report Paragraphs 206 and 210). Neither false descriptions of the geographical source of goods, nor misuse of geographical indications, is present in Grainger’s current or Safety Registryʹs proposed use of geographical identifiers.

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

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

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

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

Fair Use of National Geographical Identifiers

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

UK.COOP – Is operated by Co-operatives UK, the national trade body that campaigns for cooperation, and works to promote, develop, and unite cooperative enterprises within the United Kingdom.

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

Fair Use Regional ⁄Local

TEXAS.JOBS – Is operated by a joint effort between DE, the Texas Workforce Commission, and the National Labor Exchange to connect job seekers with approximately 96,000 job openings. An additional domain name operated by this joint effort was WORKINTEXAS-VETERANS.JOBS, a resource devoted to helping Texas veterans translate their military skills to jobs in the civil marketplace.

BOISE.COOP – Is operated by Boise Co-op, a member-owned cooperative founded in 1973 by a few dozen individuals who shared a mutual interest in buying healthy and organic food at reasonable prices.

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

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

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

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

Safety Registry has stated its intention to consider using non-reserved geographic identifiers as part of a hierarchical and intuitive framework in a fair and non-misleading manner to help customers and potential customers navigate the .SAFETY namespace. Safety Registry plans to operate the .SAFETY namespace in a manner that minimizes potential confusion by customers and potential customers, and will actively work with others in the ICANN community regarding any future policy development in this area.

22.6 Potential Future Release of Initially Reserved Names

Safety Registry looks forward to collaborating with other new gTLD Registry Operators in potentially working with ICANN’s GAC to explore potential processes that could result in the release of initially reserved country names (including ISO-3166 two characters). Specifically, Safety Registry is interested in exploring other Registry Service Evaluation Processes (RSEP) that have been filed by existing gTLD Registry Operators in releasing previously reserved domain names.

22.7 Dispute Resolution

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

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

22.8 Creation and Updating the Policies

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

Safety Registry also wishes to continually review and update these lists to prevent the misleading use of geographical identifiers. Consistent with this commitment, Safety Registry intends to be an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.

23.1 Introduction 
Safety Registry Services, LLC (“Safety Registry”) has elected to partner with Neustar, Inc. (“Neustar”) to provide back-end services for the .SAFETY registry. In making this decision, Safety Registry recognized that Neustar already possesses a production-proven registry system that can be quickly deployed and smoothly operated over its robust, flexible, and scalable world-class infrastructure. The existing registry services will be leveraged for the .SAFETY registry. The following section describes the registry services to be provided.
23.2 Standard Technical and Business Components
Neustar will provide the highest level of service while delivering a secure, stable and comprehensive registry platform. Safety Registry will use Neustar’s Registry Services platform to deploy the .SAFETY registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .SAFETY:
Registry-Registrar Shared Registration Service (SRS)
Extensible Provisioning Protocol (EPP)
Domain Name System (DNS)
WHOIS
DNSSEC
Data Escrow
Dissemination of Zone Files using Dynamic Updates
Access to Bulk Zone Files
Dynamic WHOIS Updates
IPv6 Support
Rights Protection Mechanisms
Internationalized Domain Names (IDN)
The following is a description of each of the services:
SRS 
Neustar’s secure and stable SRS is a production-proven, standards-based, highly reliable, and high-performance domain name registration and management system. The SRS includes an EPP interface for receiving data from registrars for the purpose of provisioning and managing domain names and name servers. The response to Question 24 provides specific SRS information. 
EPP
The .SAFETY registry’s back-end technology provider, Neustar, will use the Extensible Provisioning Protocol (EPP) for the provisioning of domain names. The EPP implementation will be fully compliant with all RFCs. Registrars are provided with access via an EPP API and an EPP based Web GUI. With more than 10 gTLD, ccTLD, and private TLDs implementations, Neustar has extensive experience building EPP-based registries. Additional discussion on the EPP approach is presented in the response to Question 25.
DNS
Safety Registry will leverage Neustar’s world-class DNS network of geographically distributed nameserver sites to provide the highest level of DNS service. The service utilizes “Anycast” routing technology, and supports both IPv4 and IPv6. The DNS network is highly proven, and currently provides service to over 20 TLDs and thousands of enterprise companies. Additional information on the DNS solution is presented in the response to Questions 35.
WHOIS
Neustar’s existing standard WHOIS solution will be used for the .SAFETY. The service provides supports for near real-time dynamic updates. The design and construction is agnostic with regard to data display policy and is flexible enough to accommodate any data model. In addition, a searchable WHOIS service that complies with all ICANN requirements will be provided. The following WHOIS options will be provided:
Standard WHOIS (Port 43)
Standard WHOIS (Web)
Searchable WHOIS (Web)
DNSSEC
An RFC compliant DNSSEC implementation will be provided using existing DNSSEC capabilities. Neustar is an experienced provider of DNSSEC services, and currently manages signed zones for three large top level domains: .BIZ, .US, and .CO. Registrars are provided with the ability to submit and manage DS records using EPP, or through a web GUI. Additional information on DNSSEC, including the management of security extensions is found in the response to Question 43.
Data Escrow
Data Escrow will be performed in compliance with all ICANN requirements in conjunction with an approved Data Escrow provider. The Data Escrow service will:
Protect against data loss
Follow industry best practices
Ensure easy, accurate, and timely retrieval and restore capability in the event of a hardware failure
Minimizes the impact of software or business failure.
Additional information on the Data Escrow service is provided in the response to Question 38.
Dissemination of Zone Files using Dynamic Updates
Neustar will provide dissemination of zone files through a dynamic, near real-time process. Updates will be performed within the specified performance levels. The proven technology ensures that updates pushed to all nodes within a few minutes of the changes being received by the SRS. Additional information on the DNS updates may be found in the response to Question 35.
Access to Bulk Zone Files
Safety Registry, through Neustar, will provide third-party access to the bulk zone file in accordance with Specification 4, Section 2 of the Registry Agreement. Credentialing and dissemination of the zone files will be facilitated through the Central Zone Data Access Provider.
Dynamic WHOIS Updates
By leveraging Neustar technology updates to records in the WHOIS database will be provided via dynamic, near real-time updates. Guaranteed delivery message oriented middleware is used to ensure each individual WHOIS server is refreshed with dynamic updates. This component ensures that all WHOIS servers are kept current as changes occur in the SRS, while also decoupling WHOIS from the SRS. Additional information on WHOIS updates is presented in response to Question 26.
IPv6 Support
The .SAFETY registry, through Neustar, will provide IPv6 support in the following registry services: SRS, WHOIS, and DNS⁄DNSSEC. In addition, the registry supports the provisioning of IPv6 AAAA records. A detailed description on IPv6 is presented in the response to Question 36.
Required Rights Protection Mechanisms
Safety Registry will provide all ICANN required Rights Mechanisms, including: 
Trademark Claims Service
Trademark Post-Delegation Dispute Resolution Procedure (PDDRP)
Registration Restriction Dispute Resolution Procedure (RRDRP)
UDRP
URS
Sunrise service
More information is presented in the response to Question 29.
Internationalized Domain Names (IDN)
IDN registrations are provided in full compliance with the IDNA protocol. Neustar possesses extensive experience offering IDN registrations in numerous TLDs, and its IDN implementation uses advanced technology to accommodate the unique bundling needs of certain languages. Character mappings are easily constructed to block out characters that may be deemed as confusing to users. A detailed description of the IDN implementation is presented in response to Question 44.
23.3 Unique Services 
The only unique service that Safety Registry is considering at this time is the potential imposition of an annual cost recovery based fee to validate registrars that will be providing domain name registration services in the .SAFETY gTLD.

