Application number: 1-1083-39123 for European Broadcasting Union (EBU)

European Broadcasting Union (EBU)

LʹAncienne-Route 17A
Case postale 45
Grand-Saconnex Geneva 1218
CH

+41 22 717 2111

+41 22 747 4000

http:⁄⁄www.ebu.ch

Mr. Alain Artero

Project Portfolio Manager

+41 22 717 21 58

+41 22 747 41 58

artero@ebu.ch

Ms. Rosa Delgado

Top Level Domain Advisor

+41 22 717 21 01

+41 22 717 20 10

delgado@ebu.ch

Not-for-profit Association under Swiss Law

Articles 60-79 of the Swiss Civil Code.
The EBU is an international non-governmental organization (INGO), created in 1950 as a not-for-profit Association under Swiss Law. It is a sector member of the ITU (International Telecommunication Union), the United Nations specialized agency. The relations between EBU and the Swiss Confederation are regulated by special agreement (ʺAccord de siègeʺ), defining the status of the EBU and its workers and governing bodies.

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Annika Nyberg Frankenhaeuser
Director, Media Department
Graham Warren
Director, Network and News
Ingrid Deltenre
Director General
Jane Vizard
Director, Legal Department
Lieven Vermaele
Director, Technology and Development velopment
Stefan Kürten
Director, Sports and Business
Wallace Macmillan
Chief Financial and Administrative Officer

Alexander Wrabetz
Member of the Executive Board - General Director of ORF (Oesterreichischer Rundfunk)
Cecilia Benkö Lamborn
Member of the Executive Board - Deputy Director General of SR (Sveriges Radio Ab)
Claudio Cappon
Vice-President of the Executive Board - CEO of NewCo Rai International (Radiotelevisione Italiana)
Jean-Paul Philippot
President of the Executive Board - CEO⁄Administrator General of RTBF (Radio-Télévision belge de la Communauté française)
Marija Nemčić
Member of the Executive Board - Director of International Relations, Croatian TV (Hrvatska Radiotelevizija)
Markus Schächter
Member of the Executive Board - Director General of ZDF (Zweites Deutsches Fernsehen)
Petr Fedorov
Member of the Executive Board - Director RTR Foreign Affairs, RTR (Rossijskoe Teleradio All-Russian State TV and Radio)
Rémy Pflimlin
Member of the Executive Board - President of FT (France Télévisions)
Roger Mosey
Member of the Executive Board - Director London 2012, BBC (British Broadcasting Corporation)
Zeynel Koç
Member of the Executive Board - Deputy Director General of TRT (Turkiye Radyo-Televizyon Kurumu)

radio

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Q16 - Operational or Rendering Considerations with Regard to the gTLD String
The .radio registry (and CORE Internet Council of Registrars as its technical provider) ensured that there are no known operational or rendering problems concerning the applied-for gTLD string ʺradioʺ.
Since the gTLD string ʺradioʺ is an ASCII-only string, it is safe to assume that, just like with existing ASCII-only TLD strings like .com, .net or .de, no operational or rendering problems may be expected. In particular, the name consists only of ASCII characters that are already used for existing top level domains; all the characters in the name are even used in the leftmost position of existing TLD labels. In order to confirm this, CORE Internet Council of Registrars conducted a thorough research regarding whether operational or rendering issues occurred for any existing ASCII-only top level domain in the past. The results of this research confirmed the assumption.
Since the registry does not support right-to-left scripts on the second level, bi-directional issues (like the ones described at http:⁄⁄stupid.domain.name⁄node⁄683) will not occur.
Moreover, the gTLD string exclusively uses characters from a single alphabet, does not contain digits or hyphens, and it contains characters that are not subject to homograph issues, which means there is no potential for confusion with regard to the rendering of other TLD strings.
Finally, CORE Internet Council of Registrars set up a testing environment for the .radio TLD using the CORE Registration System, including an EPP SRS, Whois and DNS servers, in order to conduct a series of tests involving typical use cases (like web site operation and e-mail messaging) for a TLD. The tests revealed no operational or rendering issues with any popular software (web browsers, e-mail clients) or operating systems.

18. (a) Describe the mission⁄purpose of your proposed gTLD.

The European Broadcasting Union (EBU) is applying for the .radio Top Level Domain (TLD) on behalf of the global Radio community, in order to provide it with a trusted and secure name space to facilitate its transformation into the next generation radio industry. The Radio community is defined as all those entities and individuals related to audio content distributed mainly by broadcasting to wide communities of listeners throughout the world (see response to Q20 below for a detailed community definition).

The European Broadcasting Union is one of the largest associations of national broadcasters in the world, with the highest turnover (CHF 404 million in 2011) and with offices in eight countries over three continents. It ensures high quality content and programs, shares knowledge and expertise and promotes the interests of its Members across all areas of its public interest mandate and its business.

EBU is also applying for the .eurovision TLD for its own exclusive use as an Institutional TLD and an integral part of EBU’s institutional and corporate communications strategy aimed at raising the profile of the organization, as well as uniting EBU’s operations and activities under a single online identity.

The.radio TLD, on the other hand, is a community-based application to provide the radio industry with a platform through which radio broadcasters and other radio industry stakeholders worldwide will collaborate to promote audio content distribution and community-wide services, promoting quality and competition in the public interest, for the benefit of listeners and Internet users.

EBU will benefit from the support and active involvement of its sister Unions grouped in the World Broadcasting Union (WBU). They will jointly lead the .radio TLD policy development process through the establishment of a World Radio Advisory Board, which will also include representatives of other stakeholder groups from the Radio community such as: AMARC (Association Mondiale des Radiodiffuseurs Communautaires), AER (Association of European Radios), and many others.

The generic goals of the .radio TLD are to:

(a) facilitate the creation and dissemination of audio content and foster digital communications amongst and within entities and individuals composing the Radio community and listeners throughout the world;

(b) advocate the fundamental rights of communication and freedom of expression through radio services, and in particular the right of radio broadcasters (and other radio providers) to communicate;

(c) provide a platform for the development of radio and .radio-specific servicesin the digital space;

(d) provide the community with a trusted and secure namespace enabling and facilitating its transformation into the next generation radio industry;

(e) promote the Radio community and the radio industry in general and foster the development of both industry and community.



These goals are to be achieved by:

(i) actively designing and developing the .radio TLD name space with a focus on the needs of the community, involving broadcasters, Internet radios, radio amateurs, listeners and other stakeholders;

(ii) allowing registration of second-level domains in the .radio TLD by entities and individuals related to audio content distributed mainly by broadcasting to wide communities of listeners throughout the world, the basic criterion being the requirement to use the domain names registered for the purpose of online audio content distribution to wide communities of listeners.

(iii) operating the .radio TLD for the benefit of the .radio community, the Internet, and public interest in general.

18. (b) How do you expect that your proposed TLD will benefit registrants, Internet users, and others?

Radio broadcasting is the oldest electronic media, but still the most efficient and reliable one, even in the Internet age. In fact, it responds perfectly to all the new media challenges of the digital age: it is wireless, mobile, sustainable. It is the most resilient media in case of emergencies and is totally flexible.


Because of these characteristics, it remains the perfect vehicle for all kinds of Public Interest communications, from one to many and even within communities. This explains whyeven today it is the most widely used communication tool in the world, the only one reaching more than 90% of the world’s population,television, telephony and the Internet lagging far behind in all global statistics. Even when other media will have caught up, radio will remain as an integral part thereof.


Through radio, billions people worldwide receive emergency communications in cases of disaster, access information they need for their daily lives (news, traffic information , commerce, education, weather forecast and so on), receive communications from authorities and governments.FM radio keeps communities together locally, short waves unite them globally. That is why Public Service Radio exists in every country in the world. Even where broadcasting is considered purely a commercial activity, public interest is involved.


Where it has already occurred, and soon in LessDeveloped Countries as well, the transition of Radio Broadcasting communities to the Internet combines the best of the radio media with the two-way communications that the web provides. But this will not happen overnight; the process needs to be carefully prepared and setup, possibly by those who have managed and operated radio smoothly and efficiently in the first 85 years of its existence as a media.


For all of these reasons the EBU, on behalf of the world radio community, is applying for the .radio TLD, not only to benefit its future registrants, but the much wider community of users as well.


In submitting an application to ICANN for the creation of a .radio TLD, the Radio community intends to create a predictable, secure and trustable name space. 

b) i. What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

On behalf of its members, the EBU transmits sports, news and music events to broadcasters worldwide through its satellite and fiber network. EBU services include radio network services, a news exchange for radio, an exchange of music concerts, live events worldwide, radio studies and market research, as well as coordination of broadcast retransmission between member and⁄or non-member participants. Other Unions and Associations participating in the ʹ.radioʹ project, offer similar services, albeit on a different scale. 

The EBU and other WBU members promote cooperation between broadcasters and facilitate the exchange of audio and audiovisual content. The EBUʹs mission includes contribution to freedom of expression, media freedom and pluralism, development of technology, communications beyond national borders, cultural diversity, dialogue between cultures, cultural identity, social integration and cohesion for all peoples and communities. 

Radio also plays a crucial role in helping communities or entire countries to rebuild and recover from the devastation and destruction of a natural or man-made disaster. During a crisis, radio enables the authorities to relay important information such as news coverage and emergency warnings. Very often, radio is the only channel through which victims can trace lost family members, or simply share their experiences. In the future, the interaction between broadcasting and Internet radio could open new enhanced possibilitiesfor disaster recovery interventions.

Taking all of this into account, the goal of the .radio TLD in terms of specialty is to focus on the needs of the community, understood as all those entities and individuals related to audio content distributed mainly by broadcasting to wide communities of listeners throughout the world. 

Service levels will match or exceed the high end of currently existing TLDs. The .radio Registry will vigorously build up and defend the reputation of the .radio TLD as an orderly and progressive TLD, under the oversight and with the support of the World Radio Advisory Board, and most notably of the Broadcasting Unions forming the WBU.

This World Radio Advisory Board will guarantee the stability and suitability of the .radio policies. These will be adopted in a transparent way with quality of service and the overall benefit of the whole Radio community including the Less Developed Countries, as their ultimate goals.

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

The .radio TLD fills a large gap in terms of consumer choice. From a competition standpoint, it creates a level playing field with respect to the market power of large unspecific TLDs. It is naturally differentiated from other TLDs by its scope, by its governance model and by its intrinsic meaning. A community TLD is by definition one of the most suitable tools to broaden and raise the profile of diversity and variety on the Internet. The .radio TLD focusses on content creation and distribution and services of general interest to the whole community, ensures a purposeful and meaningful TLD created to serve the needs of the radio industry and listeners, andacts as a strengthening tool for a wide community of industry players, broadcasters, public service stakeholders, web radios and individual amateurs. 


Innovation is greatly encouraged by the proactive structured development of the name space. The development process involves an open procedure with calls for proposals for purpose-built localized services based on designated portions of the .radio name space. This approach helps use innovative potential worldwide for the benefit of the community and for the evolution of the global Internet.


Since the early days, broadcasters have used common norms and standards to facilitate data communication. Today, more powerful standards are required due to the high volume of data exchanged over the Internet.Technology also has become more sophisticated. The radio industry is a closed community, one where a high level of co-operation and trust bridges the gaps of geography, language and inequalities.

The .radio TLD will encourage the radio community to adopt best practices in cyberspace and provide an exemplary registry model. The TLD will make it possible to unambiguously distinguish the Radio community players through an ordered domain name structure.

b) iii. What goals does your proposed gTLD have in terms of user experience?



Compared to most existing TLDs, the .radio TLD user experience will greatly enhance predictability and memorability of domain names. A community-based focus, an orderly development process and strong intellectual property protection all ensure that users will generally find the services they are looking for under the names they intuitively tend to use for them.

User experience is further improved by the specificity of a community TLD that will provide the community and those wanting to enjoy the content created and distributed by its members with the means to identify such content under a TLD explicitly designed for the purpose. 

As an example, the recent tsunami and nuclear accident in Fukushima has shown that radio is the only reliable media capable of reaching the entire community in a disaster area in real time. All of the interveners working in the disaster area needed access to very specific information. Intuitive radio domain names could help save lives in natural disasters. We plan to reserve emergency numbers in the 2LD for use by the relevant SOS authorities, e.g. 112.radio (Europe) or 911.radio (Americas). 


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

The registration policies are differentiated between pre-launch phase (A), launch phase (B) and general availability (C). All policies will be approved and reviewed by the World Radio Advisory Board established by EBU and its sisters Broadcasting Unions in the WBU, with participation of other Radio community stakeholders.

A) Pre-launch phase: Name-space mandates and Frequent Names Global Contention Resolution

During pre-launch, projects and content provision commitments are actively sought and negotiated for key public-interest portions of the name space. All potential mandate holders are subject to screening, thorough pre-validation, and very strict rules on using the .radio names to promote the TLD adoption and innovative and public-interest oriented services to the .radio community. There will be a clear and low limit on the number of pre-launch names.

The Frequent Names Global Contention Resolution is a special global community contention resolution program, mainly for frequently used radio station names aiming to achieve a coherent, consistent and friendly policy for the .radio TLD used by the worldwide radio broadcasters, and specially, to minimize conflicts.


B) Launch phase: Sunrise, Defensive Registrations and Expanded Name Selection.

During the Launch phase, all registrations are thoroughly pre-validated; launch phase pre-validation depends on priority status but will always involve community nexus and name selection.

So-called Sunrise phase will comprise the following categories:

1. Broadcasters’ Unions
2. Licensed Radio Broadcasters
 2.1 International Broadcasters
 2.2 National Broadcasters
 2.3 Regional Broadcasters
 2.4 Local Broadcasters
 2.5 Community Broadcasters*
3. Trademarks
 3.1 Trademarks used for radio related activities for example companies providing specific services, equipment, radio programmes, etc.
 3.2 Defensive registrations by non-eligible applicants
4. Internet radio
5. Licensed amateur radios and clubs
6. Radio professionals
7. Above categories for expanded name selection when not protected by trademarks

*Community Broadcasters’ serve geographic regions and communities of interest and are legally defined as a distinct broadcasting sector in many countries. They are included in Category 2 and will be considered accordingly to their geographic dimension (i.e., international, national, regional or local).

Please note that Categories 1 and 2 are also subject to pre-launch Frequent Names Global Contention Resolution, as described above and detailed in response to Question 20 below. 

Categories 1-6 have strict name selection rules (i.e. radio stations’ names or usual abbreviations of names), while Category 7 will allow, for instance, radio program⁄show names or other names related to the applicants actual activities within the radio industry. No “fantasy” names will be allowed.

It should be noted that category 3.2 will be open to any registrant for registered trademarks validated by the Trademark Clearinghouse that ICANN is setting up. But if registrant is not an entity providing specific services to the radio industry and⁄or the .radio community, the applicant will not be eligible in terms of the .radio policies, and the name will be blocked on the registrant’s behalf, but not delegated for use. This mechanism is a further guarantee to right holders, but given the extensive protections derived from the community-based policies of the TLD and the public-interest oriented Registry, EBU does not anticipate any significant recourse to this mechanism as protections and safeguards are high.

C) Live Registry: ongoing registrations

At general availability, community nexus. name selection and content and use requirements are subject to post-validation throughout an extensive compliance program (see answer to question 29 for more a more detailed explanation of the compliance procedure). The ongoing compliance program will regularly be adapted to current needs based on experience and audit findings. Community nexus validation, name selection and permitted use checks combined with strong protection of trademarks helps stamp out cyber-squatting and abusive registrations.

Please see answers to Questions 18 (c) and 20 below for further description of these phases, and their requirements.


b) v. 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.

Even if the majority of .radio registrants are expected to be corporations rather than individuals, EBU recognizes first hand that this is a relevant issue and an evolving area of law in which there is no international standard. The protection of privacy and confidential information of registrants and users will comply with applicable Law, in particular the Swiss Data Protection framework. Within the bounds of applicable regulations, the registry will implement anti-data mining measures by way of rate limitation, authenticated access or white-listing⁄black-listing, as well as tools to prevent unauthorized recourse to repetitive automated access.

The .radio Registry also intends to incorporate contractual language in its Registry Registrar Agreement (RRA) modeled after language which has been included in the template Registry Agreement and which has been successfully utilized by existing ICANN gTLD registry operators. Specifically, Registry Operator shall notify Registrar of the purposes for which Personal Data submitted to Registry Operation by Registrar is collected, the intended recipients (or categories of recipients) of such Personal Data, and the mechanism for access to and correction of such Personal Data. Registry Operator shall take reasonable steps to protect Personal Data from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars. Registry Operator may from time to time use the demographic data collected for statistical analysis, provided that this analysis will not disclose individual Personal Data and provided that such use is compatible with the notice provided to registrars regarding the purpose and procedures for such use.

Finally, EBU will propose to ICANN, either through the Registry Agreement negotiations or through Registry New Services procedure once signed, a Whois service that allows individual registrants to opt-out from publishing their personal contact data, as other existing gTLD Registries have done.

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

ICANN can trust the oldest communications industry to be serious, professional and energetic in communicating and outreaching the goals, benefits and policies of .radio to the relevant communities. In this regard EBU and its sister Unions within WBU will be leading this program in reaching out to all its members, and beyond.

The .radio TLD has outreach programs adapted to each phase of its introduction. 

The Pre-launch negotiations involving calls for projects by innovators and pioneer users. They foster the intuitive usability of the .radio TLD with a focus on the needs of the Radio community. Once these domain names are active, they become an outreach mechanism in their own right because they establish the touch-and-feel of the .radio TLD in the minds of the users. 

The Launch phase will involve outreach mechanisms that specifically leverage the Broadcasting Unions, radio conferences, and other general activities for each sector of the community. Special emphasis will be placed in raising awareness of broadcasters, Internet and amateur radios and other industry players from Less Developed Countries. 

Promotion codes distributed through community-specific channels are a form of outreach available at any time. They are also a low-cost method to achieve community nexus and to prevent abusive registrations. WBU and the other related associations will play a very active role in this regard.

18 (c) 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)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

The community-based approach of .radio (see answers to Q20 below for more details), with its rules for Eligibility, Name Selection, Accepted Use and its vigorous Enforcement practices (see answer to Q29 below for additional details) ensure that trademark owners and other rights holders will not face the usual costs of monitoring, and defending against abuses. Nor would they feel forced to register their names, identities, products, services, brands in .radio to prevent abuses. 

The .radio Registry will furthermore implement a vigorous and comprehensive general malicious conduct prevention and mitigation policy to reduce the number, importance and effects of abuses harming the general users.

Answers to enumerated questions:

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

Categories 1 and 2 (Broadcasting Unions and Licensed Broadcasters) will be subject to the Frequent Names Global Contention Resolution procedure during the Pre-Launch phase. This procedure will involves extensive mediation and alternative dispute resolution efforts to minimize conflicts among applicants. 

As described above, during the Launch Phase (Sunrise), the first-come⁄first-served principle is not universally applied. Multiple applications for the same domain will be solved through the following mechanisms:

A) Hierarchy among Sunrise⁄Landrush categories (qualifying applications from higher-ranked categories take precedence over qualified applications from lower-ranked categories). Please see answer to 18 (b) (iv) above.

B) Within same category (and subcategory), Dispute Resolution Mechanisms consisting on:

B.1) Proposed Mediation and⁄or Arbitration (if both parties agree)

B.2) If conflict arises among applications within other categories (3 to 7), the resolution could come through an auction mechanism of last resort.


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


The pricing models will be set-up by the World Radio Advisory Board (WRAB) as defined above on behalf of the .radio community to serve the best interests of that community. These interests include both sufficient funding of the Registry (but not profits as EBU is a non-for-profit entity) and fair pricing to registrants. The model will not be geared towards favoring speculators, massive warehousing or names or otherwise providing incentives for the aggregate of non-used (in the sense of content-less, service-less) names.

The .radio Registry, truthful to its public interest roots and orientation, will fully take into account the differentiated financial burdens that nominally equal pricing carries to Broadcasters and other parties located in different parts of the world. Therefore, in an effort to promote not only fairness, but also access to registrants but also promote diversification and global reach to all users, it will have reduced pricing for Broadcasters and other registrants such as web and amateur radios located and operating from Less Developed Countries.

This differentiated, preferential, reduced, exclusive pricing will be in place both at Launch and during Ongoing Registrations phases. In this latter case, the use Promotional Codes distributed through the different Regional Unions will both allow and pre-validate eligibility for such discounts. 


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.

EBU is committed to provide domain name registration services in accordance with the requirements, notices and periods set forth in the future .radio TLD Registry Agreement, ICANN Consensus Policies and best practices rules. The .radio TLD will be based on predictability regarding pricing. The .radio Registry-Registrar Agreement will not contain specific or non-standard clauses regarding price escalation between the .radio Registry and its registrars (or registrants).
The .radio business plan is designed to avoid any future necessity to increase registry price in real terms. The fundamental principle is prudence: starting from very conservative price levels and gradually lowering them. This method ensures sufficient financial reserves, favours optimal allocation of domain names, helps prevent misuse and supports an orderly registration process.

Domain name registrations will be available for periods ranging for one to ten years to registrants through registrars. In some exceptional cases, such as Sunrise, minimum period will be two years.

Yes

A. Definition of .radio
The European Broadcasting Union (EBU) is applying for the .radio TLD on behalf of the Radio 85 years old community, to which it belongs. The Radio community is defined as all entities and individuals related to audio content distributed mainly by broadcasting to wide communities of listeners throughout the world.
Registrations under .radio are restricted to bona fide members of the Radio community and subject to the further requirement that the registrant’s actions in the Radio community, as well as the registrant’s use of the registered domain name, must be:
(i) generally accepted as legitimate; and
(ii) beneficial to the cause and the values of the radio industry; and
(iii) commensurate with the role and importance of the registered domain name; and
(iv) in good faith at the time of registration and thereafter.
B. Composition of the community
The Radio industry is composed of a huge number of very diverse radio broadcasters: public and private; international and local; commercial or community-oriented; general purpose, or sector-specific; talk or music; big and small. All licensed radio broadcasters are part of the .radio community, and so are the associations, federations and unions they have created (such as the EBU, applicant for the .radio TLD with the support of its sister Unions; see below for more details on Radio industry representativeness). Also included are the radio professionals, those making radio the fundamental communications tool that it is.
However, the Radio industry keeps evolving and today, many stations are not only broadcasting in the traditional sense, but also webcasting and streaming their audio content via the Internet. Some are not broadcasters in the traditional sense: Internet radios are also part of the Radio community, and as such will be acknowledged by .radio TLD, as will podcasters. In all cases certain minimum standards on streaming or updating schedules will apply.
The .radio community also comprises the often overlooked amateur radio, which uses radio frequencies for communications to small circles of the public. Licensed radio amateurs and their clubs will also be part of the .radio community.
Finally, the community includes a variety of companies providing specific services or products to the Radio industry.
C. Applicant and Governance
The EBU wishes to establish this TLD as a trusted and high-quality namespace helping industry actors, radio listeners and Internet users in general to improve the quality, security, accessibility and predictability of radio services online, in the public interest.
The .radio TLD is submitted by the EBU, mandated by its Members as well as the global community of Radio Broadcaster: the World Broadcasting Unions (WBU), the Association Mondiale des Radiodiffuseurs Communautaires (AMARC) and other relevant regional radio associations. EBU is one of the largest associations of national broadcasters in the world. It contributes to fostering the core values of broadcasting; its mission and mandate, grounded in technical, economic and cultural values, is to serve its members equally on behalf of public interest.
The policy development process will be carried out in consultation with the World Radio Advisory Board, the .radio community policy advisory body that will include representatives from the WBU and other radio associations and organisations worldwide.
Answers to enumerated questions:
((How the community is delineated from Internet users generally))
The radio industry is a long-standing, well-defined industry sector. Since radio is everywhere, and most homes have a radio receiver, most people are radio listeners, and the Radio community uses a concrete and precise set of definitions and categories to make the community delineation operative for registration purposes:
1 Broadcasters’ Unions
2 Licensed Radio Broadcasters
2.1 International Broadcasters
2.2 National Broadcasters
2.3 Regional Broadcasters
2.4 Local Broadcasters
2.5 Community Broadcasters
3 Trademarks
3.1 Trademarks used for radio related activities for example companies providing specific services, equipment, radio programmes, etc.
3.2 Defensive registrations by non-eligible applicants
4. Internet radio stations
5 Licensed amateur radios and clubs
6 Radio professionals
1. Broadcasters’ Unions
The EBU is a member of the WBU, the platform that gathers 8 regional Broadcasting Unions of the World. For WBU membership and further information see Q11H and Q20B below. Beyond this regional Unions, other international and national broadcasting associations are also part of this category, such as AMARC (Association Mondiale des Radiodiffuseurs Communautaires), AER (Association of European Radios), and many others.
2. Licensed Radio Broadcasters
To use the radio spectrum, Radio broadcasters obtain licenses from the relevant authorities, which might classify them into the above sub-categories. This makes membership, and hence eligibility in .radio TLD terms, a relatively straightforward issue.
3. Trademarks
For trademarks used for companies providing .radio related services, equipment and audio content and defensive registrations by non-eligible applicants.
4. Internet radio
This category is much more fluid and less organized than the two previous ones. No licensing system; no organized registration. The .radio Registry, with the help of the World Radio Advisory Board and in consultation with the sector, will set objective eligibility requirements (streaming, content production) for .radio.
5. Licensed amateur radios and clubs
Amateur radio is also organized through a strict and global licensing system where every license code is unique, often via clubs or other entities.
6. Radio industry providers and partners.
Radio professionals and those companies able to demonstrate specific products, such as radio equipment manufacturers (often specified for the purpose), advertising companies, audio content and service providers will also be accepted as part of the community.
Please note that these categories may be reorganized into different groups or hierarchies for specific purposes, such as:
- Frequent Names Global Contention Resolution and Sunrise priority, as explained under Q18 above, in order to minimize conflicts and opportunistic risks.
- Pricing, as some participants in the same category may enjoy different pricing levels during the Launch phase or benefit from Promotional Pricing afterwards, as in the case of broadcasters, internet radios and amateur radios located and operating from Less Developed Countries.
((How the community is structured and organized))
The Radio community is structured mainly under 8 world broadcasting Unions which represent radio broadcasting interests at the World Radio Frequencies Conferences and coordinate their work through the WBU, as described in response to Question 11H.
The WBU works through a number of permanent working commissions, such as the Technical Committee, which deals with technical standardization; the Sports Committee, dealing with the coverage of world sports events (such as Olympic Games and football world championships); ISOG (International Satellite Operations Group), dealing with satellite contribution circuit issues. Besides the WBU, other specialized broadcasting associations represent specific radio interests, such as the already mentioned AMARC and AER.
((The current estimated size of the community))
Radio is everywhere, both in the sense of radio services and radio listeners. According to UNESCO, radio can be found in the homes of 75 per cent of the world population, which means that 5.1 billion people have access to radio stations. Currently, there are about 50,000 radio stations worldwide according to the figure published by CIA World Facts on their website. In addition, there are at least another 50,000 web radios.

