Application number: 1-1143-36731 for WGC (IOM) Limited

WGC (IOM) Limited

Jubilee Buildings
1st Floor Victoria St
Douglas Isle of Man IM1 2SH
GB

+44 1624 699 000

+44 1624 699 001

http:⁄⁄www.gold.org

Ms. Jacqueline Crocker

Head of Digital

+44 20 7826 4700

j.crocker@gold.org

Ms. Birgit Hirst

Consultant

+44 20 7826 4700

b.hirst@gold.org

Company limited by shares

English law
http:⁄⁄www.gov.im⁄ded⁄pvi⁄pvi_fr.html

Not Available

World Gold Council Holdings Limited

Aidan Francis Davin
Director
Fiona Doris Noon
Director
Nina Christine Johnston
Director
Sheila Margaret Dean
Director

World Gold Council Holdings Limited
Not Applicable

gold

Not Available

A number of operational and rendering issues may arise with the delegation, and subsequent operation and use of a new TLD. Some of these issues may be experienced just by the users of one or two particular TLDs, due to the nature or composition of the string itself; whereas other issues (such as software support) may be experienced across all new TLDs.
Evaluation of the potential operational and rendering issues for the .GOLD TLD was delegated to ARI. ARI is experienced with:
– The operational issues of operating TLDs
– TLDs that offer registrations at the third level (eg .com.au, .net.au) and below
– The rendering and operational issues surrounding the introduction of IDNs
ARI has executed a suite of tests to evaluate any issues arising from the use of the TLD string. ARI configured a test environment that consisted of DNS software, web server software, and an email server configured for sample domains in this TLD. Where possible, ARI attempted to test many equivalent applications, however the number of and different versions of applications means that testing was limited to the most common environments.
The tests executed by ARI indicate that the .GOLD TLD is subject to the same issues already experienced by TLDs in the root, which are neither new nor unique. A summary of these common issues is provided below.
- Some applications make assumptions about known valid TLDs and fail to recognize new TLDs
- Some Non-IDN aware applications require the user to provide input in A-labels
- Some IDN aware applications present the user with the domain name using A-labels instead of U-labels
- Some IDN aware applications fail to render IRIs in a manner consistent with user expectations.
To mitigate these issues, ARI will work with the Applicant to ensure that maintainers of applications are made aware of the delegation and operation of this TLD. When relevant, the Applicant will refer the maintainers to the verification code produced by ICANN in the area for Universal Acceptance of All Top Level Domains such that operational issues can be mitigated for other TLDs.
The Applicant and will work with maintainers of applications to provide subject matter knowledge where required, and provide directions to the tools provided by third parties such as the International Components for Unicode project and other groups, that can assist the application maintainer in adding the required support. User education may be required enabling users to configure their applications for correct functioning of this TLD. An informational section on the TLD website will be considered to address questions raised by the Internet community.
The steps ARI will take to mitigate these issues are more than adequate. Thus, we do not believe this TLD raises stability concerns and there is no reason that it should be denied on an operational and rendering issues bases.

The Applicant is a wholly owned subsidiary of the World Gold Council, a non-profit organisation tasked with the market development for the gold industry (collectively referred to as the World Gold Council Group). Working within the investment, jewellery and technology sectors, as well as engaging in government affairs, the World Gold Council’s purpose is to provide industry leadership, whilst stimulating and sustaining demand for gold. Thus, the World Gold Council is involved in every single current application of gold, while also prospecting for new uses for gold, ranging from nanotechnology to new investment products.

The World Gold Council Group has 23 members that comprise the world’s leading gold mining companies, representing approximately 60% of global corporate gold production. Members are active across a wide geographical spread covering markets such as Australia, India, Canada, Africa and China. Based centrally in the UK, the World Gold Council Group works throughout Europe, the US, India and the Far East, engaging with key global and regional stakeholders, partnering with experts in industry and academia to educate decision makers and communicate the value of gold.

Therefore, and given the tasks of the Applicant within the World Gold Council Group, the Applicant is in a unique position to represent and protect the brand of GOLD and GOLD is the World Gold Council Group’s most recognized business and identifier with international exposure.

Based on this background, the purpose of the TLD is manifold, as will be further explained below:
i. Reflect and operate Applicant’s key and most distinctive business and identifier (“GOLD”) at the top level of the DNS’ hierarchy, in particular to distinguish the Applicant’s objective, trusted information on gold from competing online content on gold that may be false or misleading;
It is the Applicant’s strategy to clearly distinguish its Corporate web presence on gold.org, tailored to its Corporate stakeholders, from its market-facing web presence that provides authoritative, objective information about GOLD to consumers .GOLD will help the Applicant achieve this goal.
ii. Provide stakeholders of the Applicant, including subsidiaries, and their respective members, partners, customers, sponsorships, with a recognizable and trusted identifier on the Internet;
iii. Provide such stakeholders with a secure and safe Internet environment that is mainly or even fully under the control of the Applicant and its subcontractors;
iv. Provide selected stakeholders in GOLD brands and identifiers with the opportunity to create a secure and safe Internet environment that is mainly or even fully under control of the Applicant and⁄or such stakeholders.

i. A high-carat environment: At the moment the internet is flooded with misleading information and in some cases doubtful commercial propositions around GOLD. A recent McKinsey study has found that 83% of web content on gold jewellery is SPAM, which makes it difficult for consumers to find relevant, truthful information. One of key activities of the World Gold Council Group is to produce or commission global research into gold and the World Gold Council Group is committed to developing a ‘high-carat’ environment for GOLD that disseminates this information and reflects gold’s value and standing in society. This will protect consumers and the reputation of GOLD. 




ii. Recognition for partners and stakeholders: 
The Wold Gold Council Group has active partnerships with and focuses on supporting early stage companies developing new gold based technologies, sometimes with direct capital investment. At present, they are supporting a number of research projects within academia, small start-up companies and large multi-national corporations, gold’s use in solar nanotechnology and an online gold exchange platform. These partners as well as other stakeholders will benefit from the availability of .GOLD domains, as .GOLD will bring a high degree of recognition and specialization to the currently existing name space. Where in most cases the specific connotation that has been initially given to the gTLDs (or even ccTLDs) has disappeared, the .GOLD top-level domain will be unambiguous as regards the identity of the Registry Operator, the source of the content and services offered under the .GOLD and⁄or the affiliation between the Registry Operator and the TLD;


iii. The authority on Gold across diverse audiences: 
The World Gold Council Group engages regularly with national governments and legislators, as well as supranational bodies including the World Bank, OECD and the European Commission, Council and Parliament. They actively participate in key industry related initiatives, for example being a founding member of the U.S. Agency for International Developmentʹs Public-Private Alliance for Responsible Minerals Trade, as well as currently preparing a gold specific supplement for the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas.

Working with Member companies the World Gold Council Group has developed a Conflict-Free Gold Standard and believes that this initiative represents a major advance towards eradicating gold that fuels conflict. The objective of the Standard is to create absolute trust that the gold produced under its guidelines neither fuels armed conflict, nor funds armed groups, nor contributes to human rights abuses associated with these conflicts. The Standard is designed to apply globally, for World Gold Council members and other companies involved in the extraction of gold.

The World Gold Council’s Director for Responsible Gold has recently been invited by the new Chair of the Kimberly Process (Ambassador Milovanic of the USA) to address the Kimberly Process Review Committee on our work related to the issue of “conflict definition and assessment”. This is the inter-government committee that oversees the Kimberly process.


A prominent internet presence on .GOLD will help to inform the wider community about such initiatives and allow them to become better educated consumers. 

iv. Registration of domain names: The Applicant intends to implement the following policies and procedures with respect to the registration of domain names in the .GOLD top-level domain to include but not limited to:
1. Reservation of domain names in the name of the Applicant. These names include:

a) descriptive names, referring to the actual day-to-day business activities of the Applicant, the World Gold Council Group and⁄or its subsidiaries;
b) descriptive names, referring to the internal departments of the Applicant and the World Gold Council Group;
c) descriptive names, referring to the subsidiaries of the Applicant and the World Council Group;
d) product and service brands promoted by the Applicant, the World Gold Council lGroup and⁄or its subsidiaries now and in the future;
e) Brand names, referring to partners of the Applicant and⁄or the World Gold Council Group (as a seal of approval for partnerships)
f) descriptive words typically associated with the characteristics of GOLD.
The Applicant has already identified ~450 such domain names.