An additional service which applicant may offer, commonly used in the marketplace today, is the use of RFPs (Request for Proposals) and Auctions to determine string allocation in appropriate circumstances.
23.4 Security or Stability Concerns 
All services offered are standard registry services that have no known security or stability concerns. Neustar has demonstrated a strong track record of security and stability within the industry.

24.1 Introduction
Safety Registry Services, LLC (“Safety Registry”) has partnered with Neustar, Inc. (“Neustar”) an experienced TLD Registry Operator, for the operation of the .SAFETY registry. Safety Registry is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.
Neustar built its SRS from the ground up as an EPP-based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO, and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state-of-the-art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today.
The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.
24.2 The Plan for Operation of a Robust and Reliable SRS
High-level SRS System Description
The Neustar SRS to be used for .SAFETY will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the New gTLD Applicant Guidebook.
The SRS is the central component of any registry implementation and its quality, reliability, and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability, and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, Safety Registry is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:
State-of-the-art, production-proven, multi-layer design;
Ability to rapidly and easily scale from low to high volume as a TLD grows;
Fully redundant architecture at two sites;
Support for IDN registrations in compliance with all standards;
Use by over 300 Registrars;
EPP connectivity over IPv6;
Performance being measured using 100% of all production transactions (not sampling); and
SRS Systems, Software, Hardware, and Interoperability.
The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and as a result, the team is intimately familiar with its operations.
The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load-balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.
The registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.
All interaction with the registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:
The IP address of the client;
Timestamp;
Transaction Details; and
Processing Time.
In addition to logging of each and every transaction with the SRS, Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the registry, in support of Safety Registry, to produce a complete history of changes for any domain name.
SRS Design
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:
Protocol Layer;
Business Policy Layer; and
Database.
Each of the layers is described below.
Protocol Layer
The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.
The EPP servers authenticate against a series of security controls before granting service, as follows:
The registrar’s host exchanges keys to initiate a TLS handshake session with the EPP server.
The registrar’s host must provide credentials to determine proper access levels.
The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.
Business Policy Layer
The Business Policy Layer is the “brain” of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data, and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include back-end processes such as dynamic update of DNS, WHOIS, and Billing. 
Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.
The SRS today processes over 30 million EPP transactions daily.
Database
The database is the third core component of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.
See attachment: Figure 24-1, which depicts the overall SRS architecture including network components. This multi-layer architecture is EPP-compliant, meets all applicable RFCs, and its development follows industry best-practices.
Number of Servers
As depicted in the SRS architecture diagram above, Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs, as do the databases. For the .SAFETY registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple back-end servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections.
Description of Interconnectivity with Other Registry Systems
The core Neustar SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:
WHOIS;
DNS;
Billing; and
Data Warehouse (Reporting and Data Escrow).
Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .SAFETY.
The SRS includes an “External Notifier” concept in its business policy engine as a message dispatcher. This design allows time-consuming back-end processing to be decoupled from critical online registrar transactions. Using an External Notifier solution, the registry can utilize “control levers” that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back-end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. The following are the standard three External Notifiers used the SRS:
WHOIS External Notifier
The WHOIS External Notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS External Notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS External Notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail.
DNS External Notifier
The DNS External Notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS External Notifier, the DNS External Notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail.
Billing External Notifier
The Billing External Notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This External Notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar.
Data Warehouse
The Data Warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of Data Escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The Data Warehouse databases are updated on a daily basis with full copies of the production SRS data.
Frequency of Synchronization between Servers
The External Notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes.
Synchronization Scheme (e.g., hot standby, cold standby) 
Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated in real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail.
Compliance with Specification 6 Section 1.2
The SRS implementation for .SAFETY is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and Registry-Registrar Agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1.
See attachment: Table 24-1.
Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.
Compliance with Specification 10
Specification 10 of the New TLD Registry Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced Registry Operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .SAFETY registry. The following section describes Neustar’s experience and its capabilities to meet the requirements in the new agreement.
To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustar’s current .BIZ SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.
See attachment: Table 24-2.
Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.
24.3 Resourcing Plans 
The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including:
Development⁄Engineering;
Database Administration;
Systems Administration; and
Network Engineering.
Additionally, if customization or modifications are required, the Neustar Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably.
The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustar’s SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .SAFETY registry. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Database Administration – 10 employees
Systems Administration – 24 employees
Network Engineering – 5 employees
The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .SAFETY registry.