The EBU, mandated by its Members and with the support of WBU and other relevant organisations, is applying for a .radio TLD on behalf and for the benefit of the entire Radio community in the public interest.
((Relations to any community organisations))
((Relations to the community and its constituent parts⁄groups))
Based in Geneva, Switzerland, the EBU is one of the largest associations of national broadcasters in the world. The EBU has a staff of 350 operating in Geneva with offices in Beijing, Brussels, London, Madrid, Moscow, Rome, Singapore, New York and Washington DC. It has 74 active members and brings together 85 national media organisations in 56 countries in and around Europe. The member broadcasters reach an audience of 650 million listeners and viewers weekly.
The EBU is a member of the World Broadcasting Union (WBU), the platform that gathers regional Broadcasting Unions (as described in response to Q11H).
The EBU official languages are English and French. It is an international non-governmental organisation incorporated as not-for-profit Association under Swiss Law, registered under its French name ʺUnion Européenne de Radio-Télévisionʺ (UER).
The EBU was formed on 12th February 1950 by 23 broadcasting organisations from Europe and the Mediterranean at a Conference at Devon. UK. It was on the 6th of June 1954 that Montreux became the venue for the first transmission by the EBU’s Eurovision Network. The EBU inheriting the mantel of the International Radio Union that was founded in 1927, the European Broadcasting Union promotes cooperation between broadcasters and facilitates the exchange of audio and audio-visual content. The EBUʹs mission includes contribution to freedom of expression, media freedom and pluralism, social integration, development of technology and cohesion for all peoples and communities.
On behalf of its members, the EBU transmits sports, news and music events to broadcasters worldwide through its satellite and fiber network. EBU services include radio network services, a music exchange for radio, a news exchange for radio and television, radio studies and market research as well as coordination of broadcast retransmission between member and⁄or non-member participants. The EBU conducts collective negotiation of broadcasting and re-transmission rights on behalf of its members, in particular sports rights. It coordinates joint productions for radio and television. EBU technical activities include research and development of new media as well as standards development. Key areas have been radio data system (RDS), digital audio broadcasting (DAB), digital video broadcasting (DVB), high-definition TV (HDTV). The EBU promotes open technical standards and interoperability. It studies digital technology for production and transmission and issues recommendations on appropriate solutions.
The EBU membership is composed of Active members and Associate Members (as described in response to Question 11(H)
The EBU application for the .radio TLD is the expression of a large support base within the community of radio broadcasting worldwide and the decision to apply was taken at a regular gathering of Directors General of the various Unions.
All member Unions of the WBU have written letters of endorsement for the EBU application as follows:
ABU (Asia-Pacific Broadcasting Union), representing national broadcasters of Asia and Oceania reaching audiences of 3 billion users, (60 countries).
AUB-UAR (African Union of Broadcasters), representing national broadcasters of Africa, (50 countries).
NABA (North American Broadcasting Association), representing the national broadcasters of United States, Mexico and Canada.
OTI (Organización de Televisión IberoAmericana), representing national broadcasters of Latin America and the Iberian peninsula, (60 countries).
CBU (Caribbean Broadcasting Union) representing national broadcasters of the Caribbean, (29 countries)..
AIR-IAB, (Asociación Internacional de Radiodifusión) representing commercial broadcasters from 16 South American countries plus a number of other radio associations on other continents.
ASBU (Arab States Broadcasting Union) representing broadcasters of the 23 Arab League member countries.
The EBU has also garnered support from other broadcasters’ associations covering continental regions or specialized channels:
AIB - Association for International Broadcasting, grouping international broadcasters world-wide.
AER - Association of European Radios: commercial radio broadcasters of Western Europe.
AMARC - Association Mondiale des Radiodiffuseurs Communautaires: all community radios in 115 countries around the world.
EGTA - European Association of Television and Radio Sales Houses, the regional association that gathers all vendors of Radio and TV advertising around Europe.
URTI - Union Radiophonique et Télévisuelle Internationale, a UNESCO non-profit recognized association that promotes and organizes the exchange of radio and TV programmes free-of-charge between broadcasters from the North and the South of the world.
IMDA - Internet Media Device Alliance, bringing together a number of world radio stakeholders specialized in interactive services and related equipment.
Finally, and to bear witness to the special character of this application for a community based TLD, the EBU has asked one very important partner in the radio world - the Metropolitan Opera of New York - to endorse the request. The Met endorsement demonstrates that a community-based .radio TLD is not only of interest for broadcasters, but also for all those who cooperate with this community to promote cultural diversity and excellence.
The Met distributes its concerts worldwide through a network of selected cultural radio stations in Europe, Asia, Africa and the Americas, making it possible for millions of listeners in every country to share in a unique musical experience, straight from this most prestigious New York concert and opera stage.
For further information, please see attachments to 20 (f).
((Accountability mechanisms of the applicant to the community))
The EBUʹs supreme governing body, the General Assembly, meets twice yearly. The General Assembly appoints an Executive Board of 11 members. All EBU Members are equally represented and have the same voting rights. While EBU membership is reserved to national broadcasters, participation is also open to associate Members and broadcasters without national affiliation (Approved Participants).
Most of the EBU services are available to any type of organisation irrespective of activity or EBU membership (such as non-member broadcasters, sports federations, host broadcasters, rights owners, cultural institutions).
EBU, the WBU and other relevant supporting organisations will set up a .radio policy advisory body called WRAB (World Radio Advisory Board), composed of radio broadcasters and other representative stakeholders of the community to oversee both the policies and operations of the .radio TLD Registry.
Radio has been a critical tool in modern societies for developing social accountability. The public interest is at the heart of the industry, and its members are fully committed by nature and vocation to transparency, accountability and social responsibility. EBU, the WBU and other relevant supporting organisations commit to enshrine those values into the .radio Registry.

Q20-Community-based-Designation-c-communityBasedPurpose
(c) Provide a description of the community-based purpose of the applied-for gTLD
EBU and WBU have developed and encouraged industry standards to communicate between heterogeneous systems and enable industry-wide data exchanges. The advent of the Internet, IP and adequate naming standards facilitates the integration of the industry on a wider scale and its extension to partners, suppliers and customers.
The great potential impact of the proposed domain name deserves recognition by ICANN as a chartered TLD to safeguard its open access by the relevant community.
((Intended registrants in the TLD))
The intended registrants, as explained in response to question 20a above, are those operating radio services, as part of the Radio community including broadcasters and their representative organisations; Internet radios and their organisations; amateur radio operators and their organisations, and companies and other entities providing products and services specifically targeted to the Radio community.
It is not intended that radio listeners become registrants, as this would make eligibility rules extremely complex or even ineffective, name selection difficult to assess and acceptable usage policies hard to monitor. It would further lead to enforcement overburden and compliance levels possibly too low to be acceptable.
((Intended end-users of the TLD or description of the various sub-communities))
The main end-users are those already using broadcast radio channels or stations, as well as Internet users in general, and anybody interested in radio as a service, an industry, a technology, or in any other possible way.
((Related activities the applicant has carried out or intends to carry out in service of this purpose))
Founded in 1950, the EBU promotes cooperation between broadcasters and facilitates the exchange of audio and audio-visual content. It also ensures high quality content and programs, shares knowledge and expertise and promotes the interests of its Members across all areas of its business.
EBU and WBU have developed and encouraged industry standards to communicate between heterogeneous systems that made it possible for radio systems to enable industry-wide data exchanges.
EBU technical activities include research and development of new media as well as standards development. Key areas are Internet content delivery systems and infrastructures, radio data system (RDS), digital audio broadcasting (DAB), digital video broadcasting (DVB), high-definition TV (HDTV). The EBU promotes open technical standards and interoperability. It studies digital technology for production and transmission and issues recommendations on appropriate solutions.
The advent of the Internet, powerful mobile handsets and the adequate domain naming standards further facilitates the integration of the industry to be carried out on a wider scale and extended more easily to its partners, suppliers and listeners worldwide.
On behalf of its members, the EBU transmits sports, news and music events to broadcasters worldwide through its dedicated satellite and fiber network connected directly to broadcasters and other media platforms. EBU services include radio network services, a music exchange for radio, a news exchange for radio and television, radio studies and market research as well as coordination of broadcast retransmission between member and⁄or non-member participants. The EBU conducts collective negotiation of broadcasting and re-transmission rights on behalf of its Members, in particular sports rights. It coordinates joint productions for radio and television.
Eurovision, a department of EBU, is known as the premier distributor of sports and news content for the world’s top broadcast and media platforms. This is a mature and reliable business. It is also known for various international television co-productions coordinated by the EBU, such as the annual Eurovision Song Contest (ESC) since 1956. EBU is, in financial terms, the largest association of national broadcasters in the world.
((Explanation of how the purpose is of a lasting nature))
The purpose of worldwide radio organisations such as EBU, and other WBU member Unions and other relevant sector organisations, has always been to help their members keep up with technological change. Terrestrial services are evolving , and in keeping with the current trend, radio is increasingly an internet-based or Internet using service. The efforts of the EBU, its Sister Unions and the Radio community at large are aimed at better serving the members of the community and the billion radio listeners worldwide. It is the ʺraison dʹêtreʺ of EBU and the other WBU Unions, in line with the overarching public interest goal of radio as a service. The .radio TLD will evolve with the radio industry, and the reverse is true as well. For radios around the world, being easily accessible over the Internet, within a trusted namespace with easily predictable names is not incidental, it is essential.

Q20-Community-based-Designation-d-stringRelationshipToCommunity
(d) Explain the relationship between the applied-for gTLD string and the community identified in 20(a).
Explanations should clearly state:
- relationship to the established name, if any, of the community.
- relationship to the identification of community members.
Radio, means the operators, services and technologies defined here as the Radio community. Radio also means, and is, audio broadcasting. The station broadcasting or streaming that audio content is radio, and the company performing the audio broadcasting is radio. A radio is the receiver used by the listener. Radio is the name everybody uses to refer to the entire industry, and the whole community.
With the advent of streaming via the Internet and the continuous delivery of audio content to broad groups of listeners, we now often refer to the new services as web, net or Internet radio.
The Radio community could not find any other name, even vaguely appropriate, to designate the TLD for its community. .radio is the TLD for the Radio community and could not be anything else. It is perfectly tuned.
((any connotations the string may have beyond the community))
Radio might be used, as well, as part of the name of some technologies such as “Bluetooth radio” or “RFID” (Radio Frequency IDentification) but its overwhelming meaning and use, the one with most social relevance and the only one that has meaning when used alone as “radio”, is the one described here for the Radio community.

Q20(e):
((Eligibility: who is eligible to register a second-level name in the gTLD, and how will eligibility be determined))
As described in the response to Question 20(a), two types of conditions must be fulfilled for the right to register a .radio name. These are:
(A) community membership defined as bona fide membership in the any of the eligible categories, as defined in 20 (b) above, and
(B) the additional requirements that the registrant’s actions in the Radio community, as well as the registrant’s use of the registered domain name, must be:
(i) generally accepted as legitimate; and
(ii) beneficial to the cause and the values of the radio industry; and
(iii) commensurate with the role and importance of the registered domain name; and
(iv) in good faith at the time of registration and thereafter.
These conditions must always be fulfilled. The strength of the validation is kept in line with the importance of the underlying domain name base bearing in mind the assumption that a typical user would reasonably make.
As examples, for the Category 2, the license to broadcast is a condition of eligibility, as holding a valid trademark is a condition for category 3, or a radio amateur license is for category 5, as a pre-requisite for all other conditions explained here.
To facilitate validation, registrants are required to state their intended use of the registered domain name. A false statement of intended use is an indication of bad faith and can be the basis for the suspension of the domain name.
The validation may be assisted through pre-identification of potential registrants using existing community channels, such as Union⁄Association membership, either by direct checking in the membership’s database or by the distribution of Promotion Codes to members.
After the pre-launch and launch phase, the validation mode goes from pre-validation to post-validation and later to statistically targeted random validation, backed up by a on-going enforcement program.
The validation and enforcement program are supported by an integrated issue tracking system. This system allows validating agents and personnel to cooperate and interact with the registrant. The system keeps track of decisions made by the agents and stores supplemental documentary evidence that may be supplied by the registrants.
((Name selection: what types of second-level names may be registered in the gTLD))
The fundamental rule on which name selection is based is part of the policy principles: the registrant’s nexus with the Radio community and use of domain must be commensurate to role and importance of domain registered.
The role and importance of the domain name is based on meaning an average user would reasonably assume in the context of that domain name.
This criterion also applies to the strength of the documentation or proof required of the registrant.
The pre-Launch phase (Frequent Names Global Contention Resolution) is a special global community contention resolution program for Categories 1 and 2 only, mainly for frequently used radio station names aiming to achieve a coherent, consistent and friendly policy for the .radio TLD used by the worldwide radio broadcasters, and especially, to minimize conflicts.
During the Launch phase the different categories will be able to apply for their corporate or brand names, such as the name commonly used for the radio station, or the “license” name for radio amateurs.
Below those privileged categories, as explained in Q18 above, and afterwards, in the on-going registrations or Live Registry phase, eligible members will also be allowed to register other names, but always with the express restriction stated above, allowing for instance names of programs, campaigns or any other initiative effectively related to their radio activities, and commensurate to the role and importance of such domain name.
Pre-definition of the namespace, especially names with significance for the Radio community from a public service or public interest standpoint, is developed through special programs with strong selection processes, based on proposals made by parties interested in providing content on such domain names. This process not only covers the identity and legitimacy of the party entrusted with the operation of the domain(s), but also a defined obligation with respect to the content to be provided for the benefit of the Radio community and the public.
((Content⁄Use: what restrictions, if any, the registry operator will impose on how a registrant may use its registered name))
As described in the response to Question 20(a) the use of the domain must be:
(i) generally accepted as legitimate; and
(ii) beneficial to the cause and the values of the radio industry; and
(iii) commensurate with the role and importance of the registered domain name; and
(iv) in good faith at the time of registration and thereafter.
(i), (ii) and (iv) specifically refer to the Accepted Use of .radio domain names by .radio Registry.
This is verified on the basis of:
1) the intended use statement supplied by the domain registrant at the time of registration (or possibly updated later)
2) the on-going enforcement program (see below)
((Enforcement: what investigation practices and mechanisms exist to enforce the policies above, what resources are allocated for enforcement, and what appeal mechanisms are available to registrants))
The purpose of the enforcement program is to protect the credibility of the .radio TLD for the Radio industry, the radio listeners and the Internet users in general.
In particular, it upholds the community-based purpose of the .radio TLD and helps prevent misuse or malicious behaviour.
The enforcement program is based on statistically targeted random investigations and on a complaint follow-up process. The statistical targeting is strongly automated and involves the use of search engines and the analysis of registry data related to behaviour of registrants.
Depending on the type of misuse to be investigated, website content or content sent to victims of abuse will be reviewed and analysed by the Compliance Officers.
Enhanced investigation takes place if the registrant has a bad track record in terms of compliance with the rules of the .radio TLD. Other violations of public record (such as UDRP or URS cases) will also be taken into account.
If the intended use cannot be deemed legitimate or has a negative impact on the values of the Radio community, the registration is rejected. If content or use of an existing .radio domain demonstrate that the registrant has shown bad faith by stating a false intended use, the domain name is suspended.
If a registrar is complicit with systematic violations of the .radio policies or causes an unacceptable burden for the validation and enforcement program by negligence, the registry can restrict that registrar’s access to the new registrations, subject its inventory of .radio domains to enhanced investigation and require it to conduct its own post-validation program.
An appeals process is available for all administrative measures taken in the framework of the enforcement program. The first instance of the appeals process is managed by the .radio Registry, while appeals are heard by an independent alternative dispute resolution provider. The Charter for .radio, upon which all these decisions will be based, will be approved by EBU and WRAB (World Radio Advisory Board).
All that said, EBU is convinced that the level of existing misuses and conflicts will range from marginal to non-existent, given the strict eligibility and registration rules, the organized and public-interest oriented nature of the Radio community and the oversight of the Broadcasting Unions and other relevant organisations. But designing a comprehensive and vigorous enforcement program helps in further minimizing those risks. Please see answers to questions 28 and 29 for additional details.

Not Available

No

Q22- Protection of Geo names

1. Reserved List of Geographic Names
 
In accordance with Specification 5 of the proposed TLD Registry Agreement published as Attachment to Module 5 of the Applicant Guidebook by ICANN, and with Governmental Advisory Committee (GAC) advice on geographic names at the second level, the .radio Registry will put the following names on the reserved list, therefore making them unavailable for registration or any other use:


• 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;
 
• 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
 
• the list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.
 
Technically, this is achieved by utilising the advanced domain name rule engine that is part of the CORE Registration System and described in detail in the answer to Question 28. As laid out there, the underlying set of checks can be tuned to block registrations of .radio names based on various syntactic rules, multiple reserved names lists, and patterns. Prior to the launch of the .radio TLD, the rule engine will be configured in accordance with the reserved list mandated by Specification 5, which means that the listed names are not available for registration by registrars.
 
2. Exceptions

The .radio Registry intends to propose to ICANN’s Governmental Advisory Committee (GAC), and, if approved, submit to ICANN for final approval an exception to allow the .radio Registry to use some or all of those itself, in the following circumstances.
• As a conflict-resolution mechanism to accommodate multiple applications for the same string, from radios located in different countries. Example: radio-name.countryA.radio and radio-name.countryB.radio.
 
• Alternatively, for the Registry’s own use to provide directory-like services of radio stations and services for each individual country and territory.
 
Technically, this is implemented via use of the advanced domain name rule engine that is part of the CORE Registration System. As laid out in the answer to Question 28, the underlying set of validations can be adjusted to block or allow registrations of .radio names based on various syntactic rules, and patterns in particular. Once final approval has been received, the systemʹs rule engine will be configured to allow the registration of third level domains like 〈subdomain〉.〈countryA〉.radio, but prohibit the direct registration of 〈countryA〉.radio as a second level domain.


Where required for the individual release of names, the .radio Registry may also issue special authorisation codes for specific third level names to be registered by eligible registrants only. This authorisation code is then used as the domain authinfo in an EPP 〈domain:create〉 request to the .radio SRS, which will let the request bypass the rule engineʹs blocking mechanism and permit the registration.

3. Additional monitoring
 
The .radio Registry does not plan to monitor use of geographic names below the second level (i.e. subdomains used by a .radio domain name registrant), as those procedures are both difficult and ineffective. Available dispute resolution mechanisms are a more adequate resolution procedure in cases where third or higher level domains unduly use country or territory names.
 
 

Q23 - Registry Services


1. Overview

CORE Internet Council of Registrars will provide the technical registry services for the operations of the .radio registry. The CORE Registration System offers the usual registry services for the .radio TLD: Receipt of data from registrars concerning registration of domain names and name servers via EPP (SRS; see also answer to Question 24, SRS Performance); Dissemination of top-level domain (TLD) zone files (DNS; see also answer to Question 35, DNS service, configuration and operation of name servers); Dissemination of contact or other information concerning domain name registrations (port-43 Whois, web-based Whois; see also answer to Question 26, Whois service); Internationalised Domain Names (see also answer to Question 44, Support for Registering IDN domains); DNS Security Extensions (DNSSEC; see also answer to Question 43, DNSSEC). These services are introduced below. For more detailed descriptions, please refer to the answer to the respective question in the gTLD Applicant Guidebook. Additional benefits offered by the registry are full support for Internet Protocol version 6 (IPv6), data escrow, registrar reports and support for Sunrise and Landrush phases. All of these are compliant with the new gTLD requirements. No further registry services according to the definition in the gTLD Applicant Guidebook are offered for the .radio TLD.

The Shared Registry System (SRS) is the central coordinating instance in the overall system concept. It is the authoritative source of the domain, host and contact data, provides client⁄server-based access methods for the registrars and internal personnel to this data, is responsible for the zone generation, performs accounting and reporting, and feeds the Whois servers.

The SRS is responsible for managing the domain registrations by accepting requests for the creation, update and deletion of domains and related information from the registrars, who act on behalf of the registrants.

The CORE Internet Council of Registrars and its developers have ample experience in designing, developing and operating shared registry systems. The CORE Registration System is compliant with established standards like Internet Engineering Task Force (IETF) Requests for Comments (RFCs) and can be customised for the specific needs of a top level domain, ensuring Internet Corporation for Assigned Names and Numbers (ICANN) gTLD standards compliance.

CORE Internet Council of Registrars has been entrusted with the technical operation of the .cat and .museum TLDs on behalf of the puntCAT and MuseDoma registries. Therefore, CORE has the knowledge and experience that are necessary to provide the mentioned registry services. Since the software development is handled exclusively in-house, the .radio Registry Services do not depend on any external companies or developers. Software development at CORE is always based on principles like efficiency, scalability and security by design.


2. Infrastructure Design


2.1 Goals

The design of the .radio registry infrastructure achieves three goals:


2.1.1 High Availability

The resolution of domain names by the Domain Name System (DNS) infrastructure is the most critical part. If it fails, not only a large fraction of Internet users is affected, but other Internet infrastructure depends on the domain name resolution as well, causing a cascade of failures.

The shared registry system itself is also in the focus. While theoretically, a short outage would not have a direct and larger impact to the TLD users, a longer outage can become problematic, especially in the light of DNSSEC: If the registry is unable to re-sign the zone in time, the zone will become bogus and the effect will be similar to a failure of the whole DNS infrastructure.


2.1.2 Scalability

The aspects of scalability must be observed for two reasons: The infrastructure must grow with the demand; economic considerations let it seem unreasonable to launch with oversized hardware equipment. The software design must be able to cope with increasing demand, it must allow the long term upgrade of the infrastructure. Scalability must also be provided for unforeseeable load peaks. The infrastructure must be resilient and one step ahead; spare resources must be available.


2.1.3 Security

In an increasingly adverse environment, security is a cardinal goal. Various attack vectors need to be addressed. For example, the public infrastructure must be protected against pure (distributed) denial of service attacks and exploits of bugs in devices, operating systems and application software, and the SRS must be protected against intrusion by third parties with the intent of deletion or manipulation of data or stealing private keys used for DNSSEC.