2. Launch of the TLD:

a) Sunrise: allow physical persons, organizations and entities that meet the eligibility requirements in force at that point in time to choose the domain names that are identical to their trademarks; 
b) General availability: other available domain names may be registered by physical persons, organizations and entities that meet the eligibility requirements in force at that point in time to choose the domain names in accordance with the applicable terms and conditions. 
c) Depending on the terms and conditions in force at the time of launch of the TLD, these domain names may or may not be registered in the name of the applicant for the domain name or in the name of the Applicant for the TLD (GOLD). In any case, the Applicant reserves the right to impose additional and other restrictions from time to time at its sole discretion;

v. Given the fact that the Applicant is a company that is established in the United Kingdom, it is subject to both national and European privacy and data protection rules and practices, to which the Applicant will comply. 
Due to the international nature of the Applicant’s business it has different ways in order to make existing and future partners, visitors, communities and stakeholders aware of the .GOLD TLD, including but not limited to:
1. Digital campaigns such as Search marketing, Online advertising and Social Media;
2. having Internet traffic to its key domain names resolving into domain names registered in the .GOLD TLD;
3. CRM and email marketing campaigns; etc.

i. The Applicant will organize the registry operation for the .GOLD in such a manner that it will minimize the likelihood of having multiple applications for a particular domain name. This can be achieved in one of the following ways:
1. Given the fact that, at least prior to the launch of the .GOLD top-level domain, the Applicant ⁄ Registry Operator will reserve, delegate and use a large number of domain names that are directly or indirectly relevant to Applicant’s business in its own name. Since quite a number of these domain names will be of a descriptive nature, the chances for qualifying ⁄ eligible applicants ⁄ registrants to register such domain names after the launch will be limited;
2. The Registry Operator will release available domain names post launch in a highly controlled manner, focusing primarily on making domain names available for the brands or product names of approved third parties, which also reduces the likelihood that two or more applicants qualify for the registration of the same domain name in the .GOLD top-level domain;
3. As a method of last resort, and subject to the actual domain name registration policy adopted by the Registry Operator and in force at the time of registration, domain names will be allocated on a first-come, first-served basis.
ii. The Applicant ⁄ Registry Operator may, at its discretion charge a fee for the registration of domain names under the .GOLD TLD. Such fee and domain name registration may be part of a larger package of services offered by the Applicant or its subsidiaries.
iii. The Applicant ⁄ Registry Operator may at its discretion make contractual commitments to increase or decrease the fees for the registration of domain names under the .GOLD TLD.

No

Not Available

No

Given the fact that the Applicant is part of an international association of high repute, known worldwide, it has a vested interest in giving its visitors, customers and business partners a clear and predictable naming scheme in the .GOLD TLD. Since visitors and customers may mainly be looking for offers and activities organized by the World Gold Council business units on the basis of their geographic destination, the Applicant may indeed develop plans in order to register domain names that exclusively contain geographic names (country names, city names, names of regions, etc.).
However, if such domain names will be registered, the Applicant will do so considering the following confines:
(i) these domain names will be exclusively registered in the name of the Applicant ⁄ Registry Operator or its Affiliates, and not in the name of a third party that is not controlled by the Applicant ⁄ Registry Operator, unless agreed upon otherwise with the authority competent for giving its consent in accordance with Specification 5 of the Registry Agreement;
(ii) where consents are required prior to the registration and use of a domain name referred to and in accordance with Specification 5 of the Registry Agreement, the Applicant will obtain such consents before actually registering, delegating and using these domain names.
In any case the registration, delegation and use of domain names corresponding to geographic names will at all times be done: 
- in the best interest of the Applicant and its business activities; and
- in order to directly and indirectly promote local commercial activity in the geographic locations of which the name has been registered in accordance with (i) above.

As mentioned in response to Question 18 (b) above, the Applicant is is the market development organisation for the gold industry. In connection to its business, the Applicant has a experience in managing complex information technology infrastructures, hereby relying on in-house and external resources.

However, the Applicant has no in-depth experience in managing a domain name registry system and it would require too many efforts for the Applicant to develop a system itself that complies with the specific technical requirements imposed upon new gTLD registries. Therefore, the Applicant has decided to rely on ARI Registry Services (“ARI” – see www.ariservices.com)and NetNames to provide a full suite of services in relation to the deployment and operation of its applied-for .GOLD TLD. It has been agreed between the Applicant and ARI that ARI will perform the back-end registry services for the .GOLD registry. 

The response to this question describes the registry services for the .GOLD TLD as will be provided by ARI, in the name and on behalf of the Applicant. These registry services are referred to as ARI’s Managed TLD Registry Service. When it is stated that ARI will perform certain services or comply with certain standards or processes, ARI will do this in the name and on behalf of the Applicant, who itself is committed to comply with these standards or processes towards ICANN. Where use is made of the first person plural, reference is made to ARI, as the answer to this question is provided directly by ARI, the back-end provider of registry services for the applied-for .GOLD TLD (also referred to as ‘this TLD’).

It goes without saying that each and every service offered under the .GOLD gTLD will be provided under the authority and responsibility of the Applicant.

1 INTRODUCTION

ARI’s Managed TLD Registry Service is a complete offering, providing all of the required registry services. What follows is a description of each of those services.

2 REGISTRY SERVICES
The following sections describe the registry services provided. Each of these services has, where required, been designed to take into account the requirements of consensus policies as documented here:
[http:⁄⁄www.icann.org⁄en⁄resources⁄Registrars⁄consensus-policies]
At the time of delegation into the root this TLD will not be offering any unique Registry services.

2.1 Receipt of Data from Registrars

The day-to-day functions of the registry, as perceived by Internet users, involves the receipt of data from Registrars and making the necessary changes to the SRS database. Functionality such as the creation, renewal and deletion of domains by Registrars, on behalf of registrants, is provided by two separate systems:
– An open protocol-based provisioning system commonly used by Registrars with automated domain management functionality within their own systems.
– A dedicated website providing the same functionality for user interaction.
Registrants (or prospective registrants) who wish to manage their existing domains or credentials, register new domains or delete their domains will have their requests carried out by Registrars using one of the two systems described below.
ARI operates Extensible Provisioning Protocol (EPP) server software and distributes applicable toolkits to facilitate the receipt of data from Registrars in a common format. EPP offers a common protocol for Registrars to interact with SRS data and is favoured for automating such interaction in the Registrar’s systems. In addition to the EPP server, Registrars have the ability to use a web-based management interface (SRS Web Interface), which provides functions equivalent to the EPP server functionality.

2.1.1 EPP

The EPP software allows Registrars to communicate with the SRS using a standard protocol. The EPP server software is compliant with all appropriate RFCs and will be updated to comply with any relevant new RFCs or other new standards, as and when they are finalised. All standard EPP operations on SRS objects are supported.
Specifically, the EPP service complies with the following standards:
– RFC 5730 Extensible Provisioning Protocol (EPP).
– RFC 5731 Extensible Provisioning Protocol (EPP) Domain Name Mapping.
– RFC 5732 Extensible Provisioning Protocol (EPP) Host Mapping.
– RFC 5733 Extensible Provisioning Protocol (EPP) Contact Mapping.
– RFC 5734 Extensible Provisioning Protocol (EPP) Transport over TCP.
– RFC 5910 Domain Name System (DNS) Security Extensions for the Extensible Provisioning Protocol (EPP).
– RFC 3915 Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (EPP).
– Extensions to ARI’s EPP service comply with RFC 3735 Guidelines for Extending the Extensible Provisioning Protocol (EPP).