25.1 Introduction
Safety Registry Services, LLC (“Safety Registry”) back-end registry operator, Neustar, Inc. (“Neustar”) has over 10 years of experience operating EPP-based registries. They deployed one of the first EPP registries in 2001 with the launch of .BIZ. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure Safety Registry is provided with an unparalleled EPP-based registry. The following discussion explains the EPP interface, which will be used for the .SAFETY registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.
See attachment: Figure 25-1. The protocol layer is responsible for ensuring transactions comply with the appropriate protocol.
25.2 EPP Interface
Registrars are provided with two different interfaces for interacting with the registry. Both are EPP-based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry.
However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks.
The main features of the EPP implementation are:
Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.
Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD.
Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.
Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.
Extensibility: The software is built ground-up using object-oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application.
Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.
Security: The system provides IP address-based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer.
25.3 Compliance with RFCs and Specifications
The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs.
See attachment: Table 25-1.
Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.
Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.
See attachment: Table 25-2.
EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.
The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients.
The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.
25.3 Proprietary EPP Extensions
The .SAFETY registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .SAFETY registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.
See attachment: Table 25-3.
The full EPP schema to be used in the .SAFETY registry is attached in the document titled “EPP Schema.”
25.4 Resourcing Plans
The development and support of EPP is largely the responsibility of the Development⁄Engineering and Quality Assurance teams. As an experience registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions.
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Quality Assurance – 7 employees.
These resources are more than adequate to support any EPP modification needs of the .SAFETY registry.

26.1 Introduction
Safety Registry Services, LLC (“Safety Registry”) recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders, and the public as a whole and through its use of the Neustar services is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 of the Registry Agreement. Safety Registryʹs back-end registry services provider, Neustar, Inc. (“Neustar”), has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs and ccTLDs, and as a back-end registry services provider. As one of the first “thick” Registry Operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by a TLD and to respond to a very stringent availability and performance requirement.
Some of the key features of .SAFETY’s solution include: 
Fully compliant with all relevant RFCs including 3912;
Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years;
Exceeds current and proposed performance specifications;
Supports dynamic updates with the capability of doing bulk updates; and
Geographically distributed sites to provide greater stability and performance.
In addition, through its use of the Neustar services, .SAFETYʹs thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).
26.2 Software Components
The WHOIS architecture comprises the following components:
An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys.
Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database.
Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
SRS master database: The SRS database is the main persistent store of the registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.
26.3 Compliance with RFC and Specifications 4 and 10
Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement. RFC 3912 is a simple text-based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.
See attachment: Table 26-1, which describes Neustar’s compliance with Specifications 4 and 10.
Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to WHOIS. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.
26.4 High-level WHOIS System Description
26.4.1 WHOIS Service (port 43)
The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.
The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.
26.4.2 Web Page for WHOIS queries
In addition to the WHOIS Service on port 43, Neustar provides a Web-based WHOIS application (www.whois.tld). It is an intuitive and easy to use application for the general public to use. The WHOIS Web-application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
Domain names;
Nameservers; 
Registrant, Technical, and Administrative Contacts; and
Registrars.
It also provides features not available on the port 43 service. These include:
Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the Web-based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.
Extensive support for international domain names (IDN);
Ability to perform WHOIS lookups on the actual Unicode IDN;
Display of the actual Unicode IDN in addition to the ACE-encoded name;
A Unicode to Punycode and Punycode to Unicode translator;
An extensive FAQ; and
A list of upcoming domain deletions.
26.5 IT and Infrastructure Resources
As described above, the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use:
Firewalls, to protect this sensitive data;
Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates;
Packetshaper for source IP address-based bandwidth limiting;
Load balancers to distribute query load; and
Multiple WHOIS servers for maximizing the performance of WHOIS service.
The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
See attachment: Figure 26-1, which depicts the different components of the WHOIS architecture. WHOIS is decoupled from the architecture to protect production databases and increased overall systems security.
26.6 Interconnectivity with Other Registry System
As described in Question 24 about the SRS and further in response to Question 31, “Technical Overview,” when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging-oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.
26.7 Frequency of Synchronization between Servers
Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.
26.8 Provision for Searchable WHOIS Capabilities
Neustar will create a new Web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields: 
Domain name;
Registrar ID;
Contact’s and registrant’s name;
Contact’s and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.); and
Name server name and name server IP address.
The system will also allow search using non-Latin character sets, which are compliant with IDNA specification.
The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.
See attachment: Figure 26-2, which shows an architectural depiction of the new service. Neustar’s Web-based service provides new search features based on requirements specified in Specification 4 Section 1.8.
To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine by Neustar, which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:
Data Mining;
Unauthorized Access;
Excessive Querying; and
Denial of Service Attacks.
To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:
Username-password based authentication;
Certificate based authentication;
Data encryption;
CAPTCHA mechanism to prevent robo invocation of Web query; and
Fee-based advanced query capabilities for premium customers.
The searchable WHOIS application will adhere to all privacy laws and policies of the .SAFETY registry.
26.9 Resourcing Plans 
As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:
Development⁄Engineering – 19 employees
Database Administration – 10 employees
Systems Administration – 24 employees
Network Engineering – 5 employees 
Additionally, if customization or modifications are required, Neustar’s Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the .SAFETY registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .SAFETY registry.