2.2 Design Principles

The design principles that follow these goals are as follows:

* Shared Registry System (SRS)
** The SRS (actually all services except the name servers) is run on two sites, a primary and a secondary site. These sites are geographically separated for an event of force majeure that makes one of the sites unavailable.
** Fail-over strategies are used systematically, either by the software itself or by employing cluster technologies where applicable.
** Systematic data replication⁄backup⁄escrow is ensured.
** Modularisation of the software and avoidance of monolithic structures improves scalability and maintainability.
** Intrinsic support for multiple instances of software components to distribute load is guaranteed.
** State-of-the-art security technology reduces chances for attackers to a minimum.
** Some components like the Extensible Provisioning Protocol (EPP) interfaces may run in multiple instances. Incoming requests are distributed to these instances with the help of load balancers. Excluding instances one by one allows maintenance in respect to both hardware and software without interrupting the actual service.
* DNS Infrastructure
** Diversity in software and hardware increases security.
** Use of Anycast networks ensures high availability.


3. Features


3.1 Receipt of Data from Registrars

The SRS receives data from the registrars, writes the data into the database and passes on TLD zone files to the DNS services. The registry has a Whois function to make information about contacts and domain registrations available to the general public. DNS and Whois are updated dynamically. The registry TLD name servers receive DNSSEC-signed master zone data.

The .radio TLD will be operated as a so-called ʺthickʺ registry, i.e. the data for domain registrants, administrative contacts, technical contacts and billing contacts is stored in the registry repository. Registry policy mandates that each domain must be associated with exactly four contacts, one contact of each type. In contrast to a ʺthinʺ registry (which doesnʹt store contact information), this allows the registry Whois service to provide contact information itself, i.e. it doesnʹt rely on registrars to operate their own Whois services for the inquiry of domain contact data.

Registrars can provide the data necessary for the registration of domains, contacts and name servers (hosts) in two ways. Firstly, using the EPP interface of the CORE Registration System, which allows completely automatic processing of requests. Secondly, there is the option of using a password-protected web interface (ʺControl Panelʺ). The Control Panel offers copious amounts of information and many tools for registrars and registry administrators. Registry objects can be inquired and modified, creating new objects is possible just as easily. In addition, automatically generated reports for registrars are made available for download. Each report contains detailed information about the registry objects of the respective registrar. The Control Panel also allows the administration of registrars. Such administrative functions are of course limited to users belonging to the registry. These can also - their privileges permitting - inspect the tariffs and make corrective entries in the billing system.


3.2 Internationalised Domain Names

The CORE Registration System supports internationalised domain names (IDN, see RFC 3490, 5890-5894) in several ways.

In the extensible provisioning protocol (EPP), there are various XML elements that expect a domain name. The EPP implementation of the CORE Registration System accepts domain names in A-label notation (punycode) as well as in U-label notation (unicode). The former notation is preferred; all EPP responses use A-labels, even if the respective request used U-labels.

Internationalised domain names are not only supported as first-class objects, but also as so-called variants of a base domain. In this case, a domain has more than one representation. The alternatives are organised as attributes of the base domain, meaning they cannot exist by themselves. This has the advantage that they are much less subject to domain squatting, since the variants always belong to the same registrant as the base domain. In the DNS the variants are represented by DNAME records (as it is done in the .cat and .gr TLDs) or published with the same name servers as the base domain. A precondition for the use of variants is that the specified language(s) allow the derivation of a canonical name from any valid domain name. This is, for example, achieved by the principles defined in RFC 3743 for the Chinese⁄Japanese⁄Korean languages.

For more information about IDN support, please refer to the answer to Question 44, Support for Registering IDN Domains.


3.3 DNSSEC

Support of the DNSSEC extension according to RFC 5910 allows to specify the DNSKEY data. The CORE Registration System calculates the delegation signer (DS) records from the DNSKEY data and adds them to the zone file. Further information about the DNSSEC implementation can be found in the answer to Question 43, DNSSEC.


3.4 IPv6 Support

The .radio registry infrastructure supports IPv6 on all levels: Firstly, the name servers use IPv6 addresses on the DNS protocol level (port 53), i.e. domain names can be resolved by using the IPv6 protocol. Secondly, the registry software is able to assign IPv6 addresses to in-zone hosts as provided in the EPP Host Mapping (RFC 5732) and to publish these addresses via AAAA records in the zone. Thirdly, registrars can connect to the registry by using the EPP transport protocol via IPv6. Fourthly, the Whois service (both port 43 and web interface) can be accessed via IPv6. Fifthly, the registrar web interface can be accessed via IPv6. Details about the IPv6 capabilities can be found in the answer to Question 36, IPv6 Reachability.


4. Zone Management

Whenever the authoritative data of a domain or host is altered, the change is forwarded to the DNS component and other components. Upon reception of this change, the DNS-specific database tables are updated. The structure of these tables directly corresponds to the structure of the zone file, so that the zone file can be generated with little effort.

The generated zone is then fed into the DNSSEC signing component. Since the zone changes only marginally between the runs, the signing component re-uses RRSIG signatures and NSEC3 name mappings from previous runs. This reduces the run time of the signing process by an order of magnitude on average.

In the next step, the zone is delivered to the ironDNS system, which manages the distribution of the zone to the name servers independently. For more details about this process, please refer to the answer to Question 35, DNS Service.

The whole process is covered by integrity checks. The zone is inspected by heuristic rules, for example, the change in size between the previous and new zone is determined and checked against limits. If there is any evidence that the zone may contain problems, the deployment process is halted and manual inspection by the support team is requested. Where applicable, the distribution is accompanied by safeguards, like cryptographic digests, to allow the detection of changes or truncations.


5. Whois service

The CORE Registration System contains a public service that can be used to inquire data of registry objects (i.e. domains, contacts, hosts and registrars), the Registration Data Directory Services (RDDS). At the moment, this is implemented as a Whois service. Details regarding the Whois service can be found in the answer to Question 26, Whois service. Abuse of this service is effectively prevented, for details refer to the answer to Question 28, Abuse Prevention and Mitigation.


6. Escrow and Reports

The SRS also handles the monthly reports to ICANN and the generation of escrow files according to ICANNʹs specifications. The reports and escrow files are automatically sent to ICANN and the escrow provider, respectively.

In its role as the registry backend operator for .museum and .cat, CORE Internet Council of Registrars has continuously provided reliable registry data escrow services for these registries, in full compliance with the escrow specifications of the respective ICANN registry agreements.

In the same fashion, CORE also produces registrar escrow files for its registrar activities, in full compliance with ICANNʹs Registrar Data Escrow (RDE) requirements.

Fully automated daily processes are in place that create the full or incremental XML escrow files as required, then split, sign and encrypt them according to the requirements from ICANN and the escrow agent, and finally transfer the resulting data to the escrow agentʹs server. The escrow files contain the main SRS data, zone data and RDDS⁄Whois data. CORE Internet Council of Registrars also provides access to full zone data for the .museum and .cat TLDs to eligible parties upon sign-up to this service. Access is granted to authenticated users via an SSL⁄TLS-secured web interface.

All registry agreements with ICANN require the registry operator to submit a monthly report about the registryʹs activities, inventory and performance to ICANN. COREʹs registry system is able to create such a report containing (among other things) data about: domain⁄host inventory statistics, domain transfer statistics and domain renewal⁄deletion⁄restore statistics per registrar; service availability, outage durations and response times for SRS, DNS and Whois; Whois request statistics.

In addition, the following reports may be created for each registrar: Inventory report: domain, contact and host objects sponsored by the registrar on a specific date; Transfer report: transfers in progress, completed or rejected on a specific date; Autorenewal report: domains being automatically renewed on a specific date; Billing report: detailed information about every single billing operation that has been performed on the registrarʹs account (including refunds).


7. Support for Sunrise and Landrush Phases

A common problem that arises during the initial launch of a new top level domain (and, potentially, subsequently when new features like IDNs are introduced) is to ensure that trademark owners or otherwise eligible parties can claim their names in an organised manner that can be audited in case of legal disputes. To this end, registries usually offer a so-called ʺSunriseʺ phase, i.e. a certain period of time during which only eligible parties are allowed to register domain names. Eligibility has to be proved by providing information about a trademark related to the domain name, for example. Such additional information is provided by the registrars during registration of the domain name, with the help of a special EPP extension (see answer to Question 25, Extensible Provisioning Protocol, for details).

The validity of a Sunrise domain name application is checked by an external service provider, the so-called Trademark Clearinghouse. At the time of writing, ICANN has issued a request for information for providers to perform the Trademark Clearinghouse functions. It is envisaged that the CORE Registration System will use a suitably defined interface of the Trademark Clearinghouse to submit requests according to the trademark data submitted by domain name applicants.

To facilitate the handling of Sunrise applications, the CORE Registration System is equipped with a built-in issue system that offers registry personnel a convenient web interface to review domain name applications and to approve or reject them accordingly.

The issue system allows searching for applications by various criteria (e.g. domain name or current workflow⁄approval state). It offers a two-level review workflow that allows the delegation of pre-selection tasks to the first level support staff, after which a final decision - if still required - can be made by second level personnel. All application details, including registrant information and all supplied trademark information is conveniently displayed. The issue system fully tracks and documents application status and history, allowing for a complete audit in case of legal issues. Furthermore, it is fully integrated with the registry backend, i.e. it automatically notifies the SRS about the reviewersʹ decisions and immediately activates the respective domain in case of an approval.

The issue system was first used during puntCATʹs elaborate multi-phase Sunrise period in 2006 and proved to be an invaluable tool for efficiently organising a TLD roll-out process.

Another problem registries are facing, mostly during initial launch phases, is the unbiased allocation of domains in case of multiple competing valid applications for the same name. This is predominantly an issue during the so-called ʺLandrushʺ phase (i.e. the beginning of a TLDʹs general availability (GA) when anybody may register a domain), but it may also apply to Sunrise cases in which multiple applicants present valid trademarks or similar proof of eligibility.

In the past, many registries have chosen a simple first-come, first-served approach to handle these situations - the registrar who was able to submit the first registration request after the opening of the GA phase was awarded the name. However, this seemingly fair model not only puts an unnecessary load on the registryʹs server infrastructure, it also gives registrars an unfair advantage if their systems are located closer (in terms of network topology) to the registryʹs SRS. The system also encourages the creation of ʺpseudoʺ registrars just for the purpose of getting more parallel connections to the registry system for fast submission of as many requests as possible.

Consequently, CORE suggests an alternative, auction-based approach for Landrush situations.

COREʹs registry system provides the technical infrastructure required to conduct auctions for the assignment of domain names to the highest bidding registrant.

Its core component is an EPP extension that registrars may use to place a bid for a domain name and obtain information about the status of an auction they participate in (refer to the answer to Question 25, Extensible Provisioning Protocol, for more information).

The CORE Registration System offers built-in support for Sunrise and Landrush phases. In the case of the .radio registry, both a Sunrise phase and a Landrush phase will be supported.


8. Domain Expiration and (Auto-)Renewal Policies

Domains are registered for a certain interval only. The possible intervals are multiples of a year. The system maintains a so-called ʺexpirationʺ date, which represents the date up to which the registrar has paid the fees for the respective domain. This date is also published on the public Whois servers and is included in reports generated for the registrars.

Domains must be registered at least for a year. The registration period can be extended at any time by issuing a ʺrenewʺ request to the registry. However, the resulting expiration date must be not beyond 10 full years in the future.

Since usually the registrars use the same intervals for their customers, there is always the problem that some customers make up their decisions whether to keep a domain or to delete it at the very end of the registration term. To accommodate the registrars with this problem, it is common practice among the registries to grant a so-called grace period, which starts at the expiration date. During this 45 day period, the registrar may delete the domain without paying any fees for the already started next term. If after 45 days the domain has neither been deleted nor renewed by the registrar, the registry itself automatically renews the domain by one year.


9. Billing

The registry maintains an account for each registrar. All registrations, transfers, renewals and other billable operations have to be prepaid, and corresponding fees are deducted from the registrarʹs account.

Whenever a billable operation is attempted, the registrarʹs account is first checked for sufficient funds. If the account is lacking the required funds, the operation is rejected. A corresponding result code is returned if the rejection affects a realtime EPP command, as opposed to e.g. an internal autorenew operation that was not directly triggered by a registrar command. However, the autorenewal of expired domains is treated differently; to avoid accidental domain deletions, autorenewals are continued even in case of insufficient registrar funds. Non-billable operations (like all read-only commands) and activities that trigger refunds are always executed, regardless of the registrarʹs account balance.

If sufficient funds are available, the operation is executed and the registrarʹs account is charged with the corresponding fee (if the operation was completed successfully).

Each registrar may provide an account balance threshold value. The billing subsystem will automatically send an e-mail containing a ʺlow account balance warningʺ to the registrar whenever the registrarʹs funds drop below the configured threshold value.

Some commands, like domain deletions or transfer cancellations, result in refunds if corresponding grace periods apply. The affected registrarʹs account is immediately credited for each refund.

The billing subsystem utilises its own database, containing tables for registrar accounts (including current balance and warning threshold), tariffs for billable operations along with their validity periods and book entries (each one representing a single credit or debit).

The SRS component responsible for actual registry operation communicates with the billing component. Any billable or refundable event (such as domain creation, domain deletion within grace period, request for domain transfer, domain renewal or autorenewal) results in the lookup of a suitable tariff in the tariff table, the creation of a corresponding record in the book entry table and the update of the registrarʹs account.

The entire implementation is carefully designed to ensure billing accuracy. The checking for sufficient funds as well as the processing of book entries representing the billable events are always done within the same database transaction that performs the actual billable repository change, thus ensuring transactional integrity and account consistency.


10. OT+E and Staging Environment

In addition to the production registry system, CORE Internet Council of Registrars provides an independent Operational Test and Evaluation (OT+E) system to give registrars the opportunity to develop and test their client software in a self-contained ʺsandboxʺ environment that does not interfere with production business.

The OT+E system emulates the behaviour of the production system as closely as possible to allow for realistic testing. It also includes a Whois server, as well as a name server fed from the sandbox data, which facilitates the testing of transfer policy and DNSSEC implementations on the registrar side, respectively.

The OT+E system differs, however, from the production system in some respects to further simplify development for the registrars: Firstly, each registrar is granted two independent identities on the OT+E system. This enables each registrar to test domain transfers easily by creating domains with the first identity and transferring them to the second identity (or vice versa). Secondly, to allow short turnaround times for registrars during their tests, most of the periods and deadlines used by the production system are significantly shortened (or entirely disabled) on the OT+E system. For example, the OT+E system – contrary to the production SRS – uses an Add Grace Period shorter than 5 days to allow registrars to test domain name redemption more easily.

Apart from the mentioned differences, the OT+E system will always run the exact same software as the production system. Both systems are updated at the same time whenever a new release is deployed.

To facilitate a smooth roll-out of major software upgrades, especially those that involve protocol or policy changes requiring changes to client systems, a separate so-called ʺStagingʺ system is operated, on which these new software versions are deployed with appropriate lead time before the same changes are applied to the production and OT+E systems. The actual lead time depends on the nature and the extent of the changes involved.

The SRS is routinely adapted to improved standards and to cope with new technical, capacity and organisational demands.

Q24 - Shared Registration System (SRS) Performance

CORE Internet Council of Registrars provides a unified registration system for its members since 1997. This system grants access to a multitude of top-level domain registries, currently including .com, .net, .org, .info, .biz, .name, .us, .asia, .eu, .coop and .tel domains, via a single entry point. The activities concerning the CORE Registration System provide CORE with a great deal of expertise and know-how regarding the implementation, operation, maintenance and support of a shared registration system, facing a very heterogeneous user group regarding location, language, enterprise size and structure.

CORE is also handling the technical operation of the .cat and .museum TLDs on behalf of the puntCAT and MuseDoma registries. This proves that CORE has the knowledge and experience necessary to provide the offered registry services.


1. High-Level System Description

The Shared Registry System for the .radio registry is a local installation of the CORE Registration System, developed by CORE. Consequently, the SRS is compliant with the various relevant standards for EPP (s. Question 25), Whois (s. Question 26), DNS (s. Question 35), DNSSEC (s. Question 43) and IDNs (s. Question 44).

Each registry service is handled by its own server. Overall, the services are set up ensuring n+1 redundancy. It is envisaged that further frontends will be added later, when increasing system usage requires such a step.


1.1 Multiple sites

The .radio registry as a whole is distributed among a set of independent sites. Besides the geographical diversity of the sites, each site is designed to be independent of other sites. A complete failure of one site or of related infrastructure (i.e. upstream providers) does not affect the operation of the others. No networks or vital base services (like DNS resolvers, LDAP or SMTP servers) are shared among the sites.

For the main registry operation, i.e. all services except the name servers, two sites are designated, the primary one in Dortmund, Germany and the secondary one in Amsterdam, the Netherlands. Name servers, as far as operated by the .radio registry itself, are located on other sites. Other name servers operated by contractors can be seen to be operated on other sites as well in this context.

To support scalability of the system, the SRS is modularised into components where possible. Components are allowed to run on different machines, so that the overall load of the system can be distributed hardware-wise. This approach also improves the efficiency of cluster technologies and fail-over strategies within a site.

Some components, for example the EPP interfaces to the registrars, are allowed to run in multiple instances if necessary. With the help of load balancers, the incoming requests are distributed to these instances. By directing the load balancers to exclude an instance, this instance can be maintained with respect to both hardware and software. The latter allows minor patches to be applied to the SRS software without interrupting the actual service.

Each of the two .radio registry sites contains the full set of components that are required for operation and provides for redundancy. Under normal conditions, the primary site is active, while the secondary is inactive (components are in hot standby). In case of failure or maintenance that cannot or should not be compensated by redundant systems on the active site, the inactive site can take over the operation. The full switch-over, however, is not a requirement. Since the system consists of multiple subcomponents, the task of a failed subcomponent on one site can be transferred to the mirror subcomponent on the other site, while the other subcomponents remain on the first site. This gives the administration team freedom and flexibility to react to an incident and to minimise the impact on users. Switching of services is done using HSDNS pointers, see the answer to Q32, System and Network Architecture, for details.

The various sites are interconnected by virtual private networks (VPNs). This ensures the security and confidentiality of the communication. The VPNs are used both for data transferred between the sites as part of the .radio registry operations (e.g. zone files to the name servers, replication data between the databases, data feed of the Whois servers) and for administrative purposes, including monitoring.

In the unlikely event of a simultaneous outage of multiple components that makes it impossible to provide the service at the SRSʹs main operating site (data centre) in spite of the redundancy provided within each site, or in case of natural⁄man-made disaster at that main site, a switch-over to a different site is possible. Thanks to continuous database replication, the other site is equipped with the entire data of the repository.

Figure Q24-F1 presents a ʺbird viewʺ on the registryʹs sites, the services hosted at these sites (as described above), as well as the connections between them. The meanings of the graphical elements and symbols is described in Figure Q24-F2 (which provides a legend for all graphics attached to the answers throughout this gTLD application).

Figure Q24-F3 shows the overall structure of the registry systems per site. The various depicted resources and the relationship between them are described in detail in the answer to Question 31, Technical Overview of Proposed Registry, et seqq.


1.2 Software Development

Like all crucial components of COREʹs registry system, the SRS has been developed from scratch by CORE staff or vendors . The custom-built main server component consists of 100% Java code. While it utilises a couple of proven, open-source third-party libraries and products (such as SLF4J for logging and PrimeFaces for the web applications), the core registry functionality remains fully under COREʹs control and may thus be customised as needed.


1.2.1 Change Control

All Java code comprising COREʹs SRS is maintained in a repository managed by Subversion (SVN), the leading open-source revision control system. All code check-ins into this repository — either into the SVN trunk or into dedicated development branches (for larger additions or changes) — are closely monitored by senior developers.

Software releases meant to be deployed on staging, OT+E or production environments (see below and answer to Question 23, Registry Services) are always built from so-called ʺreleaseʺ branches within the SVN repository, i.e. not from the SVN trunk or development branches. Such branches are essentially snapshots of the code known to offer stable functionality with regard to a certain specification of the system. The exclusive use of these release branches ensures that no inadvertent changes from SVN trunk or development branches are affecting code deployed on systems used by registrars or the public.


1.2.2 Quality Assurance

Each release scheduled to be deployed undergoes a series of extensive tests by an internal QA team within CORE. This includes functional tests, but also stress tests to evaluate the systemʹs behaviour under extreme load conditions.

Any issues found during these tests are reported back to the developers via JIRA, a widely used, enterprise-grade ticketing and issue system. Only after all issues were fixed to the satisfaction of the testers, a release is deployed — usually on the staging system first (also to give registrars an early opportunity to test their client systems against the new version), then on OT+E and production.

In addition to functional and stress testing, COREʹs developers also write so-called unit tests with JUnit, a widely used Java unit testing framework that greatly facilitates regression testing.


1.3 Synchronisation Scheme

The synchronisation scheme is designed to enable any of the two sites to act as the master. However, in all cases except emergency and short annual fail-over tests, the system in Dortmund is the master. Data is synchronised on database level in real time.

The database software used will be PostgreSQL 9 (current version). There are four database systems altogether: two at the primary site (Dortmund) and two at the secondary site (Amsterdam). At any time, one of these four systems is active. Its data is replicated to the other three systems: locally to the other system at the same site and remotely to the other site, where a local copy is maintained, too.


2. System Reliability, Stability and Performance


2.1 Outage Prevention


2.1.1 Data Centre Precautions

The data centres hosting the system components of the .radio registry have taken various precautions to ensure a continuous operation, such as backup power supply, technical and facility security. Please refer to the answer to Question 31, Technical Overview of Proposed Registry, for more details.


2.1.2 Availability by Design

The general system design includes various features to reduce the risk of outages. These are summarised in the following paragraphs.

The network infrastructure of the SRS is designed to compensate a failure of one of its components. This is achieved by doubling each of these components, i.e. the firewall⁄VPN system, the load balancer and the switches that represent the internal backbone. They are operated in an active-active configuration. All servers within the system are equipped with two Ethernet interfaces for each logical connection. Where applicable, the components themselves are equipped with redundant power supplies. The interconnection between the servers and the network components provides redundant paths between each two nodes without a single point of failure. For more details please refer to Question 32, System and Network Architecture.

For the database system used by the SRS, double redundancy is provided. Firstly, there are two database servers, a primary and a secondary one. The secondary database is operated as a hot-standby solution. Secondly, there are two more database servers at the secondary site. The database data at the active site is replicated to the non-active site.

To process the EPP requests of the registrars, multiple systems are provided, which run the SRS software simultaneously. A load balancer distributes the incoming requests to these systems. An outage of one server does not interrupt the service. Although the available computing power is reduced by such an outage, the provisioned spare capacities ensure that the overall performance does not violate the service level agreement.

In the unlikely event of a simultaneous outage of multiple components that makes it impossible to provide the service, or in case of natural⁄man-made disaster at the ʺmainʺ site, a switch-over to the ʺmirrorʺ site is performed. Thanks to continuous database replication, the mirror site is equipped with the entire data of the repository. Depending on the nature of the main siteʹs failure, a limited data loss regarding transactions that were performed in the last few minutes of main site uptime may occur. Compared to the damage caused by a long-term outage, this is considered negligible.

The actual switch-over procedure consists mainly of the following steps: Complete shutdown of the main site if necessary. Despite the failure, some components may still be in an operative state. To avoid interference with the mirror site, these are deactivated. IP address change of the DNS address records belonging to externally visible servers to the corresponding servers on the mirror site. To facilitate this, a short time-to-live (TTL) setting will be used, and registrars are advised to use solely domain names to connect (not IP addresses). Name servers and Whois servers are reconfigured to use the mirror site as their data source. The registrars are informed about the switch-over, enabling them to adapt or restart their clients if necessary.

The Whois subsystem has the intrinsic ability to run an arbitrary number of Whois instances in geographically diverse locations (all fed from the same data source in a near-realtime fashion). The Whois servers operate their own databases for managing the Whois data. Load balancers are used to distribute the incoming requests to these instances. In such a setup, the outage of a single Whois instance will not disrupt Whois services for Internet users. Additional Whois servers can be added quickly to the existing setup if need be.

The huge number of different name server locations used by CORE and the involved diversity (in terms of both geography and network topology) provide a high degree of inherent protection against DNS outages. In particular, the use of state-of-the-art Anycast methodology ensures that a server will be able to respond to requests as long as at least one of the sites in its Anycast cloud is available. In addition, reliable facilities with sufficient redundancy are provided at the individual sites hosting the name servers.


2.1.3 Hardware supplies and Software Availability

The data centres will keep spare parts for all critical hardware involved, which allows fast replacement in case of hardware failures. In addition, continuous 24⁄7 phone and on-site support from the vendors ensures the availability of hardware and software, including operating systems. Contracts guarantee that out-of-stock components are delivered within hours.