2.1.1.1 Security for EPP Service

To avoid abuse and to mitigate potential fraudulent operations, the EPP server software uses a number of security mechanisms that restrict the source of incoming connections and prescribe the authentication and authorisation of the client. Connections are further managed by command rate limiting and are restricted to only a certain number for each Registrar, to help reduce unwanted fraudulent and other activities. Additionally, secure communication to the EPP interface is required, lowering the likelihood of the authentication mechanisms being compromised.
The EPP server has restrictions on the operations it is permitted to make to the data within the registry database. Except as allowed by the EPP protocol, the EPP server cannot update the credentials used by Registrars for access to the SRS. These credentials include those used by Registrars to login to ARI’s SRS Web Interface and the EPP service.
Secure communication to the EPP server is achieved via the encryption of EPP sessions. The registry system and associated toolkits support AES 128 and 256 via TLS.
The Production and Operational Testing and Evaluation (OTE) EPP service is protected behind a secure firewall that only accepts connections from registered IP addresses. Registrars are required to supply host IP addresses that they intend to use to access the EPP service.
Certificates are used for encrypted communications with the registry. Registrars require a valid public⁄private key pair signed by the ARI CA to verify authenticity. These certificates are used to establish a TLS secure session between client and server.
EPP contains credential elements in its specification which are used as an additional layer of authentication. In accordance with the EPP specification, the server does not allow client sessions to carry out any operations until credentials are verified.
The EPP server software combines the authentication and authorisation elements described above to ensure the various credentials supplied are associated with the same identity. This verification requires that:
– The username must match the common name in the digital certificate.
– The certificate must be presented from a source IP listed against the Registrar whose common name appears in the certificate.
– The username and password must match the user name and password listed against the Registrar’s account with that source IP address.
To manage normal operations and prevent an accidental or intentional Denial of Service, the EPP server can be configured to rate limit activities by individual Registrars.

2.1.1.2 Stability Considerations

The measures that restrict Registrars to a limit of connections and operations for security purposes also serve to keep the SRS and the EPP server within an acceptable performance and resource utilisation band. Therefore, scaling the service is an almost linear calculation based on well-defined parameters.
The EPP server offers consistent information between Registrars and the SRS Web Interface. The relevant pieces of this information are replicated to the DNS within seconds of alteration, thus ensuring that a strong consistency between the SRS and DNS is maintained at all times.

2.1.2 SRS Web Interface

The registry SRS Web Interface offers Registrars an alternative SRS interaction mechanism to the EPP server. Available over HTTPS, this interface can be used to carry out all operations which would otherwise occur via EPP, as well as many others. Registrars can use the SRS Web Interface, the EPP server interface or both – with no loss of consistency within the SRS.

2.1.2.1 Security and Consistency Considerations for SRS Web Interface

The SRS Web Interface contains measures to prevent abuse and to mitigate fraudulent operations. By restricting access, providing user level authentication and authorisation, and protecting the communications channel, the application limits both the opportunity and scope of security compromise.
Registrars are able to create individual users that are associated with their Registrar account. By allocating the specific operations each user can access, Registrars have full control over how their individual staff members interact with the SRS. Users can be audited to identify which operations were conducted and to which objects those operations were applied.
A secure connection is required before credentials are exchanged and once authenticated. On login, any existing user sessions are invalidated and a new session is generated, thereby mitigating session-fixation attacks and reducing possibilities that sessions could be compromised.

2.1.3 Securing and Maintaining Consistency of Registry-Registrar Interaction Systems

ARI ensures all systems through which Registrars interact with the SRS remain consistent with each other and apply the same security rules. Additionally, ARI also ensures that operations on SRS objects are restricted to the appropriate entity. For example:
– In order to initiate a transfer a Registrar must provide the associated domain password (authinfo) which will only be known by the registrant and the current sponsoring Registrar.
– Only sponsoring Registrars are permitted to update registry objects.
All operations conducted by Registrars on SRS objects are auditable and are identifiable to the specific Registrar’s user account, IP address and the time of the operation.

2.2 Disseminate Status Information of TLD Zone Servers to Registrars

The status of TLD zone servers and their ability to reflect changes in the SRS is of great importance to Registrars and Internet users alike. ARI will ensure that any change from normal operations is communicated to the relevant stakeholders as soon as is appropriate. Such communication might be prior to the status change, during the status change and⁄or after the status change (and subsequent reversion to normal) – as appropriate to the party being informed and the circumstance of the status change.
Normal operations are those when:
– DNS servers respond within SLAs for DNS resolution.
– Changes in the SRS are reflected in the zone file according to the DNS update time SLA.
The SLAs are those from Specification 10 of the Registry Agreement.
A deviation from normal operations, whether it is registry wide or restricted to a single DNS node, will result in the appropriate status communication being sent.

2.2.1 Communication Policy

ARI maintains close communication with Registrars regarding the performance and consistency of the TLD zone servers.
A contact database containing relevant contact information for each Registrar is maintained. In many cases, this includes multiple forms of contact, including email, phone and physical mailing address. Additionally, up-to-date status information of the TLD zone servers is provided within the SRS Web Interface.
Communication using the Registrar contact information discussed above will occur prior to any maintenance that has the potential to effect the access to, consistency of, or reliability of the TLD zone servers. If such maintenance is required within a short time frame, immediate communication occurs using the above contact information. In either case, the nature of the maintenance and how it affects the consistency or accessibility of the TLD zone servers, and the estimated time for full restoration, are included within the communication.
That being said, the TLD zone server infrastructure has been designed in such a way that we expect no down time. Only individual sites will potentially require downtime for maintenance; however the DNS service itself will continue to operate with 100% availability.

2.2.2 Security and Stability Considerations

ARI restricts zone server status communication to Registrars, thereby limiting the scope for malicious abuse of any maintenance window. Additionally, ARI ensures Registrars have effective operational procedures to deal with any status change of the TLD nameservers and will seek to align its communication policy to those procedures.

2.3 Zone File Access Provider Integration

Individuals or organisations that wish to have a copy of the full zone file can do so using the Zone Data Access service. This process is still evolving; however the basic requirements are unlikely to change. All registries will publish the zone file in a common format accessible via secure FTP at an agreed URL.

ARI will fully comply with the processes and procedures dictated by the Centralised Zone Data Access Provider (CZDA Provider or what it evolves into) for adding and removing Zone File access consumers from its authentication systems. This includes:

– Zone file format and location.
– Availability of the zone file access host via FTP.
– Logging of requests to the service (including the IP address, time, user and activity log).
– Access frequency.

2.4 Zone File Update

To ensure changes within the SRS are reflected in the zone file rapidly and securely, ARI updates the zone file on the TLD zone servers using software compliant with RFC 2136 (Dynamic Updates in the Domain Name System (DNS UPDATE)) and RFC 2845 (Secret Key Transaction Authentication for DNS (TSIG)).
This updating process follows a staged but rapid propagation of zone update information from the SRS, outwards to the TLD zone servers – which are visible to the Internet. As changes to the SRS data occur, those changes are updated to isolated systems which act as the authoritative primary server for the zone, but remain inaccessible to systems outside ARI’s network. The primary servers notify the designated secondary servers, which service queries for the TLD zone from the public. Upon notification, the secondary servers transfer the incremental changes to the zone and publicly present those changes.
The protocols for dynamic update are robust and mature, as is their implementation in DNS software. The protocols’ mechanisms for ensuring consistency within and between updates are fully implemented in ARI’s TLD zone update procedures. These mechanisms ensure updates are quickly propagated while the data remains consistent within each incremental update, regardless of the speed or order of individual update transactions. ARI has used this method for updating zone files in all its TLDs including the .au ccTLD, pioneering this method during its inception in 2002. Mechanisms separate to RFC 2136-compliant transfer processes exist; to check and ensure domain information is consistent with the SRS on each TLD zone server within 10 minutes of a change.

2.5 Operation of Zone Servers

ARI maintains TLD zone servers which act as the authoritative servers to which the TLD is delegated.

2.5.1 Security and Operational Considerations of Zone Server Operations

The potential risks associated with operating TLD zone servers are recognised by ARI such that we will perform the steps required to protect the integrity and consistency of the information they provide, as well as to protect the availability and accessibility of those servers to hosts on the Internet. The TLD zone servers comply with all relevant RFCs for DNS and DNSSEC, as well as BCPs for the operation and hosting of DNS servers. The TLD zone servers will be updated to support any relevant new enhancements or improvements adopted by the IETF.
The DNS servers are geographically dispersed across multiple secure data centres in strategic locations around the world. By combining multi-homed servers and geographic diversity, ARI’s zone servers remain impervious to site level, supplier level or geographic level operational disruption.
The TLD zone servers are protected from accessibility loss by malicious intent or misadventure, via the provision of significant over-capacity of resources and access paths. Multiple independent network paths are provided to each TLD zone server and the query servicing capacity of the network exceeds the extremely conservatively anticipated peak load requirements by at least 10 times, to prevent loss of service should query loads significantly increase.
As well as the authentication, authorisation and consistency checks carried out by the Registrar access systems and DNS update mechanisms, ARI reduces the scope for alteration of DNS data by following strict DNS operational practices:
– TLD zone servers are not shared with other services.
– The primary authoritative TLD zone server is inaccessible outside ARI’s network.
– TLD zone servers only serve authoritative information.
– The TLD zone is signed with DNSSEC and a DNSSEC Practice⁄Policy Statement published.