27.1 Registration Life Cycle
Introduction
Safety Registry Services, LLC (“Safety Registry”) will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be use for .SAFETY.
Domain Lifecycle - Description
The registry will use Neustar’s EPP 1.0 standard for provisioning domain names, contacts, and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts. 
Domains, contacts, and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object by Neustar. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .SAFETY registry per the defined .SAFETY business rules.
The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.
OK – Default status applied by the Registry.
Inactive – Default status applied by the Registry if the domain has less than 2 nameservers.
PendingCreate – Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .SAFETY registry.
PendingTransfer – Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
PendingDelete – Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
PendingRenew – Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .SAFETY registry.
PendingUpdate – Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .SAFETY registry.
Hold – Removes the domain from the DNS zone.
UpdateProhibited – Prevents the object from being modified by an Update command.
TransferProhibited – Prevents the object from being transferred to another Registrar by the Transfer command.
RenewProhibited – Prevents a domain from being renewed by a Renew command.
DeleteProhibited – Prevents the object from being deleted by a Delete command. 
The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:
Domain may be updated
Domain may be deleted, either within or after the add-grace period
Domain may be renewed at anytime during the term
Domain may be auto-renewed by the Registry
Domain may be transferred to another registrar. 
Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.
27.1.1 Registration States
Domain Lifecycle – Registration States
As described above, the .SAFETY registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:
Active 
Inactive
Locked
Pending Transfer
Pending Delete
All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods. 
Active State
The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states.
Inactive State
The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.
Locked State
The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states.
Pending Transfer State
The Pending Transfer state indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in the Inter-Registrar Transfer Policy.
Pending Delete State
The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and the last 5-days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first come, first serve basis.
27.1.2 Typical Registration Lifecycle Activities
Domain Creation Process
The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or complement a domain creation. The following steps occur when a domain is created. 
Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.
The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. The latter assumes seven distinct contacts and 13 nameservers, with Check and Create commands submitted for each object. 
Update Process
Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object. 
For example, the Update operation on a domain name will only allow the following attributes to be updated:
Domain statuses
Registrant ID
Administrative Contact ID
Billing Contact ID
Technical Contact ID
Nameservers
AuthInfo
Additional Registrar provided fields
The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. To update the details of the contact object the Update transaction must be applied to the contact itself. For example, if an existing registrant wished to update the postal address, the Registrar would use the Update command to modify the contact object, and not the domain object. 
Renew Process 
The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed that will extend the domain beyond the 10-year limit, the Registry will reject the transaction entirely.
Transfer Process
The EPP Transfer command is used for several domain transfer related operations: 
Initiate a domain transfer
Cancel a domain transfer
Approve a domain transfer
Reject a domain transfer
To transfer a domain from one Registrar to another the following process is followed:
The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into PendingTransfer status
A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue
The domain remains in PendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
The requesting Registrar may cancel the original request up until the transfer has been completed.
A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10-year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.
Deletion Process
A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in PendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in PendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.
27.1.3 Applicable Time Elements
The following section explains the time elements that are involved 
Grace Periods
There are six grace periods:
Add-Delete Grace Period (AGP)
Renew-Delete Grace Period
Transfer-Delete Grace Period
Auto-Renew-Delete Grace Period
Auto-Renew Grace Period
Redemption Grace Period (RGP). 
The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction.
The following describes each of these grace periods in detail.
Add-Delete Grace Period 
The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrar’s billing account. 
Renew-Delete Grace Period 
The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into PendingDelete and will enter the RGP (see below). 
Transfer-Delete Grace Period 
The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into PendingDelete and will enter the RGP. A deletion of domain after a transfer is not the method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry.
Auto-Renew-Delete Grace Period 
The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into PendingDelete and will enter the RGP. 
Auto-Renew Grace Period 
The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are not required to provide registrants with the full 45 days of the period.
Redemption Grace Period 
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in PendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. 
The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in PendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5-day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.
Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.
27.2 State Diagram
See attachment: Figure 27-1, which provides a description of the registration lifecycle. 
The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete. Please refer to section 27.1.1 for detail description of each of these states. The lines between the states represent triggers that transition a domain from one state to another. 
The details of each trigger are described below:
Create: Registry receives a create domain EPP command.
WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command. The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
Delete: Registry receives a delete domain EPP command.
DeleteAfterGrace: Domain deletion does not fall within the add grace period.
DeleteWithinAddGrace: Domain deletion falls within add grace period.
Restore: Domain is restored. Domain goes back to its original state prior to the delete command.
Transfer: Transfer request EPP command is received.
Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected.
TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state.
DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state.
Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete.
27.2.1 EPP RFC Consistency
As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs. 
27.3 Resources
The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working with Safety Registry to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team. Neustar’s SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes. 
The .SAFETY registry will be using standard lifecycle rules, and as such no customization is anticipated. However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Registry Product Management – 4 employees
These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .SAFETY registry.