2.2 Performance Specifications

All components of the registry system (SRS, Whois, DNS) are operated in full compliance with ICANNʹs performance requirements as set forth in Specification 10 of the gTLD Applicant Guidebook. In particular, the SRS will meet the following specifications.


2.2.1 SRS Performance

Upper bounds for the round-trip time (RTT) of EPP requests have to be met by at least 90 per cent of all commands. The upper bound for session commands (login, logout) is four seconds, for query commands (check, info, poll, transfer) it is two seconds and for transform commands (create, delete, renew, transfer, update) it is four seconds. The downtime of the EPP service will be not more than 12 hours per month.


2.2.2 Registration Data Directory Services (RDDS) Performance

The upper bound for the round-trip time (RTT) of RDDS queries and for the RDDS update time has to be met by at least 95 per cent of all queries⁄updates. The upper bound for the collective of ʺWhois query RTTʺ and ʺWeb-based-Whois query RTTʺ is two seconds. The upper bound for the update time (i.e. from the reception of an EPP confirmation to a domain⁄host⁄contact transform command until the RDDS servers reflect the changes made) is 60 minutes. The downtime of the RDDS service will be not more than 8 hours per month, where non-availability of any service counts as downtime.


2.2.3 DNS Performance

The upper bound for the round-trip time (RTT) of DNS queries and for the DNS update time has to be met by at least 95 per cent of all queries⁄updates. The upper bound for the TCP DNS resolution RTT is 1500 milliseconds, for the UDP DNS resolution RTT it is 500 milliseconds. The upper bound for the DNS update time (i.e. from the reception of an EPP confirmation to a domain transform command until the name servers of the parent domain name answer DNS queries with data consistent with the change made) is 60 minutes. The downtime of the DNS service will be zero, i.e. continuous availability of this service is assured.


2.3 Operational Scalability

Operational scalability is primarily achieved by the underlying architecture of the components comprising the CORE Registration System.

The software used for the processing of EPP commands is designed to run on multiple systems simultaneously. Due to the fact that the software makes extensive use of Javaʹs multi-threading capabilities, it scales well with the number of processors in each system. Therefore, long-term scalability due to increased registry activity can be accomplished by extending the system with additional processors and⁄or machines.

The SRS is dimensioned to run with about ten per cent load during regular operation. The initial system is able to handle the additional load resulting from increased domain numbers. To further cope with temporary unexpected load peaks, CORE ensures that at least 100 per cent spare capacity is available all the time.

The above measures can be applied to scale the system from handling 10000 names to up to 20 million names and beyond. The initial capacity will be 1 million names and can be increased in steps of at least 1 million names within a mutually agreed time frame.

An important point is fair and acceptable use of system resources by registrars. As far as transaction numbers are concerned, the .radio registry subjects registrars’ access to acceptable use policies that forbid wasteful use of system resources. The registry systematically avoids situations where registrars or potential registrants find themselves under pressure to enter into a race against one another with respect to registry system resources. This applies in particular to launch phases, where a contention resolution mechanism (including the use of auctions) replaces time priority. The .radio registry furthermore imposes acceptable use restrictions to prevent the abuse of grace periods.

Additionally, the number of concurrent EPP connections per registrar is limited to a certain maximum, which is initially set to 10. Rate limiting is also implemented by limiting the EPP requests within a sliding window of one minute to a configurable number, in order to prevent monopolisation of the service by one registrar.

Thanks to these measures, the .radio registry avoids disproportionate demand for registry resources.


3. Employed Hardware

For server and storage systems, products of HP are to be used. Network equipment products of CISCO, HP, Juniper and Foundry are to be used. Employment of upgradable blade and RAID systems as well as ensuring redundancy of network components, power supplies and such increases not only scalability, but also availability and data integrity.

The database server as the central system component is dimensioned to be able to keep the relevant database content in memory to avoid slow disk I⁄O operations. An HP server system with 2 six-core 3 GHz CPUs and 48 GB RAM will be used. All other servers will be equipped with 24 GB of RAM. The database server is connected to a storage attached network (SAN), which is connected to a high-performance RAID system, namely HP P6300 EVA 2.4 TB SFF SAS.


4. Resourcing Plans


4.1 Implementation

Since the CORE Registration System itself has already been implemented, no resources are necessary for the initial implementation. For setting up and configuring database servers, firewalls and so on, the following resource allocations are estimated:

System Administrator: 25 man hours;

Network Operation Centre Officer: 25 man hours;

DNSSEC Signing Operator: 5 man hours.


4.2 Ongoing Maintenance

For ongoing maintenance and occasional adaption of the system, the following resource allocations are estimated:

System Administrator: 5 man hours per month;

Network Operation Centre Officer: 5 man hours per month;

Software Developer: 2 man hours per month;

Quality Assurance Agent: 1 man hour per month;

DNSSEC Signing Operator: 1 man hour per month.

Employees already working for CORE Internet Council of Registrars will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by CORE in the past over the course of 12 months.

Q25 - Extensible Provisioning Protocol (EPP)


1. Experience

The EPP interface for registrars of the .radio registry is based on COREʹs EPP implementation, which has been used for several registries.

Since 2006, CORE handles the backend registry operation for puntCAT (responsible for the .cat top-level domain). Right from the start, COREʹs .cat Shared Registration System (SRS) offered an EPP frontend fully compliant with RFCs 3730-3734 (updated to compliance with 5730-5734 in the meantime), using various EPP extensions to cope with puntCATʹs special requirements. The SRS also fully supports the provisioning of DNSSEC data in accordance with RFC 5910; for backward compatibility, the previous DNSSEC EPP extension (RFC 4310) is also supported.

In addition, based on the same technology, CORE Internet Council of Registrars is currently in the process of taking over back-end operations for a country code top-level domain managing between 200,000 and 500,000 domain names. The details of this cooperation cannot be disclosed at the time of writing. While this registryʹs DNS services have already been transitioned to CORE at this point, the migration of SRS and Whois operations are currently being finalised.

CORE Internet Council of Registrars provides the unified CORE Registration System for its members since 1997. This system grants access to a multitude of top-level domain registries, currently including .com, .net, .org, .info, .biz, .name (with support for domain name and e-mail forwarding addresses), .us, .asia, .cn, .tw, .eu, .mobi, .aero, .me, .tel, .coop, .ch and .li domains, via a single entry point. CORE members can access all supported registries using a single, unified protocol. The CORE Registration System maps the commands issued by the user to the corresponding EPP commands, sends them to the appropriate registry server and translates back the received results. Members do not need to cope with problems regarding registry communication (like different flavours of EPP, SSL⁄TLS certificate handling or Punycode conversion for internationalised domain names) themselves.

Since the CORE Registration System acts as a client regarding all the supported registries, its implementation also allowed CORE Internet Council of Registrars to gain considerable experience concerning all client side aspects of (different versions of) EPP. In particular, client-side EPP support had already started with the introduction of EPP by Afilias and Neulevel. On the server side, EPP has been in use since starting the operation of the puntCAT registry some five years ago. At the heart of the EPP implementation lies the so-called Unikit, COREʹs EPP toolkit implementation. The Unikit includes code for the client side and for the server side. In the context of the .radio registry, the server-side part of the Unikit will be used.

In the person of Klaus Malorny, CORE also actively participated in the IETF Provisioning Registry Protocol (provreg) working group and contributed to some RFCs (see Acknowledgements in RFCs 5730-5733 and RFC 5910).

The software implementing the actual shared registry system, including its EPP interface, was entirely built by CORE, involving an international team of developers from several member companies — thus demonstrating the software development skills at COREʹs disposal.


2. Standards Compliance

The EPP interface of the .radio registry, provided by the CORE Registration System, is fully compliant with RFCs 5730-5734. These define mappings for the provisioning and management of Internet domain names, Internet host names and individual or organisational social information identifiers (ʺcontactsʺ) stored in a shared central repository.

Apart from these standards, the .radio registry also supports the proposed standard for DNSSEC (RFC 5910). This is an EPP extension mapping for the provisioning and management of Domain Name System security (DNSSEC) extensions for domain names stored in a shared central repository.

The proposed standard for an EPP extension for ʺgrace periodʺ policies defined by the Internet Corporation for Assigned Names and Numbers (ICANN) is fully supported also (RFC 3915). Such grace period policies exist to allow protocol actions to be reversed or otherwise revoked during a short period of time after the protocol action has been performed.

Furthermore, a few proprietary EPP extensions are used by the .radio registry to allow registrars to provide trademark information during the Sunrise phase, auction information during Sunrise and Landrush phases as well as language information. Documentation consistent with RFC 3735 for these proprietary EPP extensions can be found below.

All incoming requests will be validated against the schema definitions in the relevant RFCs and the ones of the proprietary EPP extensions, if applicable. This adds to security and stability, as invalid requests are dismissed early on. The EPP implementation of the .radio registry is compatible with existing toolkits that produce valid EPP requests.

Pending, asynchronous operations are fully supported by the registry implementation. The SRS returns an EPP result code of 1000 if a command has succeeded synchronously, i.e. immediately. In contrast, a result code of 1001 is returned if a command was accepted but requires asynchronous processing before it can be completed.


3. Stability

A stable EPP interface is very important for smooth operation of a shared registry system. To ensure this, the CORE Registration System contains a multi-threaded, asynchronous communication implementation allowing a high number of concurrent EPP connections.

The incoming requests are filtered by their IP addresses via firewall rules in order to disallow access from unauthorised sites. This increases not only the security of the system, but also its stability, since the load on the EPP servers is reduced.


4. Equal opportunity

EPP access limitations for registrars are enforced by the CORE Registration System, allowing a certain number of concurrent connections only. This further enhances the stability of the system and is an important ingredient for equal opportunity as well. Registrars cannot effectively hinder their competitors from connecting by simply opening a great many connections themselves.

For the sake of equal opportunity, the .radio registry also avoids first-come, first-served (FCFS) policies where possible. This is why the general availability (GA) phase is the only one using this principle. All popular domain names will probably have been registered already when GA starts (during previously conducted launch phases not using FCFS), so FCFS during GA does not contradict the idea of equal opportunity.


5. Proprietary Extensions

CORE Internet Council of Registrars has already shown its ability to design, specify and implement proprietary EPP extensions in the context of the puntCAT registry. There, extensions exist for the specification of promotion codes, sponsor e-mail addresses, application objects (used during the Sunrise phase) and poll messages to notify registrars about application outcomes, for example. In the following, the proprietary EPP extensions planned to be used for .radio are described.


5.1 Extension for Trademark Information during Launch Phases

The CORE Registration System used to operate the .radio registry provides a proprietary EPP extension for submitting special data needed during launch phases.


5.1.1 Introduction

This part of this answer describes an extension mapping for version 1.0 of the Extensible Provisioning Protocol (EPP) described in RFC 5730. This mapping is an extension of the domain name mapping described in RFC 5731. It is specified using the Extensible Markup Language (XML) and XML Schema notation.

This extension serves the purpose of supplying and querying information for special phases, usually at the beginning of registry operation. A typical use case is a ʺSunriseʺ phase during which trademark holders have a prerogative to register a domain name related to their trademark. In particular, this extension allows the provisioning of trademark information and the querying of the current status of a domain name application.

In addition, the extension allows the specification of additional information about the application, such as the intended use for the domain name, a URL demonstrating prior use of similar names in other TLDs etc.; the registryʹs Sunrise policy determines whether and how this information is utilised.

An extension to the ʺpollʺ command is not included. Registrars are notified of application results via the poll message mechanism already included in EPP.

This extension has been developed along the lines of the Internet draft by Tan and Brown (see http:⁄⁄tools.ietf.org⁄html⁄draft-tan-epp-launchphase-01). Even though that document is currently only a draft, it serves the purpose needed for the .radio registry and is clearly a step forward regarding the standardisation of launch phase handling in EPP. Since this draft does not supply a schema definition at the moment, the CORE Registration System implements its own, which can be found in attachment Q25-Ext-LP.pdf, Section 1. Once the draft was augmented by a concrete schema definition, the CORE Registration System will be adapted to utilise it, retaining the custom XML namespace identifier. Once the draft becomes an RFC, a transition will be conducted to adopt the standard.


5.1.2 Object Attributes

This extension for launch phases adds additional elements to the EPP domain name mapping. Only new element descriptions are documented here.

Since registries usually allow multiple applications for a particular domain name during launch phases, an application object is used internally. Such an object has a unique ID that is returned upon creation and is used to refer to this application in further requests. Within this extension, an ʺlp:applicationIDʺ element is used to specify this ID.


5.1.2.1 Phase

The ʺlp:phaseʺ element can be used to distinguish multiple simultaneous launch phases. Its content is a server-defined identifier corresponding to a particular launch phase.


5.1.2.2 Application Status

The ʺlp:statusʺ element is used to communicate extended status(es) of the application object, beyond what is specified in the object mapping to which this application object belongs.

The following status values are defined: ʺpendingʺ, the initial state of a newly-created application object; ʺvalidatedʺ, the application meets relevant registry rules; ʺinvalidʺ, the application does not validate according to registry rules; ʺallocatedʺ, the object corresponding to the application has been provisioned (one of two possible end states of an application object); ʺrejectedʺ, the object was not provisioned (the other possible end state).


5.1.2.3 Claim Data

An application may have one or more ʺlp:claimʺ elements. An ʺlp:claimʺ element describes the applicantʹs prior right to the domain name.

The ʺlp:claimʺ element has the boolean ʺpreValidatedʺ attribute, which indicates whether a third party validation agency has already validated the claim. When this attribute has a true value, the ʺlp:pvrcʺ element must always be present.

Several child elements of the ʺlp:claimʺ element are defined. ʺlp:pvrcʺ, the Pre-Validation Result Code, is a string issued by a third-party validation agent. ʺlp:claimIssuerʺ contains the ID of a contact object (as described in RFC 5733) identifying the contact information of the authority which issued the right (for example, a trademark office or company registration bureau). ʺlp:claimNameʺ identifies the text string in which the applicant is claiming a prior right. ʺlp:claimNumberʺ contains the registration number of the right (i.e. trademark number or company registration number). ʺlp:claimTypeʺ indicates the type of claim being made (e.g. trademark, symbol, combined mark, company name). ʺlp:claimEntitlementʺ indicates the applicantʹs entitlement to the claim (i.e. owner or licensee). ʺlp:claimRegDateʺ contains the date of registration of the claim. ʺlp:claimExDateʺ contains the date of expiration of the claim. ʺlp:claimCountryʺ indicates the country in which the claim is valid. ʺlp:claimRegionʺ indicates the name of a city, state, province or other geographic region in which the claim is valid. This may be a two-character code from World Intellectual Property Organisation (WIPO) standard ST.3.


5.1.2.4 Additional Application Information

An application may carry a ʺlp:applicationInfoʺ element. If present, it contains additional information (beyond the claim) about the application, such as the domain nameʹs intended use.


5.1.3 EPP Command Mapping

This section deals with the specific command mappings for the .radio registry EPP extension for launch phases.


5.1.3.1 EPP Query Commands

There are four EPP commands to retrieve object information: ʺcheckʺ to find out whether an object is known to the server, ʺinfoʺ to ask for detailed information associated with an object, ʺpollʺ to discover and retrieve queued service messages for individual clients and ʺtransferʺ to get transfer status information for an object.


5.1.3.1.1 EPP ʺcheckʺ Command

This extension does not add any elements to the EPP ʺcheckʺ command or to the ʺcheckʺ response described in the EPP domain mapping (s. RFC 5731).


5.1.3.1.2 EPP ʺinfoʺ Command

This extension adds elements to the EPP ʺinfoʺ command and response described in the EPP domain mapping for launch phase processing.

The EPP ʺextensionʺ element of the ʺinfoʺ command contains a child ʺlp:infoʺ element to indicate that an application object should be queried. It identifies the registry launch phase namespace and the location of the registry launch phase schema. The ʺlp:infoʺ element contains the following child elements: ʺlp:applicationIDʺ, the application identifier for which the client wishes to query, and ʺlp:phaseʺ (optional), the phase the application is associated with.

When such an ʺinfoʺ command has been processed successfully, the EPP ʺextensionʺ element in the response contains a child ʺlp:infDataʺ element that identifies the registry launch phase namespace and the location of the registry launch phase schema. The ʺlp:infDataʺ element contains the following child elements. ʺlp:applicationIDʺ contains the application identifier of the returned application. ʺlp:phaseʺ (optional) contains the phase the application is associated with. ʺlp:statusʺ (optional) contains the status of the application. One or more ʺlp:claimʺ elements (optional) give the submitted data establishing the applicantʹs prior right to the domain name.

If any ʺlp:claimʺ element is present, each of them may contain the following child elements. ʺpvrcʺ gives the Pre-Validation Result Code. ʺclaimIssuerʺ contains the ID of a contact object representing the issuing authority. ʺclaimNameʺ contains the textual representation of the right. ʺclaimNumberʺ contains the registration number. ʺclaimTypeʺ contains the type of claim being made. ʺclaimEntitlementʺ contains the entitlement. ʺclaimRegDateʺ contains the registration date. ʺclaimExDateʺ contains the expiry date.

If additional information about the application was specified when the application was created, an ʺapplicationInfoʺ element will be present containing that information.

Examples of an ʺinfoʺ command and corresponding response can be found in attachment Q25-Ext-LP.pdf, Section 2.1. EPP ʺinfoʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.1.3.1.3 EPP ʺpollʺ Command

This extension does not add any elements to the EPP ʺpollʺ command or to the ʺpollʺ response described in the EPP domain mapping (s. RFC 5731).


5.1.3.1.4 EPP ʺtransferʺ Command

This extension does not add any elements to the EPP ʺtransferʺ command or to the ʺtransferʺ response described in the EPP domain mapping (s. RFC 5731).


5.1.3.2 EPP Transform Commands

There are five EPP commands to transform objects: ʺcreateʺ to create an instance of an object, ʺdeleteʺ to delete an instance of an object, ʺrenewʺ to extend the validity period of an object, ʺtransferʺ to manage object sponsorship changes and ʺupdateʺ to change information associated with an object.


5.1.3.2.1 EPP ʺcreateʺ Command

This extension adds elements to the EPP ʺcreateʺ command and response described in the EPP domain mapping for launch phase processing.

The EPP ʺextensionʺ element of the ʺcreateʺ command contains a child ʺlp:createʺ element to indicate that an application object for a launch phase should be created. It identifies the registry launch phase namespace and the location of the registry launch phase schema. The ʺlp:createʺ element contains the following child elements: ʺlp:phaseʺ (optional), the phase the application should be associated with, zero or more ʺlp:claimʺ elements to substantiate the prior rights of the applicant, and an optional ʺlp:applicationInfoʺ element providing additional information about the application, such as the intended use of the domain name.

When such a ʺcreateʺ command has been processed successfully, the EPP ʺextensionʺ element in the response contains a child ʺlp:creDataʺ element that identifies the registry launch phase namespace and the location of the registry launch phase schema. The ʺlp:creDataʺ element contains a child ʺlp:applicationIDʺ element, which informs the registrar about the application ID the server has assigned.

Examples of a ʺcreateʺ command and corresponding response can be found in attachment Q25-Ext-LP.pdf, Section 2.2. EPP ʺcreateʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.1.3.2.2 EPP ʺdeleteʺ Command

This extension defines additional elements to extend the EPP ʺdeleteʺ command described in the EPP domain mapping for launch phase processing. No additional elements are defined for the ʺdeleteʺ response.

Clients may withdraw an application if permitted by registry policy. To do so, clients submit an EPP ʺdeleteʺ command along with an ʺlp:deleteʺ element to indicate the application object to be deleted. The ʺlp:deleteʺ element contains the following child elements: ʺlp:applicationIDʺ, the identifier of the application to be deleted, and ʺlp:phaseʺ (optional), the phase the application is associated with.

An example of a ʺdeleteʺ command can be found in attachment Q25-Ext-LP.pdf, Section 2.3. EPP ʺdeleteʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text.

The CORE Registration System supports the withdrawal of an application using this extension to the ʺdeleteʺ command. Note, however, that support for the withdrawal of an application depends on the .radio registry Sunrise policy, which is described elsewhere.


5.1.3.2.3 EPP ʺrenewʺ Command

This extension does not add any elements to the EPP ʺrenewʺ command or to the ʺrenewʺ response described in the EPP domain mapping (s. RFC 5731).


5.1.3.2.4 EPP ʺtransferʺ Command

This extension does not add any elements to the EPP ʺtransferʺ command or to the ʺtransferʺ response described in the EPP domain mapping (s. RFC 5731).


5.1.3.2.5 EPP ʺupdateʺ Command

This extension defines additional elements to extend the EPP ʺupdateʺ command described in the EPP domain mapping for launch phase processing. No additional elements are defined for the ʺupdateʺ response.

Clients may modify an application if permitted by registry policy. To do so, clients submit an EPP ʺupdateʺ command along with an ʺlp:updateʺ element to indicate the application object to be modified. The ʺlp:updateʺ element contains the following child elements: ʺlp:applicationIDʺ, the identifier of the application to be modified, and ʺlp:phaseʺ (optional), the phase the application is associated with.

An example of an ʺupdateʺ command can be found in attachment Q25-Ext-LP.pdf, Section 2.4. EPP ʺupdateʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text.

The CORE Registration System supports the modification of an application using this extension to the ʺupdateʺ command. Note, however, that support for the modification of an application depends on the .radio registry Sunrise policy, which is described elsewhere.


5.1.4 Formal Syntax

The formal syntax of this EPP extension is a complete schema representation of the object mapping suitable for automated validation of EPP XML instances. The schema definition is listed in attachment Q25-Ext-LP.pdf, Section 1. Schema Definition (Formal Syntax), since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.2 Extension for Auction Information

The CORE Registration System used to operate the .radio registry provides a proprietary EPP extension for submitting special data needed for auctions as they occur after launch phases (e.g. Sunrise and Landrush).


5.2.1 Introduction

This part of this answer desribes an extension mapping for version 1.0 of the Extensible Provisioning Protocol (EPP) described in RFC 5730. This mapping is an extension of the domain name mapping described in RFC 5731. It is specified using the Extensible Markup Language (XML) and XML Schema notation.

This extension serves the purpose of supplying and querying information for special phases, usually at the beginning of registry operation. A typical use case is a ʺSunriseʺ phase during which trademark holders have a prerogative to register a domain name related to their trademark.

Registries usually allow multiple applications for a particular domain name during launch phases. This extension helps to resolve such situations by means of an auction in an automated way. This is not a normal auction, however, insofar as every application has a ʺbidʺ associated with it. Bids cannot be modified after the phase the application belongs to has ended. Among all valid applications for a given domain name, the one with the highest bid wins the auction.


5.2.2 Object Attributes

This extension for auctions adds additional elements to the EPP domain name mapping. Only new element descriptions are documented here.

This extension allows the provisioning of auction information in the form of bids. A bid can be made when applying for a domain name. In case there is more than one valid application, an auction mechanism is used as a tie-breaker. The highest bid submitted for the domain name in question will win the auction.


5.2.2.1 Bid

The ʺauction:bidʺ element is used to set and inform about a bid for a domain name. Its content is the amount of money the applicant is willing to pay for the domain name in case of an auction. The currency is given in the required currency attribute, specified by the corresponding ISO 4217 currency code.

Note that the amount is given as a non-negative number. This allows to submit a bid of zero in case the applicant is not interested in an auction at all.


5.2.3 EPP Command Mapping

This section deals with the specific command mappings for the .radio registry EPP extension for auctions.


5.2.3.1 EPP Query Commands

There are four EPP commands to retrieve object information: ʺcheckʺ to find out whether an object is known to the server, ʺinfoʺ to ask for detailed information associated with an object, ʺpollʺ to discover and retrieve queued service messages for individual clients and ʺtransferʺ to get transfer status information for an object.


5.2.3.1.1 EPP ʺcheckʺ Command

This extension does not add any elements to the EPP ʺcheckʺ command or to the ʺcheckʺ response described in the EPP domain mapping (s. RFC 5731).


5.2.3.1.2 EPP ʺinfoʺ Command

This extension does not add any elements to the EPP ʺinfoʺ command described in the EPP domain mapping. Additional elements are defined for the ʺinfoʺ response.

When an ʺinfoʺ command has been processed successfully, the EPP ʺextensionʺ element in the response, if present, contains a child ʺauction:infDataʺ element that identifies the registry auction namespace and the location of the registry auction schema. The ʺauction:infDataʺ element contains an ʺauction:bidʺ element, which informs about the amount and currency of the currently set bid as described above.

An example of an ʺinfoʺ response can be found in attachment Q25-Ext-Auction.pdf, Section 2.1. EPP ʺinfoʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example simply retrieves the current bid for the given domain name.