2.6 Dissemination of Contact or Other Information

Registries are required to provide a mechanism to identify the relevant contact information for a domain. The traditional method of delivering this is via the WhoIs service, a plain text protocol commonly accessible on TCP port 43. ARI also provides the same functionality to users via a web-based WhoIs service. Functionality remains the same with the web-based service, which only requires a user to have an Internet browser.
Using the WhoIs service, in either of its forms, allows a user to query for domain-related information. Users can query for domain details, contact details, nameserver details or Registrar details.
A WhoIs service, which complies with RFC 3912, is provided to disseminate contact and other information related to a domain within the TLD zone.

2.6.1 Security and Stability Considerations

ARI ensures the service is available and accurate for Internet users, while limiting the opportunity for its malicious use. Many reputation and anti-abuse services rely on the availability and accuracy of the WhoIs service, however the potential for abuse of the WhoIs service exists.
Therefore, certain restrictions are made to the access of WhoIs services, the nature of which depend on the delivery method – either web-based or the traditional text-based port 43 service. In all cases, there has been careful consideration given to the benefits of WhoIs to the Internet community, as well as the potential harm to registrants – as individuals and a group – with regard to WhoIs access restrictions.
The WhoIs service presents data from the registry database in real time. However this access is restricted to reading the appropriate data only. The WhoIs service does not have the ability to alter data or to access data not related to the WhoIs service. The access limitations placed on the WhoIs services prevent any deliberate or incidental denial of service that might impact other registry services.
Restrictions placed on accessing WhoIs services do not affect legitimate use. All restrictions are designed to target abusive volume users and to provide legitimate users with a fast and available service. ARI has the ability to ‘whitelist’ legitimate bulk users of WhoIs, to ensure they are not impacted by standard volume restrictions.
The data presentation format is consistent with the canonical representation of equivalent fields, as defined in the EPP specifications and ICANN agreement.

2.6.1.1 Port 43 WhoIs

A port 43-based WhoIs service complying with RFC 3912 is provided and will be updated to meet any other relevant standards or best practice guidelines related to the operation of a WhoIs service.
While the text-based service can support thousands of simultaneous queries, it has dynamic limits on queries per IP address to restrict data mining efforts. In the event of identified malicious use of the service, access from a single IP address or address ranges can be limited or blocked.

2.6.1.2 Web-based WhoIs

ARI’s web-based WhoIs service provides information consistent with that contained within the SRS.
The web-based WhoIs service contains an Image Verification Check (IVC) and query limits per IP address. These restrictions strike a balance between acceptable public usage and abusive use or data mining. The web-based WhoIs service can blacklist IP addresses or ranges to prevent abusive use of the service.

2.7 IDNs – Internationalised Domain Names

An Internationalised Domain Name (IDN) allows registrants to register domains in their native language and have it display correctly in IDN aware software. This includes allowing a language to be read in the manner that would be common for its readers. For example, an Arabic domain would be presented right to left for an Arabic IDN aware browser.
The inclusion of IDNs into the TLD zones is supported by ARI. All the registry services, such as the EPP service, SRS Web Interface and RDPS (web and port 43), support IDNs. However there are some stability and security considerations related to IDNs which fall outside the general considerations applicable individually to those services.

2.7.1 Stability Considerations Specific to IDN

To avoid the intentional or accidental registration of visually similar chars, and to avoid identity confusion between domains, there are several restrictions on the registration of IDNs.

2.7.1.1 Prevent Cross Language Registrations

Domains registered within a particular language are restricted to only the chars of that language. This avoids the use of visually similar chars within one language which mimic the appearance of a label within another language, regardless of whether that label is already within the DNS or not.

2.7.1.2 Inter-language and Intra-language Variants to Prevent Similar Registrations

ARI restricts child domains to a specific language and prevents registrations in one language being confused with a registration in another language, for example Cyrillic а (U+0430) and Latin a (U+0061).

2.8 DNSSEC

DNSSEC provides a set of extensions to the DNS that allow an Internet user (normally the resolver acting on a user’s behalf) to validate that the DNS responses they receive were not manipulated en-route.
This type of fraud, commonly called ‘man in the middle’, allows a malicious party to misdirect Internet users. DNSSEC allows a domain owner to sign their domain and to publish the signature, so that all DNS consumers who visit that domain can validate that the responses they receive are as the domain owner intended.
Registries, as the operators of the parent domain for registrants, must publish the DNSSEC material received from registrants, so that Internet users can trust the material they receive from the domain owner. This is commonly referred to as a ‘chain of trust’. Internet users trust the root (operated by IANA), which publishes the registries’ DNSSEC material, therefore registries inherit this trust. Domain owners within the TLD subsequently inherit trust from the parent domain when the registry publishes their DNSSEC material.
In accordance with new gTLD requirements, the TLD zone will be DNSSEC signed and the receipt of DNSSEC material from Registrars for child domains is supported in all provisioning systems.

2.8.1 Stability and Operational Considerations for DNSSEC

2.8.1.1 DNSSEC Practice Statement

ARI’s DNSSEC Practice Statement is included in our response to Question 43. The DPS following the guidelines set out in the draft IETF DNSOP DNSSEC DPS Framework document.

2.8.1.2 Receipt of Public Keys from Registrars

The public key for a child domain is received by ARI from the Registrar via either the EPP or SRS Web Interface. ARI uses an SHA-256 digest to generate the DS Resource Record (RR) for inclusion into the zone file.

2.8.1.3 Resolution Stability

DNSSEC is considered to have made the DNS more trustworthy; however some transitional considerations need to be taken into account. DNSSEC increases the size and complexity of DNS responses. ARI ensures the TLD zone servers are accessible and offer consistent responses over UDP and TCP.
The increased UDP and TCP traffic which results from DNSSEC is accounted for in both network path access and TLD zone server capacity. ARI will ensure that capacity planning appropriately accommodates the expected increase in traffic over time.
ARI complies with all relevant RFCs and best practice guides in operating a DNSSEC-signed TLD. This includes conforming to algorithm updates as appropriate. To ensure Key Signing Key Rollover procedures for child domains are predictable, DS records will be published as soon as they are received via either the EPP server or SRS Web Interface. This allows child domain operators to rollover their keys with the assurance that their timeframes for both old and new keys are reliable.

3 APPROACH TO SECURITY AND STABILITY

Stability and security of the Internet is an important consideration for the registry system. To ensure that the registry services are reliably secured and remain stable under all conditions, ARI takes a conservative approach with the operation and architecture of the registry system.
By architecting all registry services to use the least privileged access to systems and data, risk is significantly reduced for other systems and the registry services as a whole should any one service become compromised. By continuing that principal through to our procedures and processes, we ensure that only access that is necessary to perform tasks is given. ARI has a comprehensive approach to security modelled of the ISO27001 series of standards and explored further in the relevant questions of this response.
By ensuring all our services adhering to all relevant standards, ARI ensures that entities which interact with the registry services do so in a predictable and consistent manner. When variations or enhancements to services are made, they are also aligned with the appropriate interoperability standards.

The Applicant has engaged ARI Registry Services (ARI) to deliver services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q24 – ARI Background & Roles.pdf’. This response describes the SRS as implemented by ARI.