28.1 Abuse Prevention and Mitigation
Strong abuse prevention of a new gTLD is an important benefit to the Internet community. Safety Registry Services, LLC (“Safety Registry”) and its back-end registry services provider, Neustar, Inc. (“Neustar”), agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help Safety Registry combat abusive and malicious domain activity within the new gTLD space.
One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from:
Illegal or fraudulent actions
Spam
Phishing
Pharming
Distribution of malware
Fast flux hosting
 Botnets
Distribution of child pornography
Online sale or distribution of illegal pharmaceuticals
More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets, Safety Registry’s partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.
Policies and Procedures to Minimize Abusive Registrations
A registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. As Safety Registry’s registry provider, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.
Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique should not be entered into lightly. Neustar has a extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry.
Abuse Point of Contact
As required by the Registry Agreement, Safety Registry will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. Safety Registry will also provide such information to ICANN prior to the delegation of any domain names in the TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information will be kept accurate and up-to-date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar, shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices.
28.2 Policies Regarding Abuse Complaints
One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This will include locking down the domain name, preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold,” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. 
Safety Registry will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and reserves the right of the Applicant to lock, cancel, transfer, or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow the registry where and when appropriate to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to the TLD registrants. Below is the registry’s initial Acceptable Use Policy that we will use in connection with the .SAFETY TLD.
.SAFETY Acceptable Use Policy
This Acceptable Use Policy gives the registry the ability to quickly lock, cancel, transfer, or take ownership of any .SAFETY domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity, or security of the registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The process also allows the registry to take preventive measures to avoid any such criminal or security threats.
The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the ongoing monitoring by the registry or its partners. In all cases, the registry or its designees will alert registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.
The following are some (but not all) activities that may be subject to rapid domain compliance:
Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than .SAFETY’s own.
Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
Fast Flux Hosting: a technique used to shelter Phishing, Pharming, and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
Child Pornography: the storage, publication, display, and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.
The registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the registry reserves the right to 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 registry; (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 registry as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the registry or any registrar in connection with a domain name registration. The registry also reserves the right to place upon registry lock, hold, or similar status a domain name during resolution of a dispute.
Taking Action Against Abusive and⁄or Malicious Activity
The registry is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the TLD, or are part of a real-time investigation by law enforcement.
Once a complaint is received from a trusted source, third party, or detected by the registry, the registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety, or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the registry will place the domain on “ServerHold.” Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.
Coordination with Law Enforcement
With the assistance of Neustar as its back-end registry services provider, Safety Registry can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. The registry will respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, questions or comments concerning the request, and an outline of the next steps to be taken by Safety Registry for rapid resolution of the request.
In the event such request involves any of the activities which can be validated by the registry and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety, or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the registry will place the domain on “serverHold.” 
28.2 Measures for Removal of Orphan Glue Records
As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf.
While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, botnets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the registry has written evidence of actual abuse of orphaned glue, the registry will take action to remove those records from the zone to mitigate such malicious conduct.
Neustar runs a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone.
In addition, if either Safety Registry or Neustar becomes aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone.
28.3 Measures to Promote WHOIS Accuracy 
Safety Registry acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information.
However, the proposed used of .SAFETY as a gTLD in which all domain names will initially be registered by Safety Registry to W.W. Grainger, Inc. (“Grainger”), or its qualified subsidiaries and affiliates, essentially eliminates the potential of false or inaccurate WHOIS data in the first stage of .SAFETY’s operation. Moreover, Safety Registry aims to publish a Charter and all associated policies, guidelines, and other supporting documentation related to the implementation of the registry consistent with the Purpose, all prior to launch. As only select partners meeting the Charter⁄membership requirements mentioned above will likely be eligible to register .SAFETY domain names, the risk of false or inaccurate WHOIS data is greatly reduced.
Should Safety Registry expand the universe of potential registrants in the .SAFETY namespace, to include select partners meeting the Charter⁄membership requirements, Safety Registry intends to offer the following enhanced mechanism to ensure the accuracy of WHOIS data, specifically, a mechanism whereby third parties can submit complaints directly to Safety Registry (as opposed to ICANN or the sponsoring registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, Safety Registry will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Safety Registry reserves the right to suspend the applicable domain name(s) until such time as the registrant is able to cure the deficiencies.
In addition, should Safety Registry expand the universe of potential registrants within the .SAFETY namespace to include select partners meeting the Charter⁄membership requirements, Safety Registry shall on its own initiative, no less than twice per year, perform a manual review of a random sampling of .SAFETY domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, Safety Registry will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring registrar, who shall be required to address those complaints with its registrants. Thirty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the registrar has failed to take any action, or it is clear that the registrant was either unwilling or unable to correct the inaccuracies, Safety Registry reserves the right to suspend the applicable domain name(s) until such time as the registrant is able to cure the deficiencies.
28.3.1 Authentication of Registrant Information
As noted above, the proposed use of the .SAFETY as a gTLD in which all domain names will initially be registered by Safety Registry to Grainger, or its qualified subsidiaries and affiliates, essentially eliminates the potential of false or inaccurate WHOIS data. Additionally, all domain names will be registered through Grainger’s corporate registrar, or a similar corporate registrar, which employs enhanced security protocols that limit which employees can register domain names, as well as ensure that those domain names that are registered contain uniform, accurate, and up-to-date WHOIS information.
Should Safety Registry expand the universe of potential registrants within the .SAFETY namespace to include select partners meeting the Charter⁄membership requirements, such domain names would not be permitted to be registered until Safety Registry had a process in place to verify the identity of the registrant and the accuracy of the WHOIS data. 
28.3.2 Monitoring of Registration Data 
 As noted above Safety Registry will provide a mechanism by which third parties can submit a WHOIS accuracy complaint directly to the Registry Operator for timely investigation and resolution. In addition, Safety Registry has committed to perform a manual review of a random sampling of .SAFETY domain names no less than twice per year to test the accuracy of the WHOIS information after the expanding the potential universe of domain names to include third parties such as licensees or strategic partners. 
28.3.3 Policies and Procedures Ensuring Compliance 
These proposed enhanced safeguards designed to promote the accuracy of WHOIS data will be hard coded into the Registry-Registrar Agreement (RRA) as well as the end-registrant agreement. Safety Registry will proactively be monitoring similar gTLDs to ensure best in class policies to promote the accuracy and availability of WHOIS data.
28.4 Resourcing Plans 
Responsibility for abuse mitigation rests with a variety of functional groups. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures.
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Customer Support, provided by Neustar – 12 employees – Registrant Support, provided by Neustar
Policy⁄Legal, Provided by Neustar – 2 employees
In addition to the above staffing provided by Neustar, Safety Registry will provide the full support of its internal staff (0.5 FTE count) as well as its external vendors where the situation requires the extra staffing resources.
The resources are more than adequate to support the abuse mitigation procedures of the .SAFETY registry.