5.2.3.1.3 EPP ʺpollʺ Command

This extension does not add any elements to the EPP ʺpollʺ command or to the ʺpollʺ response described in the EPP domain mapping (s. RFC 5731).


5.2.3.1.4 EPP ʺtransferʺ Command

This extension does not add any elements to the EPP ʺtransferʺ command or to the ʺtransferʺ response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2 EPP Transform Commands

There are five EPP commands to transform objects: ʺcreateʺ to create an instance of an object, ʺdeleteʺ to delete an instance of an object, ʺrenewʺ to extend the validity period of an object, ʺtransferʺ to manage object sponsorship changes and ʺupdateʺ to change information associated with an object.


5.2.3.2.1 EPP ʺcreateʺ Command

This extension defines additional elements to extend the EPP ʺcreateʺ command described in the EPP domain mapping for auction processing. No additional elements are defined for the ʺcreateʺ response.

The EPP ʺextensionʺ element of the ʺcreateʺ command contains a child ʺauction:createʺ element to indicate that auction information should be submitted. It identifies the registry auction namespace and the location of the registry auction schema. The ʺauction:createʺ element must contain an ʺauction:bidʺ element, which specifies the amount and currency as described above.

An example of a ʺcreateʺ command can be found in attachment Q25-Ext-Auction.pdf, Section 2.2. EPP ʺcreateʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example sets the bid when applying for the given domain name to the specified amount.


5.2.3.2.2 EPP ʺdeleteʺ Command

This extension does not add any elements to the EPP ʺdeleteʺ command or to the ʺdeleteʺ response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2.3 EPP ʺrenewʺ Command

This extension does not add any elements to the EPP ʺrenewʺ command or to the ʺrenewʺ response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2.4 EPP ʺtransferʺ Command

This extension does not add any elements to the EPP ʺtransferʺ command or to the ʺtransferʺ response described in the EPP domain mapping (s. RFC 5731).


5.2.3.2.5 EPP ʺupdateʺ Command

This extension defines additional elements to extend the EPP ʺupdateʺ command described in the EPP domain mapping for auction processing. No additional elements are defined for the ʺupdateʺ response.

The EPP ʺextensionʺ element of the ʺupdateʺ command contains a child ʺauction:updateʺ element to indicate that auction information should be updated. It identifies the registry auction namespace and the location of the registry auction schema. The ʺauction:updateʺ element must contain an ʺauction:bidʺ element, which specifies the new amount and currency as described above.

Whether all modifications of bids are allowed, only certain ones (e.g. only increases) or none at all depends on the .radio registry auction policy, which is described elsewhere.

An example of an ʺupdateʺ command can be found in attachment Q25-Ext-Auction.pdf, Section 2.3. EPP ʺupdateʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example modifies the bid for the given domain name.


5.2.4 Formal Syntax

The formal syntax of this EPP extension is a complete schema representation of the object mapping suitable for automated validation of EPP XML instances. The schema definition is listed in attachment Q25-Ext-Auction.pdf, Section 1. Schema Definition (Formal Syntax), since the TLD Application System (TAS) is not well suited to pre-formatted text.


5.3 Extension for Language Information

The CORE Registration System used to operate the .radio registry provides a proprietary EPP extension for internationalised domain names (IDNs).


5.3.1 Introduction

This part of this answer desribes an extension mapping for version 1.0 of the Extensible Provisioning Protocol (EPP) described in RFC 5730. This mapping is an extension of the domain name mapping described in RFC 5731. It is specified using the Extensible Markup Language (XML) and XML Schema notation.

This extension serves the purpose of supplying and querying information for internationalised domain names. In particular, the language or script used and domain name variants are addressed.


5.3.2 Object Attributes

This extension for IDNs adds additional elements to the EPP domain name mapping. Only new element descriptions are documented here.


5.3.2.1 Languages and Scripts

This extension allows the specification of either a language tag or a script tag when registering a domain name. The language or script defines the characters allowed for use in the domain name as specified in the IDN tables (see Question 44, Support for Registering IDN Domains). It is not allowed to specify more than one language or more than one script.

For the time being, the .radio registry expects the value of a language tag element to be a an ISO 639-1 language code referring to a supported language. The value of a script tag is expected to be an ISO 15924 script code referring to a supported script.


5.3.2.2 Variants

This extension allows to specify a number of variants of the domain name to be registered together with the supplied domain name. The variants are expected to be submitted in normalised form (see also Q44, Support for Registering IDN domains). The number of variants that can be specified is limited to at most 10.


5.3.3 EPP Command Mapping

This section deals with the specific command mappings for the .radio registry EPP extension for IDNs.


5.3.3.1 EPP Query Commands

There are four EPP commands to retrieve object information: ʺcheckʺ to find out whether an object is known to the server, ʺinfoʺ to ask for detailed information associated with an object, ʺpollʺ to discover and retrieve queued service messages for individual clients and ʺtransferʺ to get transfer status information for an object.


5.3.3.1.1 EPP ʺcheckʺ Command

This extension defines additional elements to extend the EPP ʺcheckʺ command described in the EPP domain mapping for IDN processing. No additional elements are defined for the ʺcheckʺ response.

The EPP ʺcheckʺ command is used to determine if an object can be provisioned within a repository. This IDN extension modifies base check processing to support language and script tags.

The EPP ʺextensionʺ element, if present, contains a child ʺidn:checkʺ element that identifies the registry IDN namespace and the location of the registry IDN schema. If at least one of the checked domains is an IDN, the ʺidn:checkʺ element must contain either an ʺidn:langʺ element or an ʺidn:scriptʺ element. The ʺidn:langʺ element contains the language whose characters may be used in the checked domain names; the ʺidn:scriptʺ element contains the script whose characters may be used in the checked domain names. The language or script specification applies to all domain names specified in the command. The results of the check (i.e., the domains namesʹ availability for provisioning) are governed by the validity of the names with respect to the specified language or script.

Examples of ʺcheckʺ commands can be found in attachment Q25-Ext-IDN.pdf, Section 2.1. EPP ʺcheckʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. Two examples are included, one with a language tag (Section 2.1.1), one with a script tag (Section 2.1.2).


5.3.3.1.2 EPP ʺinfoʺ Command

This extension does not add any elements to the EPP ʺinfoʺ command described in the EPP domain mapping. Additional elements are defined for the ʺinfoʺ response.

When an ʺinfoʺ command has been processed successfully, the EPP ʺextensionʺ element in the response, if present, contains a child ʺidn:infDataʺ element that identifies the registry IDN namespace and the location of the registry IDN schema. The ʺidn:infDataʺ element contains either an ʺidn:langʺ element or an ʺidn:scriptʺ element. The ʺidn:langʺ element contains the language that is set for the domain name object; the ʺidn:scriptʺ element contains the script that is set for the domain name object.

The ʺidn:infDataʺ element also contains an ʺidn:variantsʺ element, which in turn contains a (possibly empty) sequence of ʺidn:nameVariantʺ elements. The ʺidn:nameVariantʺ elements represent the variants that are registered together with the actual domain name.

Examples of ʺinfoʺ responses can be found in attachment Q25-Ext-IDN.pdf, Section 2.2. EPP ʺinfoʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. Three examples are included, one with a language tag only (Section 2.2.1), one with a script tag only (Section 2.2.2) and one with a language tag and variants (Section 2.2.3).


5.3.3.1.3 EPP ʺpollʺ Command

This extension does not add any elements to the EPP ʺpollʺ command or to the ʺpollʺ response described in the EPP domain mapping (s. RFC 5731).


5.3.3.1.4 EPP ʺtransferʺ Command

This extension does not add any elements to the EPP ʺtransferʺ command or to the ʺtransferʺ response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2 EPP Transform Commands

There are five EPP commands to transform objects: ʺcreateʺ to create an instance of an object, ʺdeleteʺ to delete an instance of an object, ʺrenewʺ to extend the validity period of an object, ʺtransferʺ to manage object sponsorship changes and ʺupdateʺ to change information associated with an object.


5.3.3.2.1 EPP ʺcreateʺ Command

This extension defines additional elements to extend the EPP ʺcreateʺ command described in the EPP domain mapping for IDN processing. No additional elements are defined for the ʺcreateʺ response.

The EPP ʺcreateʺ command provides a transform operation that allows a client to create an instance of a domain object. This IDN extension modifies base create processing to support language tags, script tags and domain name variants.

The EPP ʺextensionʺ element, if present, contains a child ʺidn:createʺ element that identifies the registry IDN namespace and the location of the registry IDN schema. The ʺidn:createʺ element must contain either an ʺidn:langʺ element or an ʺidn:scriptʺ element. The ʺidn:langʺ element contains the language whose characters may be used in the domain name; the ʺidn:scriptʺ element contains the script whose characters may be used in the domain name.

The ʺidn:createʺ element must also contain an ʺidn:variantsʺ element, which in turn contains a (possibly empty) sequence of ʺidn:nameVariantʺ elements. The ʺidn:nameVariantʺ elements represent the variants that are to be registered together with the actual domain name.

Note that the .radio registry restricts the number of domain name variants given in the ʺidn:variantsʺ element to at most 10. Submitting an empty ʺidn:variantsʺ element is allowed; this will not register any domain name variants.

Examples of ʺcreateʺ commands can be found in attachment Q25-Ext-IDN.pdf, Section 2.3. EPP ʺcreateʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. Three examples are included, one with a language tag only (Section 2.3.1), one with a script tag only (Section 2.3.2) and one with language tags and variants (Section 2.3.3).


5.3.3.2.2 EPP ʺdeleteʺ Command

This extension does not add any elements to the EPP ʺdeleteʺ command or to the ʺdeleteʺ response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2.3 EPP ʺrenewʺ Command

This extension does not add any elements to the EPP ʺrenewʺ command or to the ʺrenewʺ response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2.4 EPP ʺtransferʺ Command

This extension does not add any elements to the EPP ʺtransferʺ command or to the ʺtransferʺ response described in the EPP domain mapping (s. RFC 5731).


5.3.3.2.5 EPP ʺupdateʺ Command

This extension defines additional elements to extend the EPP ʺupdateʺ command described in the EPP domain mapping for IDN processing. No additional elements are defined for the ʺupdateʺ response.

The EPP ʺupdateʺ command provides a transform operation that allows a client to change the state of a domain object. This IDN extension modifies base update processing to support domain name variants.

The EPP ʺextensionʺ element, if present, must contain a child ʺidn:updateʺ element that identifies the registry IDN namespace and the location of the registry IDN schema. The ʺidn:updateʺ element may contain an ʺidn:addʺ element and an ʺidn:remʺ element. Each of these contain a (possibly empty) sequence of ʺidn:nameVariantʺ elements. Similar to the ʺupdateʺ commandʹs elements ʺdomain:addʺ and ʺdomain:remʺ, these are used to specify the domain name variants that are to be added to and removed from the domain object, respectively. If the EPP ʺextensionʺ element is missing in the ʺupdateʺ command, no change to the domain name variants will be made.

Note that the .radio registry restricts the number of domain name variants given in the ʺidn:addʺ and ʺidn:remʺ elements to at most 10.

An example of an ʺupdateʺ command can be found in attachment Q25-Ext-IDN.pdf, Section 2.4. EPP ʺupdateʺ command, since the TLD Application System (TAS) is not well suited to pre-formatted text. The included example adds some variants to be associated with the given domain name while removing existing ones at the same time (Section 2.4.1).


5.3.4 Formal Syntax

The formal syntax of this EPP extension is a complete schema representation of the object mapping suitable for automated validation of EPP XML instances. The schema definition is listed in attachment Q25-Ext-IDN.pdf, Section 1. Schema Definition (Formal Syntax), since the TLD Application System (TAS) is not well suited to pre-formatted text.


6. Resourcing plans


6.1 Initial Work

No resources are necessary for the initial implementation, since the CORE Registration System (including the EPP extensions) has already been implemented.


6.2 Ongoing Work

For registrar support regarding the EPP extensions, the following resource allocations are estimated:

First Level Support: 4 man hours per month.

Employees already working for CORE Internet Council of Registrars will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by CORE in the past over the course of 12 months.

Q26 - Whois


1. Overview

The CORE Registration System used by CORE Internet Council of Registrars to operate the .radio TLD will offer Registration Data Directory Services (RDDS) in compliance with Specification 4 of the Registry Agreement, consisting of a Whois Service, Zone File Access and Bulk Registration Data Access.


2. Whois Service


2.1 Interfaces


2.1.1 Port 43 Whois Service

Whois data for .radio will be accessible via an interface on TCP port 43 at whois.nic.radio, using the ʺWhoisʺ protocol (as defined in RFC 3912).

While the interface is publicly available, general use is rate limited to prevent data mining and mitigate denial of service attacks. Registrars may request to be exempted from the rate limiting measures by specifying IP addresses or address ranges to be put on a whitelist. Clients sending Whois requests from whitelisted IP addresses have unlimited access to the service.


2.1.1.1 Input Format

The input sent by Whois clients to the port 43 Whois server consists of two parts: the query options (starting with a hyphen character) and the query itself.

By default, the port 43 Whois service searches for domain names and name server names matching the query string. By the following keywords, the search type can be specified explicitly:

* ʺdomainʺ: Search for domains with matching names or IDs.
* ʺnameserverʺ: Search for name servers with matching names, IDs or IP addresses.
* ʺcontactʺ: Search for contacts with matching IDs.
* ʺregistrarʺ: Search for registrars with matching IDs or organisation names.

The remaining tokens in the input are taken as the search parameter. It may contain the percent sign (‘%’) as a wildcard for any number (including zero) of characters or the underscore character (‘_’) for a single character. For data mining prevention and resource protection, the number of objects returned for wildcard searches is limited to 50.

Evidently, the query format resulting from this input format specification is fully compliant with Specification 4, since it allows querying

* domains via: whois example.radio,
* registrars via: whois ʺregistrar Example Registrar, Inc.ʺ,
* name servers via: whois ʺns1.example.radioʺ and
* name servers via: whois ʺnameserver (IP Address)ʺ.


2.1.1.2 Output Format

The Whois implementation used by CORE follows a template-based approach for its output to achieve maximum flexibility with regard to the desired format. Key-value output templates containing well-defined placeholders (e.g., for domain name, registrar name, name servers, or contact fields) for variable data allow customising the output for each response type to meet ICANNʹs demands. To supply values for the placeholders in the templates, the local Whois database is fed with all properties of registrars, domains, contacts and name servers that need to be present in the Whois output. Metadata such as the ʺlast Whois updateʺ date, is also available for use in templates. Thanks to this template mechanism, adjustments for changing requirements over time may be implemented easily.

Additionally, the Whois implementation supports internationalised output. If a contact uses ʺlocalisedʺ address fields in addition to ʺinternationalisedʺ data (as supported by RFC 5733), some data fields may contain non-US-ASCII characters. Also, internationalised domain names (IDN) allow the use of non-US-ASCII characters.

The results of a Whois query are encoded using either the US-ASCII character set, or, if a valid character set has been specified via the -C query option, the selected character set. If the output contains characters for which no encoding exists in the selected character set, they are replaced with a question mark, and a warning comment is added to the beginning of the output. Please see the answer to question 44 for more information about IDN support.

The format for values such as dates, times and phone⁄fax numbers in the Whois output conforms to the mappings specified in the EPP RFCs 5730-5734, since the SRS enforces compliant values for requests from registrars, stores them as received and feeds them to the Whois instances unmodified.

Overall, this means that the response formats for domains, registrars, and name servers, as described in ICANNʹs Specification 4 of the Registry Agreement, are fully supported by the Whois implementation used by CORE.


2.1.2 Web-based Whois Service

The web Whois service operated at whois.nic.radio shares the same functionality as the port 43 service, but receives query input via an HTML form. The output format is the same as for the port 43 service.

To prevent the Web interface from being abused for data mining, a CAPTCHA test (ʺCompletely Automated Public Turing test to tell Computers and Humans Apartʺ) must be passed upon each web Whois query before any response data is displayed.


2.2 Searchable Whois

COREʹs Whois implementation offers search capabilities in accordance with Specification 2, Section 1.8. They allow complex searches for Whois database records based on the content of various data fields, thereby considerably exceeding common Whois query functionality.

This provides powerful means of information retrieval, such as finding all domain names registered by a certain person or company. When made available to unauthorised parties, this data may be abused for undesirable activities such as data mining (e.g. for advertising purposes) or social profiling. Restrictions must be imposed to prevent such abuse.

Consequently, this feature is offered exclusively on the web-based Whois interface (not the port 43 Whois), and is only available to authenticated users after they logged in by supplying proper credentials (i.e., user name and password). The .radio registry will issue such credentials exclusively to eligible users and institutions that supply sufficient proof of their legitimate interest in extended Whois searches, like e.g. law enforcement agencies. Authorisation policies and procedures are established in close collaboration with ICANN, and in compliance with any privacy laws and policies that may apply.

The search capabilities offered meet and exceed the requirements of Specification 2:

* Searches using the wildcards ʹ%ʹ and ʹ_ʹ (with semantics as described above) are possible on the following fields (thus allowing partial matches):
** domain name
** contact data (across all contact types, including the registrant):
*** name
*** organisation
*** address fields (street, city, state⁄province, postal code, country code)
* Exact match searches are possible on the following fields:
** registrar ID
** name server name
** name server IPv4 or IPv6 address (if stored in the registry for glue records)
* Multiple such search criteria may be joined by the logical operators (listed in descending precedence):
** NOT
** AND
** OR

The web interface offers a graphical editor for convenient creation of complex searches, allowing to group sets of search criteria in order to override the defined precedence of operators (thus providing the equivalent of parentheses in classic boolean expressions).

The search results are presented as a list of domain names matching the criteria. If more than 50 results are found, only the first 50 matches are presented on the initial result page, along with an indication of the total number of matches. Links allow the user to navigate through pages of search results.


2.3 Whois Data Distribution

The Whois implementation used by CORE is written as an autonomous system component running in its own server instance, i.e. it is not part of the server running the SRS component. Multiple Whois instances, all serving the same SRS data, are run in parallel; these instances may be located in diverse locations (both geographically and in terms of network topology).

All instances of the Whois service operate on their own databases. This ensures a load decoupling between the SRS and the Whois servers - high request rates on the Whois servers will not affect the main registry systemʹs performance, and vice versa.

The database of a Whois server is continuously synchronised with the registryʹs database via a VPN connection. A special communication protocol (ʺWhois feedʺ) is used to supply information about objects that have been created, modified or deleted in the SRS to all connected Whois servers.

As soon as changes to the registryʹs database have been made persistent, these changes are forwarded to all Whois servers. The Whois servers update their own databases with the data and publish the new information. This way, changes to the registry will become visible on the Whois server typically in less than a minute, resulting in an RDDS update time well under the 60 minutes permitted by Specification 10.

The Whois feed protocol has been carefully designed to allow a graceful recovery from temporary SRS⁄Whois disconnections. In case of a communication problem or a maintenance of the Whois instance, changes that occurred since the last successful update are automatically identified and transferred.


2.4 Network Structure

The Whois network structure (for queries and the feed) is depicted in Figure Q26-F1.

The green path shows how a Whois instance is continuously fed with data from the SRS. To obtain updates, a Whois server instance (D) in the Demilitarised Zone (DMZ) maintains a TCP connection to the EPP backend (B) in the Trust zone through a firewall (C) which separates the two zones. The EPP backend fetches the required data from the primary SRS database (A) and sends a corresponding feed data stream to the Whois instance.

The yellow path illustrates the data flow of Whois queries. A port 43⁄web query coming in from the Internet enters the Untrust zone via a network router (1) and passes a firewall (2) into the DMZ. A load balancer (3) dispatches the request to one of the available Whois instances (4), which processes the requests and sends the response back to the Whois client or web browser.

As the server hardware and network setup planned for the Whois subsystem is part of the overall registry infrastructure, it shares its design principles and implementation. Please see the answers to Questions 31 and 32 for further details.


2.5 Inner Workings of a Whois Server Instance

The inner structure of a Whois server instance is depicted in Figure Q26-F2. It shows how incoming port 43 or web traffic from a load balancer (at the top) is processed internally.

Port 43 queries are handled by the RFC 3912 protocol implementation. A rate limiter component ensures that query limits are enforced for connections not originating from whitelisted IP addresses. Non-blocked requests are passed on to a query evaluator component, which parses the request, fetches required data from the instanceʹs local database engine and prepares the response based on the configured output templates. A separate statistics collector module gathers query statistics (such as query type and response time) in dedicated database tables; this data is used to create monthly ICANN reports.

Web-based queries are handled in a similar fashion. Clients connect to the Whois web frontend; if both the CAPTCHA and the rate limiter component are passed, the query from the web form is processed and answered (as well as included in statistics) just like port 43 requests. For this purpose, the web application container hosting the web Whois has direct access to the local database engine, i.e. it does not utilise the port 43 implementation, but processes requests autonomously. In contrast to the port 43 server, the web Whois also contains an LDAP authentication component; it is used to validate the credentials of users logging in for accessing the extended search features described above.

The bottom of the diagram shows the Whois feed client component, which is responsible for maintaining a connection to the Whois feed service of the EPP backend, processing the feed data and updating the local Whois database.


2.6 Whois Data Privacy Measures

The Whois server implementation used by CORE is designed to support various levels of privacy regarding the content of query responses.


2.6.1 Consideration of EPP Data Disclosure Preferences

The EPP 1.0 standard, particularly its contact mapping as described in RFC 5733, provides means for registrars to specify their preferences concerning the handling of contact data submitted to the registry. Using optional ʺcontact:discloseʺ elements when creating or modifying contacts, the registrar is able to identify contact fields that require special handling regarding their disclosure to third parties.

The Whois service is designed to respect the data disclosure preferences specified by registrars using these mechanisms. Unless registry policy dictates otherwise, contact fields will be included in or excluded from the Whois output according to the respective disclosure setting. The governing registry policy will be carefully tuned to be in line with applicable data protection laws.


2.6.2 Web Whois

The Whois serverʹs web interface uses the same output restrictions as the port 43 interface.

The CAPTCHA mechanism used to let only humans (as opposed to machines) access the Web whois provides protection against Whois data abuses like data mining or spam. As an additional guard against spam, any e-mail addresses within the Whois output can optionally be displayed as images only (instead of HTML text).


2.7 Support for Emerging Technologies

CORE is aware of the shortcomings in todayʹs RDDS technology. The Whois protocol, as defined in RFC 3912, only defines the basic exchange between client and server, without any specification of input and output formats. This has led to a large number of different output formats among registries, posing problems for automated Whois clients.

In September 2011, ICANN’s Security and Stability Advisory Committee (SSAC) published SAC 051, a Report on Domain Name Whois Terminology and Structure. It contains recommendations for a domain name registration data access protocol suitable for replacing the current Whois technology. In February 2012, ICANN published a draft roadmap for the implementation of these recommendations. CORE is committed to participate in this process, and to comply with and fully support any future RDDS technologies (such as an XML-based, RESTful Whois) emerging from it.


2.8 Whois Resiliency and Performance

Thanks to the Whois subsystemʹs intrinsic ability to run an arbitrary number of Whois instances in geographically diverse locations (all fed from the same data source in a near-realtime fashion), it offers considerable resiliency. In such a setup, the outage of a single Whois instance will not disrupt Whois services for Internet users.

The same feature also guarantees a high level of scalability and performance. Should the monitoring system operated by CORE suggest an increased demand for Whois queries for names in the .radio TLD, additional Whois servers can quickly be added to the existing setup. The decoupling of SRS and Whois services described above ensures that bursts in Whois usage will not impact SRS performance. Using such scaling measures if need be, even unusual peak volumes can be handled.

Please see the answer to question 34 (Geographic Diversity) for details about the locations planned for .radio Whois instances.

In the initial setup, each Whois instance is capable of handling up to 500 queries per second. It is assumed that the average load will be at most 100 queries per second, so there is sufficient headroom for future load increases and bursts.


2.9 Compliance with Specification 10 of the Registry Agreement

The technical features described above ensure that the RDDS (Whois) implementation provided by the CORE Registration System for .radio will be in full compliance with Specification 10 of the Registry Agreement. RDDS availability, query round trip time (RTT) and update time will be maintained well within the permissible limits.

Due to the unpredictable complexity of searches conducted using wildcards or boolean operators, it is assumed that they are not used in queries for measuring RDDS availability and query RTT. Also, the service levels for these two metrics are only guaranteed for queries returning a maximum of 10 results.


3. Zone File Access

CORE will enter into standardised agreement with Internet users seeking access to .radio zone file data by following the procedures laid out in Specification 2, Section 2. For this purpose, the SRS prepares a .radio zone data file compliant with the specified File Format Standard, which is made available at the ICANN-specified and managed URL (i.e. ftp:⁄⁄radio.zda.icann.org). Through facilitation of the CZDA provider, users presenting sufficient credentials will be granted access to this data. Full cooperation and assistance will be provided to ICANN and the CZDA provider in this context.