1 INTRODUCTION
ARI has demonstrated delivery of an SRS with exceptional availability, performance and reliability. ARI are experienced running mission critical SRSs and have significant knowledge of the industry and building and supporting SRSs.
ARI’s SRS has successfully supported a large group of Registrars for ASCII and IDN based TLDs. The system is proven to sustain high levels of concurrency, transaction load, and system uptime. ARI’s SRS meets the following requirements:
– Resilient to wide range of security & availability threats
– Consistently exceeds performance & availability SLAs
– Allows capacity increase with minimal impact to service
– Provides fair & equitable provisioning for all Registrars

2 CAPACITY
ARI’s SRS was built to sustain 20M domain names. Based on ARI’s experience running a ccTLD registries and industry analysis, ARI were able to calculate the conservative characteristics of a registry this size.
Through conservative statistical analysis of the .au registry and data presented in the May 2011 ICANN reports for the .com & .net, .org, .mobi, .info, .biz and .asia [http:⁄⁄www.icann.org⁄en⁄resources⁄registries⁄reports] we know there is:
– An average of 70 SRS TPS per domain, per month
– A ratio of 3 query to 2 transform txs
This indicates an expected monthly transaction volume of 1,400M txs (840M query and 560M transforms).
Through statistical analysis of the .au registry and backed up by the data published in the .net RFP responses [http:⁄⁄archive.icann.org⁄en⁄tlds⁄net-rfp⁄net-rfp-public-comments.htm] we also know:
– The peak daily TPS is 6% of monthly total
– The peak 5 min is 5% of the peak day
Thus we expect a peak EPP tx rate of 14,000 TPS (5,600 transform TPS and 8,400 query TPS)
Through conservative statistical analysis of the .au registry we know:
– The avg no. contacts⁄domain is 3.76
– The avg no. hosts⁄domain is 2.28
This translates into a requirement to store 75.2M contacts and 45.6M hosts.
Finally through real world observations of the .au registry, which has a comprehensive web interface when compared to those offered by current gTLD registries, we know there is an avg of 0.5 HTTP requests⁄sec to the SRS web interface per Registrar. We also know that this behaviour is reasonably flat. To support an estimated 1000 Registrars, would require 500 requests⁄second.
For perspective on the conservativeness of this, the following was taken from data in the May 2011 ICANN reports referenced above:
– .info: ~7.8M names peaks at ~1,400 TPS (projected peak TPS of ~3,600 with 20M)
– .com: ~98M names peaks at ~41,000 TPS (projected peak TPS of ~8,300 TPS with 20M)
– .org: ~9.3M names, peaks at ~1,400 TPS (projected peak TPS of ~3,100 with 20M)
After performing this analysis the projected TPS for .com was still the largest value.
ARI understand the limitations of this method but it serves as a best estimate of probable tx load. ARI has built overcapacity of resources to account for limitations of this method, however as numbers are more conservative than real world observations, we are confident this capacity is sufficient.
This TLD is projected to reach 6000 domains at its peak volume and will generate 4,2 EPP TPS. This will consume 0,03% of the resources of the SRS infrastructure. As is evident ARI’s SRS can easily accommodate this TLD’s growth plans. See attachment ‘Q24 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI expects to provide Registry services to 100 TLDs and a total of 12M domains by end of 2014. With all the TLDs and domains combined, ARI’s SRS infrastructure will be 60% utilized. The SRS infrastructure capacity can be easily scaled as described in Q32
ARI benchmarked their SRS infrastructure and used the results to calculate the required computing resources for each of the tiers within the architecture; allowing ARI to accurately estimate the required CPU, IOPS, storage and memory requirements for each server, and the network bandwidth & packet throughput requirements for the anticipated traffic. These capacity numbers were then doubled to account for unanticipated traffic spikes, errors in predictions, and headroom for growth. Despite doubling numbers, effective estimated capacity is still reported as 20M. The technical resource allocations are explored in Q32.

3 SRS ARCHITECTURE
ARI’s SRS has the following major components:
– Network Infrastructure
– EPP Application Servers
– SRS Web Interface Application Servers
– SRS Database
Attachment ‘Q24 – SRS.pdf’ shows the SRS systems architecture and data flows. Detail on this architecture is in our response to Q32. ARI provides two distinct interfaces to the SRS: EPP and SRS Web. Registrar SRS traffic enters the ARI network via the redundant Internet link and passes (via the firewall) to the relevant application server for the requested service (EPP or SRS Web). ARI’s EPP interface sustains high volume and throughput domain provisioning transactions for a large number of concurrent Registrar connections. ARI’s SRS Web interface provides an alternative to EPP with a presentation centric interface and provides reporting and verification features additional to those provided by the EPP interface.

3.1 EPP
ARI’s EPP application server is based on EPP as defined in RFCs 5730 – 5734. Registrars send XML based transactions to a load balanced EPP interface which forwards to one of the EPP application servers. The EPP application server then processes the XML and converts the request into database calls that retrieve or modify registry objects in the SRS database. The EPP application server tier comprises of three independent servers with dedicated connections to the registry database. Failure of any one of these servers will cause Registrar connections to automatically re-establish with one of the remaining servers. Additional EPP application servers can be added easily without any downtime. All EPP servers accept EPP both IPv4 & IPv6.

3.2 SRS Web
The SRS Web application server is a Java web application. Registrars connect via the load balancer to a secure HTTP listener running on the web servers. The SRS web application converts HTTPs requests into database calls which query or update objects in the SRS database. The SRS Web application server tier consists of two independent servers that connect to the database via JDBC. If one of these servers is unavailable the load balancer re-routes requests to the surviving server. Additional servers can be added easily without any downtime. These servers accept both IPv4 & IPv6.

3.3 SRS Database
The SRS database provides persistent storage for domains and supporting objects. It offers a secure way of storing and retrieving objects provisioned within the SRS and is built on the Oracle 11g Enterprise Edition RDBMS. The SRS Database tier consists of four servers clustered using Oracle Real Application Clusters (RAC). In the event of failure of a database server, RAC will transparently transition its client connections to a surviving database host. Additional servers can be added easily without any downtime.

3.4 Number of Servers
EPP Servers – The EPP cluster consists of 3 servers that can more than handle the anticipated 20M domains. This TLD will utilize 0,03% of this capacity at its peak volume. As the utilisation increases ARI will add additional servers ensuring the utilisation doesn’t exceed 50% of total capacity. Adding a new server to the cluster can be done live without downtime.
SRS Web Servers – The SRS Web cluster consists of 2 servers that can more than handle the anticipated 20M domains. This TLD will utilize 0,03% of this capacity at its peak volume. As the utilisation increases ARI will add additional servers ensuring the utilisation doesn’t exceed 50% of total capacity. Adding a new server to the cluster can be done live without downtime.
SRS DB Servers – The SRS DB cluster consists of 4 servers that can more than handle the anticipated 20M domains. This TLD will utilize 0,03% of this capacity at its peak volume. As the utilisation increases ARI will add additional servers ensuring the total utilisation doesn’t exceed 50% of total capacity. Adding a new server to the cluster can be done live without downtime.

3.5 SRS Security
ARI adopts a multi-layered security solution to protect the SRS. An industry leading firewall is deployed behind the edge router and is configured to only allow traffic on the minimum required ports and protocols. Access to the ARI EPP service is restricted to a list of known Registrar IPs.
An Intrusion Detection device is in-line with the firewall to monitor and detect suspicious activity.
All servers are configured with restrictive host based firewalls, intrusion detection, and SELinux. Direct root access to these servers is disabled and all access is audited and logged centrally.
The SRS database is secured by removal of non-essential features and accounts, and ensuring all remaining accounts have strong passwords. All database accounts are assigned the minimum privileges required to execute their business function.
All operating system, database, and network device accounts are subject to strict password management controls such as validity & complexity requirements.
Registrar access to the SRS via EPP or the Web interface is authenticated and secured with multi-factor authentication (NIST Level 3) and digital assertion as follows:
– Registrar’s source IP must be allowed by the front-end firewalls. This source IP is received from the Registrar via a secure communication channel from within the SRS Web interface
– Registrar must use a digital certificate provided by ARI
– Registrar must use authentication credentials that are provided by encrypted email
All communication between the Registrar and the SRS is encrypted using at least 128 bit encryption which been designated as ‘Acceptable’ till ‘2031 and beyond’ by NIST Special Publication 800-57.

3.6 SRS High Availability
SRS availability is of paramount. Downtime is eliminated or minimised where possible. The infrastructure contains no single points of failure. N+1 redundancy is used as a minimum, which not only protects against unplanned downtime but also allows ARI to execute maintenance without impacting service.
Redundancy is provided in the network with hot standby devices & multiple links between devices. Failure of any networking component is transparent to Registrar connections.
N+N redundancy is provided in the EPP and SRS Web application server tiers by the deployment of multiple independent servers grouped together as part of a load-balancing scheme. If a server fails the load balancer routes requests to the remaining servers.
N+N redundancy is provided in the database tier by the use of Oracle Real Application Cluster technology. This delivers active⁄active clustering via shared storage. This insulates Registrars from database server failure.
Complete SRS site failure is mitigated by the maintenance of a remote standby site – a duplicate of the primary site ready to be the primary if required.
The standby site database is replicated using real time transaction replication from the main database using Oracle Data Guard physical standby. If required the Data Guard database can be activated quickly and service resumes at the standby site.