29.1. Rights Protection Mechanisms
Safety Registry Services, LLC (“Safety Registry”) is firmly committed to the protection of intellectual property rights and to implementing the mandatory rights protection mechanisms contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. Safety Registry recognizes that although the New gTLD Program includes significant protections beyond those that were mandatory for a number of the current TLDs, a key motivator for Safety Registry’s selection of Neustar, Inc. (“Neustar”) as its registry services provider is Neustar’s experience in successfully launching a number of TLDs with diverse rights protection mechanisms, including many of the ones required in the Applicant Guidebook. More specifically, Safety Registry will implement the following rights protection mechanisms in accordance with the Applicant Guidebook as further described below:
Trademark Clearinghouse: a one-stop shop so that trademark holders can protect their trademarks with a single registration;
Sunrise and Trademark Claims processes for the TLD;
Implementation of the Uniform Domain Name Dispute Resolution Policy to address domain names that have been registered and used in bad faith in the TLD;
Uniform Rapid Suspension: A quicker, more efficient, and cheaper alternative to the Uniform Domain Name Dispute Resolution Policy to deal with clear cut cases of cybersquatting;
Implementation of a thick WHOIS, making it easier for rights holders to identify and locate infringing parties.
A. Trademark Clearinghouse Including Sunrise and Trademark Claims
The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD registry is support for, and interaction with, the Trademark Clearinghouse. The Trademark Clearinghouse is intended to serve as a central repository for information to be authenticated, stored, and disseminated pertaining to the rights of trademark holders. The data maintained in the Clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the Trademark Clearinghouse will interact with each registry operator and registrars, Safety Registry is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the Trademark Clearinghouse. In addition, Safety Registry’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the Clearinghouse and associated RPMs are feasible and implementable.
Utilizing the Trademark Clearinghouse, all operators of new gTLDs must offer: (i) a Sunrise registration service for at least 30 days during the pre-launch phase, giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a Trademark Claims service for at least the first 60 days that second-level registrations are open. The trademark claim service is intended to provide clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.
Safety Registry’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .BIZ, .US, .TRAVEL, .TEL, and .CO and will implement the both of these services on behalf of .SAFETY.
Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes
In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .US ccTLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of trademark applications and registrations with the United States Patent and Trademark Office (USPTO).
Subsequently, as the back-end registry operator for the .TEL gTLD and the .CO ccTLD, Neustar launched validated Sunrise programs employing processes. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs.
Below is a high-level overview of the implementation of the .CO Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service, and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of Safety Registry as required by ICANN.
Sunrise and .CO
The Sunrise process for .co was divided into two sub-phases: 
Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks; and
Global Sunrise program giving holders of eligible registered trademarks of national effect that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large.
Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application, using official national trademark databases and submitted documentary evidence.
Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the registry pursuant to an optional “Pre-validation Process.” Whether or not an applicant was “pre-validated,” the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply to the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the registry.
At the registry level, Neustar subsequently either delivered the approval number and domain name registration information to the Clearinghouse, or in cases where there was no approval number, trademark information and the domain name registration information that was provided to the Clearinghouse through EPP (as is currently required under the Applicant Guidebook).
Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and its trademark matched the domain name applied for, the Clearinghouse communicated that fact to the Registry via EPP.
When there was only one validated Sunrise application, the application proceeded to registration when .CO launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .CO Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure website to enable trademark owners to view the status of their Sunrise application.
Although the exact process for the Sunrise program and its interaction between the trademark owner, registry, registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new gTLDs.
Trademark Claims Service Experience
With Neustar’s .BIZ TLD launched in 2001, Neustar became the first registry with a Trademark Claims service. Neustar developed the Trademark Claims Service by enabling companies to stake claims to domain names prior to the commencement of live .BIZ domain registrations.
During the Trademark Claims process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar.
The Trademark Claimant was required to provide various information about their trademark rights, including the:
Particular trademark or service mark relied on for the trademark Claim;
Date a trademark application on the mark was filed, if any, on the string of the domain name;
Country where the mark was filed, if applicable;
Registration date, if applicable;
Class or classes of goods and services for which the trademark or service mark was registered;
Name of a contact person with whom to discuss the claimed trademark rights.
Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name.
The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed.
If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the Claimant’s (or Claimants’) alleged trademark rights to the desired domain name, Neustar processed the application.