In addition, bulk access to the zone files for .radio will also be provided to ICANN or its designee, as well as to the Emergency Operators on a continuous basis.


4. Bulk Registration Data Access

As described in the answer to question 38 (Data Escrow), the Escrow module of the CORE Registration System is capable of creating files containing Thin Registration Data, as well as Thick Registration Data restricted to the domain names of a single registrar. Using this facility, CORE will grant ICANN periodic access to Thin Registration Data, as well as exceptional access to a failing registrarʹs Thick Registration Data, in a format and on a schedule fully compliant with Specification 2, Section 3.


5. Experience in providing ICANN-compliant Whois services

CORE has been operating Shared Registry Systems (SRS) since 1997, which all require a connected port 43 Whois server. In its role as the registry backend operator for .cat and .museum, CORE has continuously provided (and still provides) reliable Whois services for these registries, being in full compliance with RFC 3912 and ICANN registry agreements.

The experience gathered from these previous Whois related activities enables CORE to develop and operate a Whois subsystem for the .radio registry that is fully compliant with all ICANN requirements.


6. Resourcing Plans

The CORE Registration System already supports the Whois services as described above at the time of writing. Since the system is designed to be highly configurable, the realisation of different privacy policies merely requires changing the respective settings within the system configuration.

This means that no development resources will be needed for the Whois service during the initial setup of the system. However, the staff on duty at CORE will need to define the related policies and configure the system accordingly.


6.1 Initial implementation

For the initial setup, the following resources are allotted:

* Registry Policy Officer: finalising policies, creating documentation: 1.5 man days
* System Administrator: configuring system for policies: 4 man hours
* First Level Support: training: 2 man hours per person


6.2 Ongoing maintenance

For the ongoing system maintenance, the following resources are allotted:

* System Administrator: system maintenance: 0.5 man days per month
* First Level Support: support: 6 man hours per month
* Second Level Support: access authorisation: 5 man hours per month

Employees already working for CORE Internet Council of Registrars will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by CORE in the past over the course of 12 months.

Q27 - Registration Life Cycle

The CORE Registration System used by CORE Internet Council of Registrars to operate the .radio TLD implements a registration life cycle that conforms with best practices and procedures widely used by existing top level domain registries. While the life cycle fully complies with all relevant EPP RFCs, it also simplifies the processing of automatic domain renewals in order to ease domain data management for registrars.

The attached state diagram (Figure Q27-F1) depicts the typical life cycle of a .radio domain during the General Availability phase, from its creation to its release. In the following, the various triggers, states and transitions involved in the registration life cycle (denoted by capital letters in parentheses) are described in detail. Blue boxes denote domain states, yellow boxes denote actions caused by registrar commands, grey boxes denote automatic actions by the system, white boxes denote timed conditions reached at some point in the life cycle.


1. Domain Creation

(A) After receiving a ʺdomain:createʺ command from the registrarʹs EPP client, the specified domain name is checked for availability and compliance with the registryʹs rules and policies. If these checks are passed, a corresponding domain object is created in the repository. Its expiration date is set according to the registration period specified in the ʺdomain:createʺ command (1-10 years) and the EPP commandʹs time stamp.

With its creation, the domain also enters the Add Grace Period (AGP), which lasts 5 days; during this time frame, the registrar may delete the domain for a full refund of the registration fee (as long as the limits specified by the AGP Limits Policy are not exceeded). Also, a domain deleted during the AGP will not enter the Redemption Grace Period (RGP), but will instead be released immediately. To indicate the AGP, the domainʹs Grace Period (GP) status according to RFC 3915 is set to ʺaddPeriodʺ; this status is automatically removed after the end of the AGP.

(B) The domain is registered. Provided that at least two name servers are present in the domain and the domain has not been put into status ʺclientHoldʺ or ʺserverHoldʺ, it is published in the TLD zone and carries the EPP status ʺokʺ. If no name servers are associated with the domain, the domain carries the EPP status ʺinactiveʺ to indicate that no delegation information is present. Note that a .radio domain may either have zero name servers or 2-13 name servers; the case of exactly one name server is prohibited by server policy. In any case, the domainʹs current data is published on the Whois server (according to the disclosure settings set by the registrar).


2. Domain Update

(C) After receiving an EPP ʺdomain:updateʺ command, the domain is modified in the repository according to the data specified in the command. The domain returns to the registered state (B). Should the update change the domainʹs name servers or its ʺclientHoldʺ status, its publication in the TLD zone is affected according to the condition described in state (B). An update command may set other domain status values, such as ʺclientDeleteProhibitedʺ; see below for a full list of all supported status values. The TLD name servers and Whois servers are updated to reflect the domainʹs new data.


3. Domain Renewal (Automatic or Explicit)

(D) If a domain reaches its expiration date, it is automatically renewed; it will not be deleted, but remains in the registered state. Note that, in order to avoid unduly disruption of the domainʹs operation, this automatic renewal will even take place if the domain carries the status ʺclientRenewProhibitedʺ; this status will only disallow the explicit renewal of domains.

(E) With reaching its expiration date, the domain enters the so-called ʺAuto Renew Grace Periodʺ (ARGP), which lasts 45 days. During this time period, the registrar has the opportunity of deleting the domain name without being charged for the renewal. In order to avoid the necessity of a refund in this case, the CORE Registration System only charges the registrar with the renewal fee after the end of the ARGP (i.e., when the renewal is final). If the registrar deletes the domain during the Auto Renew Grace Period, nothing has been charged yet, so no refund is required either. Note that this differs from the commonly used practice of charging the renewal fee already at the beginning of the Auto Renew Grace Period, which requires complicated refunds in case the domain is deleted or transferred in this period. During the Auto Renew Grace Period, the domain carries the ʺautoRenewPeriodʺ GP status, which is also displayed in the Whois along with the previous expiration date (now in the past). Only after the end of the Auto Renew Grace Period, the expiration date is increased.

(F) If the end of the ARGP is reached before the registrar deletes the domain, the registrar is charged with the renewal fee. The domainʹs ʺautoRenewPeriodʺ GP status is removed.

(G) After explicit renewal (or final automatic renewal), the domainʹs expiration date is increased. The domainʹs Whois output is changed to reflect this.

(H) If the registrar explicitly renews a domain by sending a ʺdomain:renewʺ EPP command, the CORE Registration System increases the domainʹs expiration date according to the period value specified in the command. Note that a domainʹs remaining registration period may not last more than 10 years; renewal requests that would make a domain exceed this limit are rejected. The registrar is charged with the corresponding renewal fee. The domainʹs ʺRenew Grace Periodʺ is started, which lasts 5 days; during this period, the domain may be deleted for a full refund of the renewal fee. This is indicated via the ʺrenewPeriodʺ GP status, which is automatically removed when the Renew Grace Period ends.


4. Domain Deletion

(I) After receiving an EPP ʺdomain:deleteʺ command, the deletion of the domain from the repository is initiated.

(J) If the domain is in its AGP when the delete command is received, it will be released immediately, i.e. it will be available for new registrations right away. The domain will not enter the Redemption Grace Period (RGP) in this case, and the registrar receives a refund of the registration fee (as long as the limits specified by the AGP Limits Policy are not exceeded).

(K) The domain is released (i.e., purged from the repository) and available for new registrations. This marks the end of the domainʹs life cycle. If the domain was in its Add, Auto Renew, Renew or Transfer Grace Period when the delete command was received, the related charges are refunded to the sponsoring registrar.


5. Domain Restore After Deletion - the Redemption Grace Period (RGP)

(L) If the domain is not in its AGP when the delete command is received, it enters the Redemption Grace Period (RGP), which lasts 30 days. This means that the domain is not released immediately, but is only put into the EPP status ʺpendingDeleteʺ (which is also displayed in the domainʹs Whois output) and withheld from DNS publication.

The CORE Registration System fully supports the Redemption Grace Period procedures and protocols, as defined by RFC 3915. During the RGP, the domain may be restored by the previous registrar by sending a ʺdomain:updateʺ command carrying an EPP RGP extension according to the RFC.

(M) The domain is in the Redemption Grace Period (RGP). During this phase, it is not present in the TLD zone. The domain carries the EPP status ʺpendingDeleteʺ and the RGP status ʺredemptionPeriodʺ according to RFC 3915.

(N) If the domain is not restored by the previous registrar before the end of the RGP, the domain will be scheduled for release. The EPP status ʺpendingDeleteʺ is retained, the domainʹs RGP status is changed to ʺpendingDeleteʺ.

(O) The domain is no longer restorable by the registrar and due for release. It will remain in this state for a time period defined by registry policy; this could, for example, be a variable time period with a random offset in order to make the release date and time less predictable for domain snipers. Once this time period ends, the domain is released and put into the final state (K).

(P) If the previous registrar restores the domain before the end of the RGP (by sending a ʺdomain:updateʺ command carrying an EPP RGP extension according to RFC 3915), the domainʹs RGP status is changed to ʺpendingRestoreʺ. If the registrar also sends the RGP restore report within 5 days (or along with the update command), the ʺpendingDeleteʺ status value is removed from the domain and the domain will be put back into the registered state (B). If the conditions described under (B) are met, the domain will be re-added to the TLD zone. If, however, the restore report is not received within 5 days, the domain goes back into the RGP (RGP status ʺredemptionPeriodʺ), i.e. into state (M); the RGP is not restarted in this case, but is resumed at the point when the restoration was initiated by the registrar.


6. Domain Transfer

(Q) Upon request by a domainʹs registrant, a registrar (called ʺgainingʺ registrar in this case) may request to transfer a domain name currently sponsored by a different registrar (the so-called ʺlosingʺ registrar) into its own domain portfolio. This is done by sending an EPP ʺdomain:transferʺ command with operation ʺrequestʺ. After receiving such a command, the domain is marked with a ʺpendingTransferʺ EPP status value. ʺdomain:trnDataʺ EPP poll messages are placed in the message queues of both gaining and losing registrar to inform them about the transfer request. The gaining registrar is charged with the transfer fee.

A request for a domain transfer will only succeed if certain conditions are met. In particular, the provided authorisation information must be correct, and the domain must not have the ʺclientTransferProhibitedʺ or ʺserverTransferProhibitedʺ status values set. Note that the status ʺserverTransferProhibitedʺ is automatically set and maintained for 60 days by the SRS after a domain is first created, as well as after each successful registrar transfer. This is common practice among registries and avoids the problem of ʺregistrar hoppingʺ, i.e. frequent registrar changes (after e.g. hijacking a domain name) in order obstruct takedown procedures.

(R) The domain transfer is pending. The CORE Registration System waits for either the transfer to time out (after 5 days), or for the reception of an approval, rejection or cancellation before the time-out. The losing registrar may approve or reject the transfer by sending an EPP ʺdomain:transferʺ command with operation ʺapproveʺ or ʺrejectʺ, respectively. The gaining registrar may cancel the transfer by sending an EPP ʺdomain:transferʺ command with operation ʺcancelʺ.

(S) The transfer was completed successfully, either by approval of the losing registrar or by time-out (which by default automatically approves the transfer; this behaviour is configurable). The ʺpendingTransferʺ EPP status value is removed from the domain. The domain is assigned to the gaining registrar and removed from the losing registrarʹs portfolio. ʺdomain:trnDataʺ poll messages are placed in the message queues of both gaining and losing registrar. The domain returns to status (B). A successful transfer starts the domainʹs ʺTransfer Grace Periodʺ (TGP) which lasts 5 days; during the TGP (which is indicated by the ʺtransferPeriodʺ GP status), the domain may be deleted by the gaining registrar for a full refund of the transfer fee.

(T) The transfer was unsuccessful, i.e. it was rejected by the losing registrar or cancelled by the gaining registrar. The EPP status ʺpendingTransferʺ is removed from the domain. ʺdomain:trnDataʺ poll messages are placed in the message queues of both gaining and losing registrar. The domain returns to status (B). The transfer fee previously charged to the gaining registrar is refunded.


7. EPP and Grace Period Status Values

As described above, the .radio domain life cycle involves various EPP Domain and Grace Period status values and uses them in compliance with RFCs 5730-5733 and 3915 (note that RFC 5910 does not specify any status values). This section provides an overview of the status values and describes whether and how they are used in the life cycle.

In general, status values starting with ʺclientʺ may only be set or removed by the registrar, while all other status values (including those starting with ʺserverʺ) may only be set or removed by the registry, either automatically or manually by registry staff.


7.1 EPP Domain Status Values (from RFC 5731)

* clientDeleteProhibited: Indicates that the domain cannot be deleted by a ʺdomain:deleteʺ command.
* clientHold: Indicates that the domain is not published in the .radio zone.
* clientRenewProhibited: Indicates that the domain cannot be renewed by an explicit ʺdomain:renewʺ command; the status does not prevent automatic renewal.
* clientTransferProhibited: Indicates that the domain cannot be transferred.
* clientUpdateProhibited: Indicates that the domain cannot be modified.
* inactive: The domain has no delegation information, i.e. no name servers are associated. The domain is not published in the .radio zone.
* ok: The domain is active, i.e. it resolves, has no pending operations or prohibitions, and carries no other status values.
* pendingCreate: Indicates that the domainʹs creation is pending, i.e. that an asynchronous process is in progress to finish the domainʹs creation. This status is supported, e.g. for use during launch phases such as Sunrise and Landrush (to indicate that a domain applicationʹs asynchronous review is pending); please refer to the answer to question 29 (Rights Protection Mechanisms) for more information about the special life cycle support offered by the CORE Registration System for launch phases.
* pendingDelete: Indicates that the domain is being deleted; depending on its RGP status (see below), it may be restorable or not.
* pendingRenew: Indicates that the domain is pending a renewal. While supported by the CORE Registration System, this status not used in the designated .radio domain life cycle.
* pendingTransfer: Indicates that the domain is in the process of being transferred from one registrar to another registrar.
* pendingUpdate: Indicates that an update to the domain is pending, i.e. that an asynchronous process is in progress to finish the domainʹs modification. While supported by the CORE Registration System, this status not used in the designated .radio domain life cycle.
* serverDeleteProhibited: Indicates that the domain cannot be deleted.
* serverHold: Indicates that the domain is not published in the .radio zone.
* serverRenewProhibited: Indicates that the domain cannot be renewed by an explicit ʺdomain:renewʺ command; the status does not prevent auto-renewal.
* serverTransferProhibited: Indicates that the domain cannot be transferred. This status is automatically set and maintained for 60 days by the SRS after a domain is first created, as well as after each successful registrar transfer.
* serverUpdateProhibited: Indicates that the domain cannot be modified.


7.2 EPP Grace Period Status Values (from RFC 3915)

* addPeriod: Indicates that the domain is in the Add Grace Period.
* autoRenewPeriod: Indicates that the domain is in the Auto Renew Grace Period.
* renewPeriod: Indicates that the domain is in the Renew Grace Period.
* transferPeriod: Indicates that the domain is in the Transfer Grace Period.
* pendingDelete: Indicates that a deleted domain is scheduled for release, i.e. it can no longer be restored by the registrar.
* pendingRestore: Indicates that a request to restore a deleted domain has been received, and that the registry awaits the restore report from the registrar.
* redemptionPeriod: Indicates that a deleted domain is in its Redemption Grace Period, i.e. it may be restored by the registrar.


8. Consistence with Commitments to Registrants

The registration life cycle described above is consistent with the registryʹs commitments to registrants, as laid out in the answer to Question 30a. In particular, the handling of auto-renewals and the Redemption Grace Period ensures the ʺProtection of Investmentʺ part of that commitment, since it protects the domain from vanishing unintendedly.


9. Resourcing Plans

The CORE Registration System already supports the life cycle described above at the time of writing. Since the system is highly configurable, the adjustment of any variables and flags defining the process (such as name validity policies, or the durations of involved grace periods and time-outs) merely requires changing the respective settings within the system configuration. No coding is required for this, which means that no special developing resources will be needed. However, the staff on duty at CORE Internet Council of Registrars will need to define the related policies and set up the system to support and maintain the desired registration life cycle.

For the initial setup, the following resources are allotted:

* Registry Policy Officer: finalising policies, creating documentation: 3 man days
* System Administrator: configuring system for policies: 4 man hours
* First Level Support: training: 3 man hours per person

For the ongoing maintenance, the following resources are allotted:

* System Administrator: 4 man hours per month

Employees already working for CORE Internet Council of Registrars will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by CORE in the past over the course of 12 months.

Q28 : Abuse Prevention and Mitigation

The .radio Registry, with the assistance of its backend registry provider CORE Internet Council of Registrars, will establish, thorough and effective methods to prevent abuse of .radio domain names, .radio registrant data or the associated infrastructure, as well as to mitigate any impact from such abuse (should it occur despite the preventive measures). In order to achieve this, the .radio Registry is committed to deploying extensive organizational and technical measures. The most salient examples of these measures are described below.

~1. Rapid Takedown Policy for Cases of General Malicious Activity

The .radio Registry has committed to closely collaborate with law enforcement authorities and security agencies in order to take quick action in case a .radio name is reported to be involved in malicious activity. For this purpose, a Rapid Takedown Policy is established that:

* identifies cases of malicious activity,

* defines ways for the registry to be notified of such activity (e.g. via a dedicated website, e-mail address or phone hotline),

* defines clear and consistent procedures to quickly stop the malicious activity (after the activity was confirmed and impact of the measures has been assessed),

* defines related service levels (e.g. with respect to the maximum time the registry may take to respond to takedown requests). This time limit will never exceed 15 business days in the case of less urgent cases, and not exceed 24 hours in the most urgent cases such as phishing,

* defines rules regarding the notification of involved parties (registrant, administrative contact, technical contact, registrar, informant),

* defines ways to appeal against any measures taken (through the general Eligibility Restrictions Dispute Resolution Procedure as is the case for all appeals against Registry decisions, but with panelists that are specialized in Security and Malicious Conducts).

* defines how cases covered by the policy need to be documented and reported. In this context, cases of malicious activity may include (but are not limited to):
** wrong, invalid or harmful DNS setup (e.g. pointers to false IP addresses),
** use of trademarked or otherwise reserved names without proper rights,
** use of the domain in actions that affect the stability and security of the Internet (e.g. in Denial of Service (DoS), Distributed Denial of Service (DDoS) attacks or botnets),
** use of the domain for the distribution of malware (such as computer viruses, worms, Trojan horses, spyware or rootkits),
** use of the domain for phishing or scamming,
** use of the domain for spamming (affecting e-mail or other forms of electronic messaging).
** maintaining invalid registrant contact data in the domain.

Where applicable, the policy includes metrics and thresholds for finding quantitative indications of malicious conduct.

Procedures to stop malicious activity may include (but are not limited to):

* notifying the domainʹs sponsoring registrar, specifying a deadline until which the activity needs to have ceased,
* notifying the domainʹs registrant, administrative or technical contact directly (again specifying a deadline until which the activity needs to have ceased),
* locking the domain and putting it on hold in order to prevent changes to the domain and remove it from the .radio zone (ʺtakedownʺ),
* deleting the domain name and blocking it from further registration if need be. Escalation rules (defining which steps are to be taken in which order and conditions for moving on to the next, more drastic measure) are part of the policy. 

Since removing a domain name from the .radio zone usually has serious consequences (such as rendering websites and e-mail addresses utilizing the domain name unusable), the .radio Registry will, in accordance with the policy, exercise extreme caution with regard to any takedown decision.

At the same time, the .radio Registry is aware that malicious activity potentially affects a large number of Internet users, which sometimes warrants drastic measures. The Rapid Takedown Policy aims at finding appropriate measures, taking the interests of all involved parties into consideration. The Rapid Takedown Policy will be announced to both .radio registrars and .radio registrants and be part of the Registry-Registrar Agreement (RRA) and the .radio registration terms.

2. Rapid Takedown Policy for Cases of Phishing

The .radio Registry will work closely with all relevant CERTs and CSIRTs to develop an Anti-Phishing-specific simplified procedure. The goals will be to:

* get all five Swiss CERTs and CSIRTs (at least, but open to other CERTs) accredited as Authorized Intervenors),

* develop criteria and checklist for domain names eligible for Rapid Suspension,

* develop secured communications method between Authorized Intervenor and Registry, including an Affidavit form.

Names reported by Authorized Intervenors will be suspended in less than 4 hours. This system should expand to a global Authorized Intervenors list. In this regard, the .radio Registry will work with the Antiphishing Working Group and other initiatives in order to develop and complete their proposed Accelerated Takedown proposal, which is still in beta stage.

3. Single Point of Contact for Abuse 

To ensure that the .radio Registry gets notified of any cases of abuse as quickly and as easily as possible, an area of the public website operated by the .radio Registry for the .radio TLD will be dedicated to the reporting of such cases.

The respective web pages establish a single point of contact where abuse cases can be reported via a simple web form. An e-mail address and a phone number will also be provided as alternative means of communication. 

Every case reported will raise a high-priority ticket within the .radio support staffʹs ticket system, to be examined immediately and treated in accordance with the Rapid Takedown Policy (and the other Compliance Procedures related to Eligibility and Use, and Trademark Claims).

4. Prevention of Domain Name Tasting or Domain Name Front Running

The life cycle of a .radio domain name includes a 5-day Add Grace Period (AGP) during which a newly created domain name may be deleted with a refund of the domain fee. This is common practice and corresponds to the policies of almost all existing generic top level domains.

However, in the past the Add Grace Period has been abused for practices such as domain name tasting and domain name front running.

Domain name tasting means that domains were created simply for the purpose of testing whether revenue can be generated by e.g. creating a web page with advertisements for the domain; if this was found feasible within the first few days, the domain was retained, otherwise it was deleted within the add grace period for a full refund, i.e. the domain was ʺtastedʺ for potential revenue without any payment to the registry.

Domain name front running refers to the practice of pre-registering domain names somebody has merely expressed interest in (e.g. by searching for them on the Whois web front-end of a registrar) with the purpose of reselling the domain to that person (at an inflated price) afterwards; again, the Add Grace Period has been abused for this purpose since a registrar could do that without any cost (if the unsold domain was deleted before the end of the add grace period).

In 2008, ICANN introduced the so-called ʺAGP Limits Policyʺ (http:⁄⁄ www.icann.org⁄en⁄tlds⁄agp-policy-17dec08-en.htm) which addresses these and other issues resulting from the Add Grace Period. The .radio Registry will fully implement this policy by restricting Add Grace Period refunds to registrars according to the limits specified by the policy. At the end of every month, the registration systemʹs billing module will determine every registrarʹs net domain adds and check whether the add grace period refunds granted during that month exceed the permissible number according to the policy; if this is the case, additional charges to the registrarʹs account will be initiated to effectively revert the excessive refunds.

Any exemption requests by registrars, whether they were granted (as permitted by the policy) or rejected, are documented, and such documentation will be maintained and made available for review by ICANN on request. The registryʹs monthly report to ICANN will contain per-registrar information on the granted add-deletes, as well as additional columns regarding the exemption requests.

The related report columns are (with column header names in parentheses):

* number of AGP deletes (ʺdomains-deleted-graceʺ)

* number of exemption requests (ʺagp-exemption-requestsʺ)

* number of exemptions granted (ʺagp-exemptions-grantedʺ)

* number of names affected by granted exemption request (ʺagp-exempted-domainsʺ)

5. Prevention of Domain Name Sniping (Grabbing)

Domain name sniping (also known as ʺgrabbingʺ) is another common abuse pattern; the name refers to the practice of trying to re-register potentially interesting domain names immediately after they are deleted (sometimes by accident, or because a registrant failed to renew the domain with his registrar in time).

Since .radio domains are (per registry policy) automatically renewed when they reach their expiration date, no explicit renewals by registrars are required to prevent a domain name from being deleted when they expire. Registrars need to explicitly delete domains in order to release them for re-registration. This substantially reduces opportunities for domain name sniping.

However, registrars may still send unintended domain deletions, i.e. due to clerical errors or miscommunication with the registrants. Even for these cases, measures against domain sniping are in place.Starting in 2002, registries have started to implement an ICANN proposal, the so-called ʺRedemption Grace Periodʺ (RGP, http:⁄⁄www.icann.org⁄en⁄registrars⁄redemption-proposal-14feb02.htm).

The proposal recommends introducing a 30-day period after a nameʹs deletion during which the name is removed from the TLD zone (in order to give the registrant the chance to take notice of his nameʹs deletion) but is still eligible for being restored by the previous registrar⁄registrant.

Supporting the RGP significantly reduces chances for domain grabbers to obtain inadvertently deleted domains, since a registrant gets 30 days to notice the mistake and restore the domain before it becomes available for re-registration.