3.7 SRS Scalability
ARI’s SRS scales efficiently. At the application server level, additional computing resource can be brought on-line rapidly by deploying a new server online. During benchmarking this has shown near linear.
The database can be scaled horizontally by adding a new cluster node into the RAC cluster online. This can be achieved without disruption to connections. The SRS has demonstrated over 80% scaling at the database level, but due to the distributed locking nature of Oracle RAC, returns are expected to diminish as the number of servers approaches double digits. To combat this ARI ensures that when the cluster is ‘scaled’ more powerful server equipment is added rather than that equal to the current members. Capacity can be added to the SAN at any time without downtime increasing storage and IOPs.

3.8 SRS Inter-operability and Data Synchronisation
The SRS interfaces with a number of related registry systems as part of normal operations.

3.8.1 DNS Update
Changes made in the SRS are propagated to the DNS via an ARI proprietary DNS Update process. This process runs on the ‘hidden’ primary master nameserver and waits on a queue. It is notified when the business logic inserts changes into the queue for processing. The DNS Update process reads these queue entries and converts them into DNS update (RFC2136) commands that are sent to the nameserver. The process of synchronising changes to SRS data to the DNS occurs in real-time.

3.8.2 WhoIs
The provisioned data supporting the SRS satisfies WhoIs queries. Thus the WhoIs and SRS share data sets and the WhoIs is instantaneously updated. Under normal operating conditions the WhoIs service is provided by the infrastructure at the secondary site in order to segregate the load and protect SRS from WhoIs demand (and vice versa). WhoIs queries that hit the standby site will query data stored in the standby database – maintained in near real-time using Oracle Active Data Guard. If complete site failure occurs WhoIs and SRS can temporarily share the same operations centre at the same site (capacity numbers are calculated for this).

3.8.3 Escrow
A daily Escrow extract process executes on the database server via a dedicated database account with restricted read-only access. The results are then transferred to the local Escrow Communications server by SSH.

4 OPERATIONAL PLAN
ARI follow defined policies⁄procedures that have developed over time by running critical registry systems. Some principals captured by these are:
– Conduct all changes & upgrades under strict and well-practised change control procedures
– test, test and test again
– Maintain Staging environments as close as possible to production infrastructure⁄configuration
– Eliminate all single points of failure
– Conduct regular security reviews & audits
– Maintain team knowledge & experience via skills transfer⁄training
– Replace hardware when no longer supported by vendor
– Maintain spare hardware for all critical components
– Execute regular restore tests of all backups
– Conduct regular capacity planning exercises
– Monitor everything from multiple places but ensure monitoring is not ‘chatty’
– Employ best of breed hardware & software products & frameworks (such as ITIL, ISO27001 and Prince2)
– Maintain two distinct OT&E environments to support pre-production testing for Registrars

5 SLA, RELIABILITY & COMPLIANCE
ARI’s SRS adheres to and goes beyond the scope of Specification 6 and Specification 10 of the Registry Agreement. ARI’s EPP service is XML compliant and XML Namespace aware. It complies with the EPP protocol defined in RFC5730, and the object mappings for domain, hosts & contacts are compliant with RFC 5731, 5732 & 5733 respectively. The transport over TCP is compliant with RFC5734. The service also complies with official extensions to support DNSSEC, RFC5910, & Redemption Grace Period, RFC 3915.
ARI’s SRS is sized to sustain a peak transaction rate of 14,000 TPS while meeting strict internal Operational Level Agreements (OLAs). The monthly-based OLAs below are more stringent than those in Specification 10 (Section 2).
EPP Service Availability: 100%
EPP Session Command Round Trip Time (RTT): 〈=1000ms for 95% of commands
EPP Query Command Round Trip Time (RTT): 〈=500ms for 95% of commands
EPP Transform Command Round Trip Time (RTT): 〈=1000ms for 95% of commands
SRS Web Interface Service Availability: 99.9%
ARI measure the elapsed time of every query, transform and session EPP transaction, and calculate the percentage of commands that fall within OLA on a periodic basis. If percentage value falls below configured thresholds on-call personnel are alerted.
SRS availability is measured by ARI’s monitoring system which polls both the EPP and SRS Web services status. These checks are implemented as full end to end monitoring scripts that mimic user interaction, providing a true representation of availability. These ‘scripts’ are executed from external locations on the Internet. 

6 RESOURCES
This function will be performed by ARI. ARI staff are industry leading experts in domain name registries with the experience and knowledge to deliver outstanding SRS performance.
The SRS is designed, built, operated and supported by the following ARI departments:
– Products and Consulting Team (7 staff)
– Production Support Group (27 staff)
– Development Team (11 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided in attachment ‘Q24 – ARI Background & Roles.pdf’. This attachment describes the functions of the teams and the number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a vast experience in estimating the number of resources required to support a SRS.
Based on past experience ARI estimates that the existing staff is adequate to support an SRS that supporting at least 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q24 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required, trained resources can be added to any of the teams with a 2 month lead time.
The Products and Consulting team is responsible for product management of the SRS solution including working with clients and the industry to identify new features or changes required. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
The Production Support Group (PSG) is responsible for the design, deployment and maintenance of the SRS infrastructure including capacity planning and monitoring as well as security aspects – ensuring the SRS services are available and performing at the appropriate level and operating correctly. The team consists of:
– Production Support Manager
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support):
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation:
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrator
 – 1 Network Engineer
The development team is responsible for implementing changes and new features into the SRS as well as bug fixing and complex issue diagnosis. The team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
These resources sufficiently accommodate the needs of this TLD, and are included in ARI’s fees as described in our Financial responses.

The Applicant has engaged ARI Registry Services (ARI) to deliver services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q25 – ARI Background & Roles.pdf’. This response describes the Extensible Provisioning Protocol (EPP) interface as implemented by ARI.

1 INTRODUCTION

ARI’s EPP service is XML compliant and XML Namespace aware. The service complies with the EPP protocol defined in RFC5730, and the object mappings for domain, hosts and contacts are compliant with RFC5731-3 respectively. The transport over TCP is implemented in compliance with RFC5734. The service also complies with the official extensions to support DNSSEC, RFC5910 and Redemption Grace Period, RFC3915. ARI implemented EPP draft version 0.6 in 2002, then migrated to EPP RFC 1.0 on its publishing in 2004. The system has operated live since 2002 in the .au ccTLD.
Descriptions in this response follow the terminology used in the EPP RFCs. When referring to the software involved in the process, ARI’s EPP interface is called the server, and the software used by Registrars is called the client.

2 TRANSPORT LAYER

The ARI EPP service implements the RFC5734 – EPP Transport over TCP. Connections are allowed using TLSv1 encryption, optionally supporting SSLv2 Hello for compatibility with legacy clients. AES cipher suites for TLS as described in RFC3268 are the only ones allowed.

2.1 Authentication
Registrar access to the EPP interface is authenticated and secured with multi-factor authentication (NIST Level 3) and digital assertion as follows. Registrars must:
– present a certificate, during TLS negotiation, signed by the ARI Certificate Authority (CA). The server returns a certificate also signed by the ARI CA. Not presenting a valid certificate results in session termination. ARI requires that the Common Name in the subject field of the certificate identifies the Registrar.
– originate connections from an IP address that is known to be assigned to the Registrar with that Common Name.
– Registrar must use authentication credentials provided to the Registrar via encrypted email
– Registrars aren’t able to exceed a fixed number of concurrent connections. The connection limit is prearranged and designed to prevent abuse of Registrars’ systems from affecting the Registry. The limit is set to reasonable levels for each Registrar, but can be increased to ensure legitimate traffic is unaffected. If any of the above conditions aren’t met the connection is terminated.
All communication between the Registrars and the EPP service is encrypted using at least 128 bit encryption which been designated as ‘Acceptable’ till ‘2031 and beyond’ by NIST Special Publication 800-57.

2.3 Connection Close
The server may close the connection as a result of a logout, an error where the state of the connection is indeterminate, or after a timeout. Timeout occurs where no complete EPP message is received on the connection for 10 minutes.