This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.
B. Uniform Domain Name Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)
1. UDRP
Prior to joining Neustar, Mr. Neuman was a key contributor to the development of the Uniform Domain Name Dispute Resolution Policy (“UDRP”) in 1998. This became the first “Consensus Policy” of ICANN and has been required to be implemented by all domain name registries since that time. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs that it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision.
URS
In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted the IRT’s recommendation that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension system (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP to protect their trademarks and to promote consumer protection on the Internet.
The URS is not meant to address questionable cases of alleged infringement (e.g., use of terms in a generic sense), for anti-competitive purposes, or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place.
Unlike the UDRP, which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24 hours of receipt of the complaint from the URS Provider to restrict all changes to the registration data, including transfer and deletion of the domain names.
In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period and would not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS.
Additionally, the WHOIS reflects that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates.
Safety Registry is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. In fact, during the IRT’s development of the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement.
Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries to which it provides back-end registry services.
C. Implementation of Thick WHOIS
The .SAFETY registry will include a thick WHOIS database as required in Specification 4 of the Registry Agreement. A thick WHOIS provides numerous advantages, including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience.
D. Policies Handling Complaints Regarding Abuse
In addition the rights protection mechanisms addressed above, Safety Registry will implement a number of measures to handle complaints regarding the abusive registration of domain names in its gTLD as described in its response to Question 28.
Registry Acceptable Use Policy
One of the key policies each new gTLD registry needs to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. The policy must be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name, preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold,” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting nameservers to collect information about the DNS queries to assist the investigation. .SAFETY’s Acceptable Use Policy, set forth in our response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, and child pornography. In addition, the policy will include the right of the registry to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the policy.
Monitoring for Malicious Activity
Safety Registry is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the gTLD, or is part of a real-time investigation by law enforcement.
Once a complaint is received from a trusted source, third party, or detected by the registry, the registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety, or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the registry will place the domain on “ServerHold.” Although this action removes the domain name from the gTLD zone, the domain name record still appears in the gTLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.
29.2 Safeguards against Unqualified Registrations
As set forth in Safety Registry’s response to Question 28, the proposed used of .SAFETY as a gTLD in which all domain names will initially be registered by Safety Registry to W.W. Grainger, Inc. (“Grainger”), or its qualified subsidiaries and affiliates, essentially eliminates the potential of false or inaccurate WHOIS data in the first stage of .SAFETY’s operation. Moreover, Safety Registry aims to publish a Charter and all associated policies, guidelines, and other supporting documentation related to the implementation of the registry consistent with the Purpose, all prior to launch. As only select partners meeting the Charter⁄membership requirements mentioned above will likely be eligible to register .SAFETY domain names, the risk of false or inaccurate WHOIS data is greatly reduced.
Should Safety Registry expand the universe of potential registrants in the .SAFETY namespace to include select partners meeting the Charter⁄membership requirements, Safety Registry intends to offer the following enhanced mechanism to ensure that only qualified registrants have registered in the name space: specifically, a mechanism whereby third parties can submit complaints directly to Safety Registry (as opposed to ICANN or the sponsoring registrar) about the qualification of a domain name registrant in the .SAFETY namespace. Safety Registry will then undertake an investigation to either confirm or dismiss the allegation. Safety Registry reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to resolve any qualification requirements.
If this mechanism, coupled with verification requirements imposed at the registrar level, prove inadequate, Safety Registry would evaluate implementing an annual sampling of the active zone file to verify registrant qualification as well as WHOIS accuracy. The size of the sampling would be based upon a meaningful statistical universe and would be subject to change based upon the results of this survey.
29.3 Resourcing Plans
The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general, the development of applications such as Sunrise and IP claims is the responsibility of the Engineering team, with guidance from the Product Management team. Customer Support and Legal play a critical role in enforcing certain policies such as the rapid suspension process. These teams have years of experience implementing these or similar processes.
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees;
Product Management – four employees;
Customer Support – 12 employees.
Safety Registry’s 0.5 FTE allocated to registry oversight and compliance should have no problem undertaking these initial functions based upon the closed nature of the registry and the limited zone files size. However, if the number of domain names were to exceed a manageable size, Safety Registry would consider outsourcing this potential function to a qualified third party that could recognize more efficiencies and economies of scale in implementing these additional safeguard mechanisms.
These combined resources are more than adequate to support the rights protection mechanisms of the .SAFETY registry.