The .radio Registry supports the Redemption Grace Period as proposed by ICANN and implements it in full compliance with RFC 3915 (ʺDomain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP)ʺ).

6. Prevention of Orphaned Glue Records

According to the definition found in the ʺSSAC Comment on the Orphan Glue Records in the Draft Applicant Guidebookʺ (http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf), a glue record becomes an ʺorphanʺ when the delegation point NS record (the ʺparent NS recordʺ) that references it is removed while retaining the glue record itself in the zone. Consequently, the glue record becomes ʺorphanedʺ since it no longer has a parent NS record. In such a situation, registrars and registrants usually lose administrative control over the record, and the recordʹs attribution to a certain registrar may become unclear, which makes it a potential vector for abuse.

The glue record policy in effect for the .radio TLD avoids this situation entirely by disallowing orphan glue records altogether. This corresponds to policy #3 mentioned in section 4.3 (page 6) of the SSAC document mentioned above. The technical implementation within the Registry and its associated zone generation process ensures this by the following measures:

* As a general principle, glue records are only created if they are really necessary, i.e. only in the case where a name server (e.g. ʺns.example.radioʺ) is used for the delegation of a superdomain of its own name, e.g. ʺexample.radioʺ in this example. If the same name server is used for e.g. ʺexample2.radioʺ, no glue record is created.

* A host object within the .radio TLD (e.g. ʺns.example.radioʺ) cannot exist without its parent domain (ʺexample.radioʺ). Any attempt to create the host ʺns.example.radioʺ will be rejected by the SRS if the domain ʺexample.radioʺ does not already exist or is not sponsored by the registrar creating the host. Likewise, the domain ʺexample.radioʺ cannot be deleted by the registrar if subordinate hosts like ʺns.example.radioʺ still exist. These subordinate hosts have to be deleted before the domain may be deleted; if such hosts are used in delegations for other .radio names, these delegations in turn have to be removed before the host may be deleted.

* If a domain name is put on hold (e.g. as a consequence of the Rapid Takedown Policy described above), this not only means that the delegation for the name itself is removed from the zone; it also means that any occurrences of NS records referencing a name server that is subordinate to the domain are also removed from other .radio domains, along with any accompanying glue records. The same of course holds true should the domain name have to be deleted entirely by the registry.

Consequently, no glue records can exist for a certain domain in the .radio zone after that domain is put on hold or deleted as part of abuse prevention or mitigation procedures.

It should be noted that this policy may lead to other domains (not directly involved in the abuse case) being affected by the takedown if they were delegated to a name server subordinate to the offending domain. Depending on their overall DNS architecture, such domains may become unreachable or less reachable after the delegation point is removed. While this could in theory be avoided by a less rigid orphan glue record policy, the overall benefit of adopting the strict policy described above is deemed higher than the potential damage to domains using an DNS infrastructure depending on an offending domain name.

7. Preventing Use of Trademarked, Reserved, Invalid, Illegal or Otherwise Unsuitable .radio Names

As laid out in the answer to Question 29 (Rights Protection Mechanisms), the .radio Registry takes extensive measures to protect the legal rights of others (such as trademark holders) with regard to .radio domain names. This includes

• conducting a Sunrise phase to allow trademark holders to secure names related to their trademarks prior to GA,

• accessing a Trademark Clearinghouse to validate trademarks presented by registrants,

• offering a Trademark Claims Service, at least during the first 60 days of general availability,

• taking precautions against phishing and pharming and

• committing to full compliance with established Dispute Resolution and Suspension Procedures, including the Uniform Rapid Suspension (URS), the Trademark Post-Delegation Dispute Resolution Procedure (Trademark PDDRP), and the Uniform Domain Name Dispute Resolution Policy (URDP).

Please refer to the answer to Question 29 for more detailed information on these measures.

In addition to these specific rights protection measures, CORE Registration System provides the following general means to make sure that no .radio names are registered which are for other reasons deemed invalid, reserved, illegal, offensive or unsuitable.

7.1 Rule Engine

For the most part, this is achieved by the deployment of a complex rule engine that checks each registered name at the time of registration for compliance with a configurable set of rules. Among other things, these rules will include:

* a test to ensure that the domain name has the proper number of labels (which is two for a traditional registry that allows only second level domains to be registered),

* a test to ensure that no hyphens occur in position 3 and 4 of any of the domainʹs U-labels (to protect ʺxn--ʺ and future ACE prefixes),--

* a test to disallow hyphens at the beginning or end of the name,

* a test to find ASCII characters which are neither a letter, nor a digit, nor a hyphen,

* a test to find invalid IDN characters, i.e. characters not contained in any of the support IDN character tables,

* a test to disallow reserved geopolitical names,

* a test to disallow registry reserved names,

* a test to disallow ICANN reserved names,

* a test to disallow otherwise reserved or unsuitable names. 

Please refer to the answer to Question 44 (Internationalised Domain Names) for more information on the rules governing valid IDNs in the .radio TLD.

For the tests checking for reserved names, custom lists of labels can be conveniently maintained by the .radio Registry to define the disallowed names for each category. Additional categories can also be added as required for enforcing specific policies of the .radio TLD.

The rules are stored in database tables (rather than static configuration files), which means rules can be added, deleted or altered by authorised registry personnel without requiring a shutdown or restart of the .radio SRS.

7.2 Compliance with Specification 5 of the Registry Agreement

The rule engine is the central system component ensuring that the .radio Registry will operate the .radio TLD in full compliance with Specification 5 (ʺSCHEDULE OF RESERVED NAMES AT THE SECOND LEVEL IN GTLD REGISTRIESʺ) of the Registry Agreement. Unless the .radio Registry is otherwise authorised by ICANN and the Government Advisory Committee (GAC) in writing, the rule engine for .radio will be set up to prohibit the registration of the labels and label types listed in Specification 5 by registrars.

7.3 Pattern Matching and Fuzzy String Comparison

In addition to the pre-registration checks described above, the rule engine also supports testing registered domain names against a set of configurable string patterns, as well as for their similarity to a set of disallowed strings. The former is implemented by matching names against regular expressions, the latter by calculating the so-called ʺLevenshtein distanceʺ between the registered name and a given disallowed string (which is a measure for their similarity). Prior to performing any of these checks, the registered name is subjected to a number of normalisations in order to maximise its comparability; this includes the mapping of IDN characters with accents to their ASCII counterparts where feasible, the removal of hyphens and the removal of digits.

If a name matches a regular expression, or if the calculated Levenshtein distance falls below a certain threshold, the name is still normally registered, however it is also internally flagged for review. Due to the fuzzy nature of the pattern and Levenshtein matching, a name flagged via these checks may not necessarily be invalid or illegal; this is why the flagged names need to be reviewed manually by the .radio support staff. Flagged names automatically create tickets within the support teamʹs issue system, which starts a workflow that ultimately decides whether the name is permissible (in which case the flag is removed) or invalid⁄illegal (in which case the name is deleted and the registrar gets notified).

7.4 Handling of IDNs

In the context of abuse prevention, the proper handling of Internationalised Domain Names (IDNs) becomes an important aspect.

If different IDN scripts were allowed to be mixed within one domain name, so-called homographs could be used to make users believe they are looking at a certain web site while it is actually a different one which name just has an identical or very similar visual representation. For example, since the Cyrillic letter ʺErʺ (ʺ*ʺ in Cyrillic script) in lower case has the same visual appearance as the Latin lower case letter ʺpʺ, mixing Latin and Cyrillic scripts would allow the creation of a domain name like ʺ*ay*al.radioʺ, a homograph of the Latin-only name ʺpaypal.radioʺ which, despite being a different word, looks exactly the same. Such a domain name could thus e.g. be used for spoofing or phishing attacks. The .radio Registry prevents such abuse by implementing an IDN policy that disallows the mixing of scripts; within each label of a registered .radio, only characters from a single script may be used.

Likewise, the Cyrillic-only second level domain ʺ***.radioʺ looks identical to its Latin-only counterpart ʺpop.radioʺ. If only the rule described above (no mixing of scripts) would apply, these two names could coexist for different registrants, and could thus be abused to confuse users. However, the special way the .radio Registry handles such IDN variants while considering respective IDN tables and canonical forms of domain names, as described in detail in the answer to Question 44 (Support for Registering IDN Domains), prevents this situation; only one of these two domains may exist at the same time. In short, one singe table, Latin script, will be allowed.**

The .radio Registry is aware that even within the same script (e.g., Latin), the use of diacritics may potentially cause similar confusion among users, e.g. if the ASCII-only name ʺpaypal.radioʺ and a very similar one with diacritics (like ʺpáypàl.radioʺ) are coexisting as completely separate registrations. Hence, the .radio Registry has decided to treat such names as false variants and only allow their registration by the same registrant. Please see response to Question 44 below, and specially the IDN Table attached there, for further details.

8. Domain Data Access Control 

One important point of attack that may lead to abuse of .radio domains and their associated data is the unauthorized or excessive access to data stored within the .radio repository. This applies to both read access (e.g. via public interfaces such as the port 43⁄port 80 Whois) and write access (such as registrar interfaces like EPP or the[8] web-based Control Panel). The measures taken in the .radio TLD to properly restrict access are laid out in the following sub-sections.

8.1 Prevention of Whois Data Mining

The port 43⁄port 80 Whois interfaces grant public access to domain, host and contact data. As such they are a potential target for data mining, i.e. the retrieval of large numbers of postal or e-mail addresses for e.g. the purpose of advertising.

As explained in detail in the answer to question 26 (Whois), the Whois implementation provided by the .radio Registration System prevents such data mining attempts, most importantly by:

• Access to all Whois interfaces is rate-limited (when accessed from IP addresses not whitelisted for unlimited access).


• Web interface users are required to pass a CAPTCHA before access is granted.

• Web interface users seeking access to extended Whois search capabilities are required to authenticate by entering login credentials (which are only issued to eligible parties).

• For improved spam protection, E-mail addresses may be displayed as images only in the web-based Whois.

• Contact disclosure flags as specified in RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, are fully supported. This gives registrants enhanced control over the contact fields they want to disclose in the Whois. In this respect, the system is configurable and allows restricting the use of EPP contact disclosure settings via rules defined by specific registry policies or legal requirements.

8.2 Prevention of Unauthorized Data Modifications

Domain data within the .radio Registry is exclusively provisioned by registrars, i.e. registrants have no direct write access to their data within the repository; all their modifications have to be done via the registrar sponsoring the respective domain. In this constellation, registrants need to trust their registrar and will expect that the management of domain is conducted in a diligent and correct manner. This means that the registryʹs interfaces used by registrars need to be secured in order to only allow the sponsoring registrar of a domain (and nobody else) to modify domain data.

The EPP interface provided by the .radio Registration System does this by:

* requiring SSL⁄TLS on the transport layer,

* requiring a strong EPP password (minimum length, mandatory digits and non-alphanumerical characters),

* requiring changing the EPP password on a regular basis,

* requiring registrars to supply lists of IP addresses or subnets from which exclusive access will be granted, 

* requiring registrars to use SSL client certificates known to and trusted by the registry, thus providing an additional means of authentication beyond the EPP password.

Likewise, the web-based Control Panel:

* requires SSL⁄TLS on the transport layer,

* requires registrars to log in with a user name and password (for which the same rules regarding minimum length, mandatory digits and non- alphanumerical characters apply),

* requires changing the password on a regular basis,

* requires registrars to supply lists of IP addresses or subnets from which exclusive access will be granted,

* requires registrars to install SSL client certificates known to and trusted by the registry in their web browsers, thus providing an additional means of authentication beyond the web password. 

9. Whois Accuracy 

Since .radio is operated as a so-called ʺthick registryʺ, the .radio Whois displays information about the registrant, as well as the administrative, technical and billing contacts of every .radio domain. In cases of malicious or abusive activity involving a .radio domain, this Whois contact information usually is the first and most important source of information, e.g. for law enforcement authorities, to determine in a timely manner the people or organizations responsible for the domain. Consequently, it is deemed very important to maximize the accuracy of contact information stored in the registry repository. 

The .radio Registry is therefore committed to taking diligent measures to promote Whois accuracy, including (but not limited to) the following:

* Contact data completeness policy: While RFC 5733, the Extensible Provisioning Protocol (EPP) Contact Mapping, merely requires contact data to contain a name, a city, a country code and an e-mail address for a syntactically complete EPP request, the .radio TLD policy for contact data mandates the specification of at least one address line (street), a voice phone number and a postal code in addition. This means that, in addition to the XML schema validation conducted by the .radio SRS for every EPP request received from the registrar (which ensures the presence of all RFC-mandated contact data), the SRS also requires these essential fields to be present and will reject requests lacking them with a ʺparameter value policy errorʺ message. The validation done by the SRS also goes beyond validating against the EPP XSDs with respect to field content. For instance, contact e-mail addresses are required to contain an ʹ@ʹ character and a valid domain name; this is not mandated by the XSDs specified in RFC 5733.

Contact data monitoring: On a regular basis, the registry will run automated plausibility audits on the contact data submitted by registrars. Using publicly available databases, contact address lines will e.g. be mapped to cities and zip codes, which are then compared to the ones provided by the registrant. Likewise, phone and fax numbers will be checked for plausibility.

* Domain data change notifications: [15] The .radio Registration System can be configured (on a per-registrar basis) to automatically notify certain contacts of a domain (e.g. both the registrant and the administrative contact in order to reach multiple people concerned with the domain) after every change made to the domain (i.e. alterations of associated contacts or name servers). When enabled, this feature allows unauthorized or unintended changes to domain and contact data to be detected immediately. This functionality will however need to be deployed after consultation with .radio registrars, since many registrars do not endorse direct communication between the registry and registrants, i.e. their customers.

* WDRP auditing: In 2003, ICANN adopted the so-called ʺWhois Data Reminder Policyʺ (WDRP, http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm) which obliges ICANN-accredited registrars to send yearly Whois data reminder notices to registrants. These notices contain the Whois data currently on file for the respective domain, as well as instructions for the registrant about ways to correct the data if required. While the .radio Registry does not intend to replicate this reminder procedure on the registry level, it will establish an auditing process that monitors the WDRP activities of .radio registrars to make sure that WDRP responsibilities are honored.

 10. Resourcing Plans

The CORE Registration System already supports the technical abuse prevention and mitigation measures above at the time of writing. No additional coding is required for this, which means that no special developing resources will be needed. Continuous audits and monitoring, as well as timely reactions to reports of malicious activity will be provided by the staff on duty at CORE Internet Council of Registrars.

For the initial setup, the following resources are allotted:

• Registry Policy Officer: finalising policies, creating documentation: 7 man days

• System Administrator: monitoring setup: 3 man days

• First Level Support: training: 1 man day per person

• Second Level Support: training: 1 man day per person

For the ongoing maintenance, the following resources are allotted:

• First Level Support: 10 man hours per month

• Second Level Support: 20 man hours per month

• System Administrator: 3 man hours per month

Employees already working for CORE Internet Council of Registrars will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks conducted by CORE in the past over the course of 12 months.

Q29- Rights Protection Mechanisms

Whenever a new top level domain is introduced, the protection of intellectual property, legal rights and trademarks is an important objective. Using suitable technical means and appropriate policies and procedures, rights owners and trademark holders must be protected from abusive domain registrations throughout a TLDʹs launch phase(s), as well as during the period of general availability (GA) which follows these launch phase(s).

The .radio Registry is fully committed to preventing abusive uses of its namespace, regarding legal rights of third parties, and beyond. It is fully committed to an orderly and trusted namespace with clear and effective policies guaranteeing that domain names are used according to the principles of the .radio TLD by the relevant community, as explained in more detail in questions 18 and 20 above.

In this regard, below is an outline of the Enforcement Policies that will be applied in .radio having an effect on Rights Protection :

1. Launch Phase (Sunrise; Landrush)
2. Compliance Procedures: General Availability
3. Dispute Resolution Mechanisms⁄Rights Protection
4. Technical Implementation
5. Human Resources


1. Launch phase: Criteria; Conflict Resolution; Mechanisms

As explained in answers to questions 18 and 20, .radio Launch phase will consist of a long (well over the minimum 30 days as required), orderly Sunrise period during which multiple applications will be accepted and published, and then validated, prioritized and eventually accepted or rejected according to their relative priority.

The Sunrise will have seven main Categories, some with different sub-Categories:

1. Broadcasters Unions
2. Licensed radio Broadcasters
3. Companies providing specific services and equipment for the radio industry (for their trademarks, plus others for defensive registrations if not eligible)
4. Web radios
5. Licensed amateur radios and clubs
6. radio professionals
7. Same as above, with extended name selection.

Each application will be individually and thoroughly validated against both the general requirements of .radio registration policies and the specific requirements of each Category or Sub-Category. Priority will be differentiated by Category (and Sub-category) each one having absolute priority over the next one.

Within the top two Categories, first-come⁄first served will apply as the last resort resolution mechanism, but conflicting applicants may avoid this by agreeing on Mediation or Arbitration. For the remaining 5 Categories (and Sub-category) all validated applications will be deemed to carry the same rights. Auction will be the last resort resolution mechanism for intra (sub-)category concurrent applications, but the parties may avoid it by electing for Mediation.

Upon rejection of an application the applicant will have one week to notify their intention to appeal the decision (before an independent Mediation and Arbitration Center). In that case, no application for the same name from the same or lower rank in Sunrise priority will be approved, pending the Appeal. If the Appeal finds that the Registry failed to apply the .radio Launch Registration Policies in an adequate manner, this will result in the restoration of the domain name, for which processing will then resume according to the .radio Launch Registration Policies (within the category or lower priority categories)

The registry will also offer the TM Claims mechanism as provided by the TM Clearinghouse. This service will be provided not just for the Sunrise period, but also afterwards, during the General Availability Phase.

2. Compliance Mechanisms. General Availability

As explained in questions 18 and 20, once in Ongoing (live) Registration mode, the .radio Registry will perform ex-post validation based on Whois data and use of the domain name, both against the Registrations Policies and the Intended Use Statement provided by the registrant at registration time (or updated afterwards).

2.1 Ex-officio random checks

Checks will be performed by compliance agents both based on complaints and ex-officio, through statistically targeted random checks. The .radio Registry will start with 50 such random cases per day, and will adapt the practices according to the experience gained (it is expected that the number will decrease over time, as reputation and enforcement will make compliance easier over time).

Checks will be carried out both on compliance with .radio policy and, at the same time, on registrant data accuracy.

In case the compliance agents discover any problem, they will forward the issue to the Compliance Officers, and the registrant will be contacted to clarify⁄correct the situation. If not solved in due time (15 or 30 days, according to the specific cases), the name may be put on registry hold.

2.2 Complaints, Rights Protection

Similarly, in case of a third party complaint for infringement of rights of others, the Compliance Officers will request the complainant to compile a specific form including such information as :
* identification of complainant,
* identification of right infringed,
* declaration of good faith belief that the domain name is used to violate said right,
* indemnification of the Registry in case of action based on false, inaccurate or otherwise non-applicable claims,
* acceptance of jurisdiction of the courts of Geneva and Registrant’s domicile, in case the name is blocked and the registrant wants to sue the complainant for damages.

Then the registrant will be contacted. In case the registrant provides within the following 15 business days a counter-statement with some specific content (identification; signed declaration of non-infringement of rights, with explanation of reasons) the domain name will not be blocked, and the complainant shall use the Uniform Rapid Suspension procedure, the UDRP, the .radio Charter Compliance Dispute Resolution Procedure (CCDRP) or file a lawsuit in a competent court. In case the registrant fails to provide all the elements (which will often be the case in blatant violations) the domain name could be put on registry hold.

Against these decisions (not just for Rights Protections, but also in cases of Compliance decisions for Eligibility or use breaches and malicious conduct) the parties may appeal to an independent Mediation and Arbitration Authority according to the .radio CCDRP.

3. Dispute Resolution (and Prevention) Mechanisms involving Rights Protection

3.1 Compliance with ICANN-mandated Dispute Resolution Mechanisms

The .radio Registry will fully comply with all procecures established in Specification 7 of the draft TLD Registry Agreement. the .radio Regsitry agrees to adhere to any remedies ICANN imposes on Registry Restrictions Dispute Resolution Procedure and Post-Delegation Dispute Resolution Procedure, as implemented and amended in the future.

The .radio Registry further agrees to implement Uniform Trademark Dispute Resolution Procedure (UDRP) and Uniform Rapid Suspension Procedures (URS) in the manner established in the .radio Agreement and the Consensus Policies.

3.2 Additional compliance measures related to ICANN-mandated policies

• UDRP

While compliance with the UDRP as it is now lies on registrars’ side, the .radio Registry is not willing to accept non-compliant registrars preventing its implementation. Besides ICANN-applied sanctions, the Registry will suspend the ability to register new domain names under .radio for those registrars failing to implement UDRP decisions.

In order to do this, the .radio Registry will implement a specific complaints form for successful UDRP complainants facing non-cooperative registrars for .radio names. Upon evidence of non-compliance, the offending registrar would be prevented from registering any new .radio name for three months after effective compliance the first time, and six months in case of repeated failures to comply. This measure is more effective and less harmful for the end users than termination, and will be included in the .radio RRA.

• URS

The .radio Registry will immediately comply with URS decisions upon notification from the URS Service provider, through its Compliance Team.

Furthermore, .radio will offer the successful complainant, if the name becomes available for registration at any given time, a Notification Service for any future attempt to register such a name. This service will be free of charge to the successful URS complainant.

• Trademark Claims

As noted above, the .radio Registry intends to extend the TM Claims services beyond the mandatory Sunrise period and the first 60 days of General Availability, on an ongoing base.

4. Technical Implementation

4.1 Launch phase

Technically, Sunrise phases differ from the general availability period in some important aspects:

In addition to the usual domain data (contacts, name servers), registrars need to collect trademark information (such as trademark name, trademark number, trademark type, trademark application and trademark registration dates) from the registrants and submit this data to the registry when applying for domain names.

The specified trademark information needs to be validated. This involves verifying the data with the help of a so-called ʺTrademark Clearinghouseʺ, a central repository authenticating, storing and disseminating trademark information (providers for this service are to be designated by ICANN). In addition, manual reviews may be part of the validation process, for which appropriate tools should be in place.

The results of the trademark validation need to be received and properly processed. This includes notifying all involved parties (such as the registrar and registrant).

It is possible that multiple applications for the same domain name are received. To distinguish these applications, a unique ʺapplication IDʺ is assigned to each of them in order to clearly identify them in future references, notifications and queries. If more than one of the applications for a domain name carry valid trademark data, contention resolution measures need to be taken in order to determine the registrant to whom the domain is awarded.

The CORE Registration System used by CORE Internet Council of Registrars to operate the .radio TLD fully supports these and other requirements of Sunrise phases via features described in the following.

4.1.1 Sunrise EPP Extension Support

The system supports an EPP extension for submission of trademark data along with domain applications during launch phases such as Sunrise. For multi-phase Sunrise periods, the extension also supports the specification of the phase for which an application is submitted.

Moreover, the extension offers the possibility to submit additional textual information along with an application, such as e.g. the intended use for the domain name, or a URL demonstrating the previous use of the domain name under other top level domains. The registryʹs Sunrise policy governs whether specifying this information is required, which kind of data this information needs to provide, and how this information affects the decision about whether or not a domain name is awarded.

Please refer to the answer to Question 25 (Extensible Provisioning Protocol) for more information about the launch phase EPP extension.

4.1.2 Sunrise Whois Support

CORE provides special Whois services during launch phases like Sunrise. This allows registrants to check the status of their applications independently from information they may obtain from their registrars.

However, the Whois search options and the information returned during Sunrise differs from General Availability (as described in the answer to Question 26). Only the search for application IDs is enabled, without any support for wildcards. If an application ID exactly matches the Whois clientʹs query string, the applicationʹs data (domain name, registrar, application date, contact data and trademark information) is returned, along with information about the applicationʹs status (such as ʺapprovedʺ or ʺunder reviewʺ). See the Sunrise⁄Landrush life cycle specification below for details about possible application states.

4.1.3 Registration Life Cycle Support for Sunrise (and Other Launch Phases)

The system supports the special steps of the registration life cycle that occur during Sunrise, i.e. the initial asynchronous trademark validation and⁄or selection processes.

The registration life cycle described in the answer to Question 27 (Registration Life Cycle) applies to the ʺGeneral Availabilityʺ (GA) phase of the .radio TLD, i.e. the normal ʺFirst-Come, First-Servedʺ (FCFS) period that usually starts after a TLD has finished its initial launch phase(s). Launch phases like Sunrise and Landrush usually involve a special life cycle that adds some complexity to the initial domain creation step.