3 EPP PROTOCOL

This section describes the interface relating to the EPP protocol described in RFC5730. This includes session management, poll message functionality and object mappings for domains, hosts and contacts.

3.1 Session Management
Session management refers to login and logout commands, used to authenticate and end a session with the SRS. The Login command is used to establish a session between the client and the server. This command succeeds when:
– The username supplied matches the Common Name in the digital certificate used in establishing the TLS session.
– The provided password is valid for the user.
– The user’s access to the system isn’t suspended.
The Logout command is used to end an active session. On processing a logout the server closes the underlying connection. The Hello command can be used as a session keep-alive mechanism.

3.2 Service Messages
Offline notifications pertaining to certain events are stored in a queue. The client is responsible for polling this queue for new messages and to acknowledge read messages. Messages include notification about server modification of sponsored objects, transfer operations, and balance thresholds.

4 EPP OBJECT MAPPINGS

This section covers the interface for the 3 core EPP objects; domain, host and contact objects, as per RFC5731, 5732, & 5733 respectively.

The EPP domain, contact and host object mapping describes an interface for the check, info, create, delete, renew (domain only), transfer (domain & contact only) and update commands. For domain objects the server doesn’t support the use of host attributes as described by RFC5731, but rather uses host objects as described by RFC5731 and RFC5732. Details of each command are:
– check command: checks availability of 1 or more domain, contact or host objects in the SRS. Domain names will be shown as unavailable if in use, invalid or reserved, other objects will be unavailable if in use or invalid.
– info command: retrieves the information of an object provisioned in the SRS. Full information is returned to the sponsoring client or any client that provides authorisation information for the object. Non-sponsoring clients are returned partial information (no more than is available in the WhoIs).
– create command: provisions objects in the SRS. To ascertain whether an object is available for provisioning, the same rules for the check command apply.
– delete command: begins the process of removing an object from the SRS. Domain names transition into the redemption period and any applicable grace periods are applied. Domain names within the Add Grace Period are purged immediately. All other objects are purged immediately if they are not linked.
– renew command (domain only): extends the registration period of a domain name. The renewal period must be between 1 to 10 years inclusive and the current remaining registration period, plus the amount requested in the renewal mustn’t exceed 10 years.
– transfer command (domain and contact only): provides several operations for the management of the transfer of object sponsorship between clients. Clients that provide correct authorisation information for the object can request transfers. Domain names may be rejected from transfer within 60 days of creation or last transfer. The requesting client may cancel the transfer, or the sponsoring client may reject or approve the transfer. Both the gaining and losing clients may query the status of the current pending or last completed transfer.
– update command: updates authorisation information, delegation information (domains), and registration data pertaining to an object.

5 NON-PROPRIETARY EPP MAPPINGS

ARI’s EPP service implements 2 non-proprietary EPP mappings, to support the required domain name lifecycle and to provide & manage DNSSEC information. The relevant schema documents aren’t provided as they are published as RFCs in the RFC repository.

5.1 Grace Period Mapping
The Domain Registry Grace Period Mapping for the Extensible Provisioning Protocol (as per RFC 3915) is used to support the domain name lifecycle as per existing TLDs. The update command is extended by the restore command to facilitate the restoration of previously deleted domains in the redemption period. This command defines 2 operations, request & report, described here:
– Request operation: requests the restoration of a domain.
– Report operation: completes the restoration by specifying the information supporting the restoration of the domain. The restore report must include a copy of the WhoIs information at both the time the domain was deleted & restored, including the restore reason.

5.2 DNSSEC Mapping
The Domain Name System (DNS) Security Extensions Mapping for EPP, as per RFC5910, is used to support the provisioning of DNS Security Extensions. ARI requires clients use the Key Data interface. Clients may associate a maximum of 4 keys per domain. The registry system generates the corresponding DS data using the SHA-256 digest algorithm for the domain and any active variant domains.
ARI is aware of issues DNSSEC causes when transferring DNS providers – a transfer of Registrar usually means a change in DNS provider. DNSSEC key data won’t be removed from the SRS or the DNS if a transfer occurs. It is the responsibility of and requires the cooperation of the registrant, Registrars, and DNS providers, to provide a seamless transition. ARI observes progress with this issue and implements industry agreed solutions as available. DNSSEC information is included in info responses when the secDNS namespace in login.

6 PROPRIETARY MAPPING

The registry system supports 3 additional EPP extensions where no published standard for the required functionality exists. Developed to conform to the requirements specified in RFC3735, these extensions include the provisioning of Internationalised Domain Names and domain name variants, and the association of arbitrary data with a domain name. These 3 extensions are introduced below, and further described in the attached schema documentation.

6.1 Internationalised Domain Names
ARI has developed an extension to facilitate the registration and management of Internationalised Domain Names as per RFCs 5890-5893 (collectively known as the IDNA 2008 protocol). This extension extends the domain create command and the info response.
The create command is extended to capture the language table identifier that identifies the corresponding IDN language table for the domain name. Additionally the extension requires the Unicode form to avoid an inconsistency with DNS-form, as per RFC 5891.
The domain info command is extended to identify the language tag and Unicode form provided in the initial create command. This information is disclosed to all querying clients that provided the extension namespace at login. This extension is documented in the attachment ‘Q25 – idnadomain-1.0.pdf’.

6.2 Variant
ARI has developed an extension to facilitate the management of Domain Name variants. This extension extends the domain update command and the domain create and info responses. The domain update command is extended to allow the addition (activation) and removal (de-activation) of domain name variants subject to registry operator policy.
The domain create and info responses are extended to return the list of activated domain name variants. This information is disclosed to all querying clients that provided the extension namespace at login. The extension is documented in the attachment ‘Q25 – variant-1.1.pdf’.

6.3 Key-Value
ARI has developed an extension to facilitate the transport of arbitrary data between clients and the SRS without the need for developing EPP Extensions for each specific use-case. This extension extends the domain create and domain update transform commands and the domain info query command. This extension is documented in the attachment ‘Q25 – kv-1.0.pdf’.

7 ADDITIONAL SECURITY

The registry system provides additional mechanisms to support a robust interface. The use of command rate limiting enables the registry to respond to and withstand erroneous volumes of commands, while a user permission model provides fine-grained access to the EPP interface. These 2 mechanisms are described below.

7.1 Rate Limiting
The registry system supports command and global rate limits using a token-bucket algorithm. Limits apply to each connection to ensure fair and equitable use by all. Clients that exceed limits receive a command failed response message indicating breach of the limit.

7.2 User Permission Model
The registry system supports a fine-grained permission model controlling access to each specific command. By default, clients receive access to all functionality; however it is possible to remove access to a specific command in response to abuse or threat to stability of the system. Clients that attempt a command they have lost permission to execute, receive an EPP command failed response indicating loss of authorisation.

8 COMPLIANCE

Compliance with EPP RFCs is achieved through design and quality assurance (QA). The EPP interface was designed to validate all incoming messages against the respective XML Schema syntax. The XML Schema is copied directly from the relevant RFCs to avoid any ambiguity on version used. Inbound messages that are either malformed XML or invalid are rejected with a 2400 response. Outbound messages are validated against the XML Schema, and if an invalid response is generated, it is replaced with a known valid pre-composed 2400 response, and logged for later debugging.
A QA process provides confidence that changes don’t result in regressions in the interface. Automated build processes execute test suites that ensure every facet of the EPP service (including malformed input, commands sequencing and synchronisation, and boundary values) is covered and compliant with RFCs and the EPP service specification. These tests are executed prior to committing code and automatically nightly. The final deliverable is packaged and tested again to ensure no defects were introduced in the packaging process.
New versions of the EPP Service follow a deployment schedule. The new version is deployed into an OT&E environment for Registrar integration testing. Registrars are encouraged during this stage to test their systems operate correctly. After a fixed time in OT&E without issue, new versions are scheduled for production deployment. This ensures incompatibilities with RFCs that made it through QA processes are detected in test environments prior reaching production.
ARI surveys Registrars for information about the EPP client toolkit. These surveys indicated that while many Registrars use ARI toolkits, several Registrars use either their own or that from another registry. The ability for Registrars to integrate with the ARI EPP service without using the supplied toolkit indicates the service is compliant with RFCs.
ARI is committed to providing an EPP service that integrates with third party toolkits and as such tests are conducted using said toolkits. Any issues identified during testing fall into the following categories:
– Third-party toolkit not compliant with EPP
– EPP service not compliant with EPP
– Both third-party toolkit and EPP service are compliant, however another operational issue causes an issue
Defects are raised and change management processes are followed. Change requests may also be raised to promote integration of third-party toolkits and to meet common practice.