Safety Registry Services, LLC and its back-end operator, Neustar, Inc. (“Neustar”), recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .SAFETY registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements.
Neustar’s approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and Center for Internet Security (CIS). Policies are reviewed annually by Neustar’s information security team.
The following is a summary of the security policies that will be used in the .SAFETY registry, including:
Summary of the security policies used in the registry operations;
Description of independent security assessments;
Description of security features that are appropriate for .SAFETY;
List of commitments made to registrants regarding security levels;
All of the security policies and levels described in this section are appropriate for the .SAFETY registry.
30.(a).1 Summary of Security Policies
Neustar, Inc. has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.
The Program defines:
The policies for internal users and its clients to ensure the safe, organized, and fair use of information resources:
The rights that can be expected with that use;
The standards that must be met to effectively comply with policy;
The responsibilities of the owners, maintainers, and users of Neustar’s information resources;
Rules and principles used at Neustar to approach information security issues.

The following policies are included in the Program:
Acceptable Use Policy
The Acceptable Use Policy provides the “rules of behavior” covering all Neustar Associates for using Neustar resources or accessing sensitive information.
Information Risk Management Policy
The Information Risk Management Policy describes the requirements for the ongoing information security risk management program, including defining roles and responsibilities for conducting and evaluating risk assessments; assessments of technologies used to provide information security; and monitoring procedures used to measure policy compliance.
Data Protection Policy
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.
Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.
Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the ongoing awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates.
Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting “lessons learned” post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.
Physical and Environmental Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.
Privacy Policy
Neustar supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. Neustar supports domestic and international laws and regulations that seek to protect the privacy rights of such individuals.
Identity and Access Management Policy
The Identity and Access Management Policy covers user accounts (login ID naming convention, assignment, authoritative source) as well as ID lifecycle (request, approval, creation, use, suspension, deletion, review), including provisions for system⁄application accounts, shared⁄group accounts, guest⁄public accounts, temporary⁄emergency accounts, administrative access, and remote access. This policy also includes the user password policy requirements.
Network Security Policy
The Network Security Policy covers aspects of Neustar network infrastructure and the technical controls in place to prevent and detect security policy violations.
Platform Security Policy
The Platform Security Policy covers the requirements for configuration management of servers, shared systems, applications, databases, middle-ware, and desktops and laptops owned or operated by Neustar Associates.
Mobile Device Security Policy
The Mobile Device Policy covers the requirements specific to mobile devices with information storage or processing capabilities. This policy includes laptop standards, as well as requirements for PDAs, mobile phones, digital cameras and music players, and any other removable device capable of transmitting, processing, or storing information.
Vulnerability and Threat Management Policy
The Vulnerability and Threat Management Policy provides the requirements for patch management, vulnerability scanning, penetration testing, threat management (modeling and monitoring), and the appropriate ties to the Risk Management Policy.
Monitoring and Audit Policy
The Monitoring and Audit Policy covers the details regarding which types of computer events to record, how to maintain the logs, and the roles and responsibilities for how to review, monitor, and respond to log information. This policy also includes the requirements for backup, archival, reporting, forensics use, and retention of audit logs.
Project and System Development and Maintenance Policy
The System Development and Maintenance Policy covers the minimum security requirements for all software, application, and system development performed by or on behalf of Neustar and the minimum security requirements for maintaining information systems.
30.(a).2 Independent Assessment Reports
Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70), and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management, and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group, and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.
External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts, and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:
A network survey is performed in order to gain a better knowledge of the network that was being tested;
Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase;
Identification of key systems for further exploitation is conducted;
Exploitation of the identified systems is attempted.
Each phase of the audit is supported by detailed documentation of audit procedures and results. Identified vulnerabilities are classified as high, medium and low risk to facilitate management’s prioritization of remediation efforts. Tactical and strategic recommendations are provided to management supported by reference to industry best practices.
30.(a).3 Augmented Security Levels and Capabilities
There are no increased security levels specific for .SAFETY. However, Neustar will provide the same high level of security provided across all of the registries it manages.
A key to Neustar’s operational success is Neustar’s highly structured operations practices. The standards and governance of these processes:
Include annual independent review of information security practices;
Include annual external penetration tests by a third party;
Conform to the ISO 9001 standard (Part of Neustar’s ISO-based Quality Management System);
Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices;
Are aligned with all aspects of ISO IEC 17799;
Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually);
Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).
A summary view to Neustar’s security policy in alignment with ISO 17799 can be found in section 30.(a).4, below.
30.(a).4 Commitments and Security Levels
The .SAFETY registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:
Compliance with High Security Standards;
Security procedures and practices that are in alignment with ISO 17799;
Annual SOC 2 Audits on all critical registry systems;
Annual 3rd Party Penetration Tests;
Annual Sarbanes Oxley Audits;
Highly Developed and Document Security Policies;
Compliance with all provisions described in section 30.(a).4, below, and in the attached security policy document.
Resources necessary for providing information security;
Fully documented security policies;
Annual security training for all operations personnel;
High Levels of Registry Security;
Multiple redundant data centers;
High Availability Design;
Architecture that includes multiple layers of security;
Diversified firewall and networking hardware vendors;
Multi-factor authentication for accessing registry systems;
Physical security access controls;
A 24⁄7 manned Network Operations Center that monitors all systems and applications;
A 24⁄7 manned Security Operations Center that monitors and mitigates DDoS attacks;
DDoS mitigation using traffic scrubbing technologies.