During Sunrise phases, this step comprises the validation of trademark data and the determination of the winning application if multiple ones were received. Depending on the concrete registry policy in place, one or multiple Sunrise phases may be conducted.

So-called ʺLandrushʺ phases are usually conducted after (or in parallel to) Sunrise phases in order to limit the load on the Shared Registration System (SRS) that usually occurs during the initial run on popular, generic names. Their goal is to replace the brute-force FCFS approach of the GA by a fair, controlled domain assignment process that does not encourage registrars to flood the SRS with requests when GA starts. Similar to Sunrise, most Landrush approaches let registrars submit multiple applications for the same domain name, among which a winner is determined by asynchronous contention resolution measures as defined by the registryʹs policies. In contrast to Sunrise, usually no special proof of eligibility needs to be supplied by registrars or validated by the registry during Landrush.

4.1.3.1 Life Cycle Support for Sunrise

During both Sunrise and Landrush, the first step of the normal domain life cycle (ʺcreate domainʺ, position (A) in the GA life cycle diagram Q27-F1 from the answer to Question 27) consists itself of a number of individual steps representing the registryʹs rights protection workflow. The steps during Sunrise are depicted in Figure Q29-F1:

(A1) Registrars are required to submit Sunrise applications for domain names by sending EPP 〈domain:create〉 commands containing a special EPP extension for the specification of relevant trademark data. In addition, a second EPP extension may be used to specify data required to resolve a potential contention with regard to the domain name, such as the registrantʹs bid for the case that an auction should be held to decide the final assignment of the domain name (if the registryʹs policy utilises auctions to resolve contention during Sunrise).

Application data is stored in the registry database. Checking this data for validity may involve manual evaluation that needs to be done asynchronously. Also, multiple valid applications for the same domain name may be submitted during Sunrise, which is why applications are collected until the end of the Sunrise submission period, after which evaluations (and, if required, contention resolution) take place to determine the final outcome. The final result of the application is later communicated to the registrar via an EPP poll message. A unique application ID is assigned to the application and returned to the registrar for future reference and queries.

(A2) The registry system accesses the API of the connected Trademark Clearinghouse in an attempt to validate the submitted trademark information in relation to the desired domain name.

(A3) If the check with the Trademark Clearinghouse fails, i.e. the provided trademark information is found to be evidently invalid, the application is rejected immediately without further manual review. An EPP poll message is placed in the registrarʹs message queue to inform the registrar about the negative outcome of the application. The applicationʹs status is now ʺinvalidʺ, which is also displayed in the special launch phase Whois output when the application ID is queried.

This step in the life cycle may also be reached later in the validation process, i.e. after the application was found invalid during a manual review, or when a contention resolution for a name with multiple valid applications was lost by the registrant. In the latter case, the applicationʹs status is ʺrejectedʺ, which is also displayed in the Whois output when the application ID is queried.

(A4) If the check with the Trademark Clearinghouse succeeds, i.e. the provided trademark information is found to be (at least tentatively) valid, the application is added to the pool of automatically validated applications for the given name. Such applications are collected in the registry database until the end of the Sunrise submission period. The registrar may withdraw the application by sending an EPP 〈domain:delete〉 before the Sunrise submission period ends.

The applicationʹs status is now ʺpendingʺ, which is also displayed in the Whois output when the application ID is queried.

(A5) At the end of the Sunrise submission period, the application may be further evaluated, potentially involving manual checks. If the outcome of this evaluation is that the application is invalid, the application is rejected by going to step (A3).

(A6) All remaining, valid applications for the given name are examined. If there is only one valid application (left) for the given name, this application may be approved in step (A7). Otherwise, a contention resolution needs to be conducted to determine the final assignee for the application, which is done in step (A8).

(A7) The application is approved, the domain is allocated and assigned to the registrar. An EPP poll message is placed in the registrarʹs message queue to inform the registrar about the positive outcome of the application. The domain proceeds into the registered state.

The applicationʹs status is now ʺallocatedʺ, which is also displayed in the Whois output when the application ID is queried.

(A8) Since multiple valid applications for the same name were submitted, a contention resolution is required to determine the registrant to which the domain is awarded (the actual contention resolution used for .radio is described below). If the resolution is won, the next step is (A7); if it is lost, the next step is (A3).

During the contention resolution, the applicationʹs status is ʺvalidatedʺ, which is also displayed in the Whois output when the application ID is queried.

4.1.3.2 Life Cycle Support for Landrush

The steps during a Landrush phase are quite similar to the ones for Sunrise. As depicted in Figure Q29-F2, the basic approach is the same, except that no trademark information is submitted or reviewed in the process; the only aspects governing the assignment of the domain name during Landrush are

whether more than one application was received for the name and

if this should be the case, which of these applications wins the contention resolution.

The availability of Landrush support in the CORE Registration System does not imply that dedicated Landrush phases must be held. While they are technically feasible, registry policy may also dictate that Sunrise and Landrush are conducted in a single phase, or in overlapping phases. The CORE Registration System is prepared for such cases. A combined Sunrise⁄Landrush phase is e.g. possible by allowing applications during Sunrise to be submitted without carrying any trademark data (which marks them as Landrush applications). During the selection process, applications carrying trademark data (i.e. proper Sunrise applications) then always take precedence over ones that were submitted without such data; only if no valid Sunrise applications are received for a name, the Landrush applications for the name are considered, and the winning one is determined in accordance with the registryʹs contention resolution policies.

Another alternative to a dedicated Landrush phase is the use of a FCFS approach for GA with staggered pricing; in this approach, a domainʹs initial registration price is relatively high when GA starts, but is decreased over time. Registrants willing to pay the high price may register the domain early on, others will try waiting until the price goes down. Despite the FCFS principle, such staggered pricing will usually prevent a flood of requests from registrars at the beginning of GA. The CORE Registration System supports this approach by its flexible billing module, which allows the definition of prices for all billable operations for specific time periods, i.e. different prices may be defined for e.g. the first day after the start of GA, the second day, the third day and so forth. It is even possible to use a formula-based approach to express the domain price as a function of the elapsed time since the start of GA.

The billing module, in conjunction with the rule engine described in the answer to Question 28, may also be used to charge individual, higher prices for attractive, generic names (ʺpremiumʺ domains). If a registry chooses this approach, domains affected by this special pricing are configured in the rule engine, along with a so-called ʺprice modelʺ identifier that determines the tariff used for each of these domains.

See below for more information on the GA approach designated for .radio.

4.1.4 Trademark Clearinghouse Support

The CORE Registration System is prepared for accessing APIs of the Trademark Clearinghouse in order to validate the trademark information submitted by the registrar during Sunrise. In addition, the system also contains provisions to make use of the Trademark Clearinghouse APIs for providing a Trademark Claims Service as soon as .radio enters a period of general availability (see below for more information on this service).

Since Trademark Clearinghouse Service Providers have not been assigned by ICANN at the time of writing, the full technical specifications for these APIs are not yet known. While basic provisions have been made in the CORE Registration System to connect to these providers, the details will therefore have to be finalised once the service providers have been announced and API specifications are available. As described below, appropriate developer resources are allocated to perform this task.

4.1.5 Support for Multiple Applications for the Same Domain Name

The CORE Registration System is designed to maintain multiple domain objects representing the same domain name at a given point in time. This feature is required to store multiple applications for the same name during launch phases like Sunrise.

To distinguish between the various applications for the name in the database (as well as in external APIs), each application is assigned a unique application ID. These application IDs are returned to registrars in the responses to domain applications via EPP and may subsequently be used, among other things, to enquire an applicationʹs review status. Also, review results are reported back to registrars via poll messages carrying the unique application ID. Registrars can utilise the ID to clearly associate results with their various applications. Registrants may query the status of their applications from the .radio Whois server using the ID.

4.1.6 Issue System

When manual reviews of Sunrise applications are required, this typically involves a specific support team workflow that, among other things, consists of
* storing application data in a database,
* making application data available to the support staff via a web interface,
* assigning the task of reviewing applications for a certain domain name to a specific support member (for the purpose of clear responsibilities),
* having the application reviewed by the assigned person, who in the process may
* request additional information or documentation from the registrant,
* add such documentation, as well as comments concerning the review, to the application,
* make a decision about the applicationʹs outcome or
* forward the task to a different support person with better insight or higher decision privileges (who may then make the final decision).

To support this workflow, the CORE Registration System is equipped with a built-in Issue System that offers registry personnel a convenient web interface to review domain name applications and approve or reject them accordingly.

The Issue System
* offers an SSL-secured web interface accessible by .radio registry staff only;
* allows searching for applications by various criteria (e.g. domain name or current workflow⁄approval state);
* allows a registry support person to find newly submitted or otherwise unassigned applications and to take responsibility for them;
* offers a two-level review workflow that allows the delegation of pre-selection tasks to the first level support staff, after which a final decision - if still required - can be made by second level personnel;
* conveniently displays all application details, including registrant information, the supplied trademark information, as well as the results of the verification of that trademark data with the Trademark Clearinghouse;
* fully tracks and documents application status and history, allowing for a complete audit in case of disputes or legal enquiries and
* is fully integrated with the registry backend, i.e. it automatically notifies the SRS about the reviewersʹ decisions and immediately activates the respective domain in case of an approval. The Issue System also triggers the creation of appropriate EPP poll messages in order to keep registrars informed about the outcome of their applications.

The Issue System was first employed using puntCATʹs elaborate multi-phase Sunrise period in 2006 and proved to be an invaluable tool for efficiently organising a TLD roll-out process. It ensures that the registry staff reviewing Sunrise applications finds all information relevant to a domain name in one place and comes to well-founded decisions in a timely manner. The experience gathered from developing and operating the Issue System in that context helped to develop a second-generation version that is now part of the CORE Registration System.

4.1.7 Support for Resolving Contention

If multiple valid and eligible applications for a domain name are received, a well-defined and deterministic process is required to nominate the winning application. The details of this contention resolution procedure highly depend on a specific top level domainʹs policies; for example, a top level domain that represents a certain geographic region may have a policy that prefers trademark holding companies based in that region over other eligible trademark holders.

However, even after such policy-based considerations, multiple candidates for the winner of an application may be left in contention. In such a situation, different tie-breaker rules can be applied to make a decision.

4.1.7.1 First-Come, First-Served

The obvious tie-breaker rule is to simply award the domain to the first application submitted, i.e. the one that carries the earliest time stamp among the ones in the contention set. Since the CORE Registration System assigns a unique time stamp to each received application in a fair, unbiased manner and makes it available to the review staff of the .radio Registry, this ʺfirst-come, first-servedʺ strategy is a viable, technically supported way to resolve contentions.

1.7.2 Auctions

However, first-come, first-served selection processes based on application submission times have the drawback of potentially encouraging registrants and registrars to submit all their requests as soon as the registry starts accepting applications, which imposes time pressure on the involved parties, puts a considerable load on the involved systems and may cause an unfair advantage for registrars with better connectivity to the SRS.

Therefore, the CORE Registration System also supports a simple auction-based tie-breaker approach out-of-the-box. It allows the registrar to submit a single, blind bid amount along with the Sunrise or Landrush application (via a special EPP extension). To avoid the submission of more than one bid, multiple applications for the same domain name carrying identical trademark data (during Sunrise) are rejected.

In the case of a contention, the application that was submitted with the highest bid wins. In the unlikely event that two applications were submitted with the exact same bid amount, the one with the earlier time stamp wins; this also applies to the corner case that multiple applications were received but none of them carried a bid, which is treated as if all were submitted with a bid of zero. Only the winning applicant pays his bid, i.e. there is no extra fee for placing a bid; this ensures that the process cannot be regarded as a lottery. If no contention should arise (i.e. there is only one applicant left before bids would be considered as a tie-breaker), the bid amount is irrelevant and only the standard application fee (which is always due) is paid.

4.1.8 Trademark Claims

When a match of a registered name is found via the API provided by the Trademark Clearinghouse, the Trademark Claims Service is supposed to provide clear notice to a prospective registrant of the scope of the mark holderʹs rights. The registrant will in turn be required to provide statement that
* he received notification that the mark is included in the Trademark Clearinghouse,
* he received and understood the notice and
* his registration and use of the requested domain name will not infringe on the rights that are subject of the notice.

The registrant will be directed to the Trademark Clearinghouse Database information referenced in the Trademark Claims Notice to enhance understanding of the Trademark rights being claimed by the trademark holder.

Also, if a domain name is registered in the Trademark Clearinghouse, the registry will, through an interface with the Clearinghouse, promptly notify the mark holders(s) of the registration after it becomes effective.

4.2 Reducing opportunities for noncpliance

As laid out in that answer, the underlying set of checks can be tuned to block registrations of .radio names based on various syntactic rules, multiple reserved names lists, and patterns. Prior to the launch of the .radio TLD, the rule engine will be configured in accordance with the policies of the .radio Registry. Reserved names lists will be populated as governed by all eligibility restrictions that need to be enforced, which means that such names are not available for registration by registrars.

However, should eligible parties approach the .radio Registry (via a registrar) providing sufficient evidence of their eligibility for a specific reserved domain name, the .radio Registry can enable the chosen registrar to register the domain name for that specific registrant only (circumventing the rule engine check that would otherwise prevent the registration).

4.2.1 Reducing Opportunities for Phishing and Pharming

In most cases, the abusive behaviours of phishing and pharming constitute, among other things, a severe violation of the legal rights of others. Both practises are usually applied to make users enter confidential or otherwise exploitable information on fake web sites pretending to be operated by a certain company or institution. In the case of phishing, the attack is usually done by trying to conceal the real domain name in the URL, or by using a domain name very similar to the one the user originally meant to visit. In the case of pharming, the attack happens on the DNS level, i.e. while the user still sees the correct domain name of the site he meant to visit, the IP address his resolver determined for the domain name somehow gets manipulated to point to the fake web site; in many instances, this manipulation happens on a node close to the user, e.g. by altering a desktop computerʹs local hosts file (overriding normal DNS resolution), or by modifying the DNS lookup facilities of an Internet router at the userʹs home.

Due to the way these attacks are conducted, neither phishing nor pharming can be entirely prevented on the registry level. However, the registry can put mechanisms and policies in place that will make such exploits harder or limit their duration and impact.

4.2.1 Phishing

One important tool to rapidly address phishing activities shown by a web site operated under the .radio TLD is the Rapid Takedown Policy described in the answer to Question 28 (Abuse Prevention and Mitigation). It allows a fast takedown of an offending site after respective activities were reported and confirmed.

In addition, the flexible rule engine used by the CORE Registration System to validate permissible .radio domain names can be utilised in the context of phishing. Should a certain .radio domain name (or a pattern of such names) be repeatedly involved in attempts to mimic a rights holderʹs legitimate .radio name for phishing purposes, the set of registration validation rules can be easily augmented to prevent the offending domain name (and, if need be, even an entire pattern of names deemed too similar to a rights holderʹs legitimate domain name) from being registered again after takedown. Of course, this practise will be exercised in close collaboration with ICANN and other parties potentially involved in the definition of names deemed not eligible for registration within the .radio TLD.

As described in the answer to Question 28 (Abuse Prevention and Mitigation), the sophisticated IDN handling implemented by the CORE Registration System is designed to provide protection against the most common cases of IDN-based phishing attempts, such as IDN homograph attacks. Please refer to the answers to Question 28, as well as Question 44 (Support for Registering IDN Domains), for more information on this topic.

4.2.2 Pharming

With regard to pharming, neither the quick takedown of offending domain names nor the blocking of such names are suitable as countermeasures. Due to the nature of the attack, the registryʹs approach needs to aim at a robust DNS infrastructure for .radio, which ideally should guarantee the integrity and authenticity of DNS lookup results all the way from the registry-operated TLD name servers to the userʹs local resolver.

As described in detail in the answer to Question 35 (DNS service, configuration and operation of name servers), the .radio Registry will deploy a highly reliable and secure DNS subsystem for the .radio TLD, which is powered by the elaborate DNSSEC setup laid out in the answer to Question 43 (DNSSEC). The .radio Registry is therefore able to safeguard against any attempts to perform DNS manipulation on the level of the name servers operating the .radio zone.

However, due to the way the domain name system (and DNSSEC in particular) works, preventing manipulations of the .radio TLD name servers alone is not sufficient to avoid pharming attacks. In order to provide complete protection, DNSSEC support is required on every level of the domain resolution process, from the root zone via the TLD name servers and the delegated name servers down to a userʹs resolver. This means that registrars need to sign the zones they host on their name servers (and offer this service to their registrants), and resolvers (or other clients looking up .radio domain names) need to verify the signatures and notify their users when inconsistencies are detected. Consequently, the .radio Registry will encourage and advertise the widespread support and use of DNSSEC among registrars, registrants and end users. Once DNSSEC has been widely adopted, web browsers, e-mail clients and similar applications will increasingly support the verification of the related signatures out-of-the-box (rather than via the extensions available today), which will drastically diminish opportunities for pharming. In this ideal setup, even a local hosts file placed by a virus on a desktop computer to override its DNS lookups would not remain undetected, since the user aware of DNSSEC would instantly get notified about wrong or lacking DNSSEC signatures.

5. Resourcing Plans

The CORE Registration System already supports the rights protection features described above at the time of writing. No coding is required for this, which means that no special developing resources will be needed. The staff on duty at CORE Internet Council of Registrars will be in charge of performing manual reviews of trademark data where required.

One aspect to be considered for resource planning is the registry systemʹs connection to the Trademark Clearinghouse; since the involved API is not fully defined at the time of writing, some software development will have to be done in order to integrate the Clearinghouse into the Sunrise workflow, as well as to incorporate it into the designated Trademark Claims Service.

For the initial setup, the following resources are allotted:
- Registry Policy Officer: finalising policies, creating documentation: 5 man days
- System Administrator: configuring system for policies: 1 man day
- First Level Support: training: 4 man hours per person
- Software Developer: integration of Trademark Clearinghouse API: 10 man days
- For the Sunrise phase, the following resources are allotted:
- First Level Support: 30 man days per month
- Second Level Support: 30 man days per month
- For the ongoing maintenance, the following resources are allotted:
- System Administrator: 1 man day per month

Employees already working for CORE Internet Council of Registrars will be handling these tasks. The numbers above were determined by averaging the effort required for comparable tasks.

Q30 a) - External Technical & Operational Capability

This chapter presents an abstract, high-level description of the security principles governing the operation of the .radio TLD by the .radio registry. Since this part of the response is published, detailed information is not included in this part of the answer, however an exhaustive description of the employed security measures is presented in the answer to Question 30 b).

Knipp Medien und Kommunikation GmbH, the technical provider for CORE Internet Council of Registrars, is currently in the process of being certified according to the ISO 27001 standard. The completion of the certification process is estimated for Q4⁄2012.


1. Security Policy

As .radio registry does not perform the technical operation of the registry itself, but has contracted CORE Internet Council of Registrars for that purpose, .radio registry defines a general security policy framework that is imposed on itself, CORE and all further contractors and subcontractors. All participating entities have to ensure that their security policies meet the requirements of the framework.

The security policy framework has the following key objectives:

* confidentiality
* access
* accountability
* availability

These objectives are further explained in the following.


1.1 Confidentiality

Confidentiality means the protection of private, proprietary and other sensitive information from entities that neither have a right or a need to gain access to it. Information includes, but is not limited to, registration data, registrar data, financial data, contracts, human resources data, and other business and technical data. To achieve this, all managed data are categorised into the classes ʺhighly sensitiveʺ, ʺconfidentialʺ and ʺpublicʺ, which then define the base levels for the respective protective measures. With respect to the determined classification, for each set of data it is defined

* where the data is stored,
* how it is backed up,
* what protective measures are taken both for the data itself and its backups,
* how long the data is retained and how it is safely destroyed once the information is no longer required,
* how it is protected from illicit access,
* how legitimate access and modification is controlled,
* to which extent the data has to be auditable and
* which regular audits are performed.


1.2 Access

Access defines the rights, privileges and the mechanisms by which assets of the .radio registry are being protected. Assets may refer to physical items like desktop computers, notebooks, servers, network devices and other equipment, or to logical items like registration data, e-mails and communication logs, passwords or cryptographic key material. For each entity (i.e., person or machine) that is granted access, it is clearly defined

* for which purpose the access is granted,
* to which level the entity can view or change the data, partially or in whole,
* which obligations are imposed on the holder of the access rights,
* at which frequency the grant is revisited, i.e. checked whether it is still required to uphold the grant.


1.3 Accountability

Accountability defines the responsibilities of staff members and management with respect to security aspects. This includes

* handling of passwords and security tokens,
* reviewing audit logs and identifying potential security violations,
* management of security and access control and
* reporting of potential security breaches.

Staff members are made aware of their responsibilities on the assignment of duties and on a regular basis.


1.4 Availability

For each facet of the registry operation, beyond the requirements of ICANN, it is determined which service level is required, i.e.

* the availability requirements, defining the desired relative availability over a period of time (typically one month), including the allowed maximum planned and unplanned outage times,
* the recovery time objective and
* the recovery point objective, if applicable.


1.5 Security Role Concept

For the .radio registry, the considerations above manifest themselves in an exhaustive security role concept, which defines roles carrying certain access privileges and responsibilities. Employees at the .radio registry are assigned one or multiple roles identified by this concept, which clearly defines their duties and access rights.


2. Security Commitments to Users of the .radio TLD


2.1 Abuse Prevention and Mitigation

As discussed in detail in the answer to Question 28, the registry has taken various precautions to reduce the probability that the domain names within .radio are being used in connection with abusive or criminal activities.


2.2 Reliability and Availability of DNS

Various technical measures ensure a 100% availability of the DNS, as well as reliable, accurate and fast responses. A highly protected DNSSEC infrastructure ensures that the digital signatures contained in the DNS are trustworthy.


2.3 Technical Progress

The .radio registry is committed to employ state-of-the-art security measures on an ongoing basis. This includes, for example, the use of current and secure software, fast patches of security affecting bugs, and the adoption of new security related technologies as they become available.


3. Security Commitments to Registrants


3.1 Protection of Investment

With the commercialisation of the Internet, domain names have become valuable assets. Domain names are no longer simply a more or less convenient handle for cryptic IP addresses, but as brands they have become the base for whole businesses worth millions to billions. Also, with domain names, lifestyles (ʺtwitterʺ, ʺfacebookʺ generations) and communities are associated. Therefore, the loss, abuse or unavailability of a domain name, be it temporary or permanently, may cause significant damage to the domain name registrant.

The .radio registry fully recognises this. With its highly developed technical and administrative security framework, .radio registry has taken the necessary measures to protect the investments of registrants in their names. Due to the domain auto-renew mechanism, a valid domain is never deleted by the registry itself. In addition, the Redemption Grace Period provides extra protection if a request to delete the domain is inadvertently issued by the registrant himself or by the entrusted registrar. Also, if it can be proven that a domain has been illegally moved to a different registrant, this is reverted by the registry to original state.


3.2 Adherence to Registration Policy

The registration policy clearly defines the conditions by which potential registrants may register domain names. The registrants can rest assured that the registry strictly adheres to these rules. In detail,

* The registry guarantees equal opportunity if multiple registrants meet the registration conditions in the same way.
* The registry applies a clear procedure for handling violations of the registration policy. The registrant has the ability to correct the violations before further actions are taken by the registry; he has also the right to appeal if he believes that the grounds for the registryʹs decisions are invalid.
* The registry maintains its neutrality in conflicts, unless forced by ICANNʹs Uniform Dispute Resolution Policy (UDRP), Uniform Rapid Suspension (URS) and Registry Restrictions Dispute Resolution Procedure (RRDRP).


3.3 Privacy of Registrant Data

While the registry is strongly committed to data protection and privacy, only limited commitments can be made with respect to registrant data. This is owed to various requirements imposed by ICANN for the right to operate the registry.

First, the registry is required to provide so-called Registration Data Directory Services (RDDS). On the one hand, this allows the anonymous public to retrieve information on the registrant of a domain name. The registry tries to mitigate the impact by taking measures against data mining and by fully supporting EPPʹs disclosure settings, which allow the registrant (via the registrar) to restrict the exposure of specific data fields (within the limits of ICANN requirements).

On the other hand, as part of the RDDS, the registry is also required to grant access to the data to eligible users and institutions with legitimate interest, not limited to law enforcement agencies. The registry will monitor the activities of these entities and will withdraw the access if there are indications of excessive or abusive use.

Second, the registry has to give access to the registrant data to ICANN as part of the escrow requirement. While the data is encrypted by a public key of ICANN and thus safe from access by third parties, no guarantees can be given about the data handling by ICANN.

The registry adds a declaration about the data handling to the registration agreement in order to make a potential registrant aware of the limited privacy.