9 CAPACITY

This TLD is projected to reach 6000 domains at its peak volume and will generate 4,2 EPP TPS. This will consume 0,03% of the EPP resources. ARI’s SRS can easily accommodate this TLD. This was described in considerable detail in the capacity section of question 24.

10 RESOURCES

This function will be performed by ARI. ARI provides a technical support team to support Registrars and also provides Registrars with a tool kit (in Java and C++) implementing the EPP protocol. Normal operations for all registry services are managed by ARI’s Production Support Group (PSG), who ensure the EPP server is available and performing appropriately.
Faults relating to connections with or functionality of the EPP server are managed by PSG. ARI monitors EPP availability and functionality as part of its monitoring practices, and ensures PSG staff are available to receive fault reports from Registrars any time. PSG has the appropriate network, Unix and application (EPP and load balancing) knowledge to ensure the EPP service remains accessible and performs as required. These ARI departments support EPP:
– Products and Consulting Team (7 staff)
– Production Support Group (27 staff)
– Development Team (11 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q25 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that existing staff are adequate to support a registry system that supports in excess of 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q25 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required, trained resources can be added to any of the above teams with a 2-month lead time.

10.1 Team Details
The products and consulting team is responsible for product management of the EPP solution, and works with clients and industry to identify required system features or changes. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
The Production Support Group (PSG) is responsible for the design, deployment and maintenance of the EPP infrastructure including capacity planning, monitoring, and security. This team ensures the EPP services are available and performing appropriately. The team consists of:
– Production Support Manager
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support):
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation:
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrator
 – 1 Network Engineer
The development team is responsible for EPP changes and features, bug fixes and issue diagnosis. The team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
These resources sufficiently accommodate the needs of this TLD, and are included in ARI’s fees as described in our financial responses.

The Applicant has engaged ARI Registry Services (ARI) to deliver services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q26 – ARI Background & Roles.pdf’. This response describes the WhoIs interface as implemented by ARI.

1 INTRODUCTION

ARI’s WhoIs service is for all domain names, contacts, nameservers and Registrars provisioned in the registry database. This response describes the port 43 and web interfaces of WhoIs, security controls to mitigate abuse, compliance with bulk access requirements for registration data, and the architecture delivering the service.

2 PORT 43 WHOIS SERVICE

WhoIs is on TCP port 43 in accordance with RFC3912. Requests are made in semi-free text format and ended by CR & LF. The server responds with a semi-free text format, terminating the response by connection close.
To support IDNs and Localised data we assume the query is encoded in UTF-8 and sends responses encoded in UTF-8. UTF-8 is backwards compatible with the ASCII charset and its use is consistent with the IETF policy on charsets as defined in BCP 18 [http:⁄⁄tools.ietf.org⁄html⁄bcp18].

2.1 Query Format
By default WhoIs searches domains. To facilitate the queries of other objects keywords must be used. Supported keywords are:
– Domain
– Host⁄Nameserver
– Contact
– Registrar
Keywords are case-insensitive. The rest of the input is the search string. Wildcard chars may be used in search strings to match zero or more chars (%), or match exactly one char(_). Wildcard chars must not be in the first 5 chars.

2.2 Response Format
The response follows a semi-structured format of object-specific data, followed by query-related meta-information, then a disclaimer.
The object-specific data is represented by key⁄value pairs, beginning with the key, followed by a colon and a space then the value terminated by an ASCII CR & LF. Where no object is found ‘No Data Found’ is returned.
The meta-information is used to identify data freshness and indicate when limits have been exceeded. It appears on one line within ‘〉〉〉’ and ‘〈〈〈’ chars.
The legal disclaimer is presented without leading comment marks wrapped at 72 chars. This format is consistent with that in the registry agreement.

2.3 Domain Data
Domain data is returned in response to a query with the keyword omitted, or with the ‘domain’ keyword. Domain queries return information on domains that are provisioned in the registry database.
The IDN domains may be specified in either the ASCII-compatible encoded form or the Unicode form. Clients are expected to perform any mappings, in conformance with relevant guidelines such as those specified in RFC5894 and UTS46.
Variant domains may be specified in the search string and WhoIs will match (using case-insensitive comparison) and return information for the primary registered domain.
For queries containing wildcard chars, if only one domain name is matched its details are returned, if more than one domain name is matched then the first 50 matched domain names are listed.

2.3.1 Internationalised Domain Names
The WhoIs response format, prescribed in Specification 4, does not provide a mechanism to identify active variant domain names. ARI will include active variant domain names in WhoIs responses until a common approach for handling and display of variant names is determined.

2.3.2 Reserved Domain Names
Domain names reserved from allocation will have a specific response that indicates the domain is not registered but also not available.

2.4 Nameserver Data
Nameserver data is returned in response to a query where the ‘nameserver’ or ‘host’ keywords have been used. Nameserver queries return information on hosts that are provisioned in the registry.
The search string for a nameserver query can be either a hostname or IP. Queries using the hostname produce one result unless wildcards are used. Queries using the IP produce one or more results depending on the number of hostnames that match that address. Queries for the hostname are matched case-insensitively.
The quad-dotted notation is expected for IPv4 and the RFC3513 – IPv6 Addressing Architecture format for IPv6. Wildcards cannot be used for IP queries.

2.5 Contact Data
Contact data is returned in response to a query where the ‘contact’ keyword was used. Contact queries return information on contacts that are provisioned in the registry.
The search string for a contact query is the contact identifier. Contact identifiers are matched using a case-insensitive comparison. Wildcards cannot be used.

2.6 Registrar Data
Registrar data is returned in response to a query where the ‘Registrar’ keyword was used. Registrar queries return information on Registrar objects that are provisioned in the registry.
The search string for a Registrar query can be name or IANA ID. Queries using the name or the IANA ID produce only one result. Queries for the name are matched using a case-insensitive comparison. Wildcards cannot be used.

2.7 Non-standard Data
The SRS supports domain-related data beyond that above. It may include information used to claim eligibility to participate in the sunrise process, or other arbitrary data collected using the Key-Value Mapping to the EPP. This information will be included in the WhoIs response after the last object-specific data field and before the meta-information.

3 WEB-BASED WHOIS SERVICE

WhoIs is also available via port 80 using HTTP, known as Web-based WhoIs. This interface provides identical query capabilities to the port 43 interface via an HTML form.

4 SECURITY CONTROLS

WhoIs has an in-built mechanism to blacklist malicious users for a specified duration. Blacklisted users are blocked by source IP address and receive a specific blacklisted notification instead of the normal WhoIs response.
Users may be blacklisted if ARI’s monitoring system determines excessive use. A whitelist is used to facilitate legitimate use by law enforcement agencies and other reputable entities.

5 BULK ACCESS

The registry system complies with the requirements for the Periodic Access to Thin Registration Data and Exceptional Access to Thick Registration Data as described in Specification 4.

5.1 Periodic Access to Thin Registration Data
ARI shall provide ICANN with Periodic Access to Thin Registration Data. The data will contain the following elements as specified by ICANN. The format of the data will be consistent with the format specified for Data Escrow. The Escrow Format prescribes an XML document encoded in UTF-8. The generated data will be verified to ensure that it is well formed and valid.
The data will be generated every Monday for transactions committed up to and on Sunday unless otherwise directed by ICANN. The generated file will be made available to ICANN using SFTP. Credentials, encryption material, and other parameters will be negotiated between ARI and ICANN using an out-of-band mechanism.

5.2 Exceptional Access to Thick Registration Data
If requested by ICANN, ARI shall provide exceptional access to thick registration data for a specified Registrar. The date will contain full information for the following objects:
– Domain names sponsored by the Registrar
– Hosts sponsored by the Registrar
– Contacts sponsored by the Registrar
– Contacts linked from domain names sponsored by the Registrar
As above the format of the data will be consistent with the format specified for Data Escrow. And will be made available to ICANN using SFTP.

6 CAPACITY

ARI’s WhoIs infrastructure is built to sustain 20M domain names. Based on ARI’s experience running a high volume ccTLD registry (.au) and industry analysis, ARI were able to calculate the conservative characteristics of a registry of this size.
Through conservative statistical analysis of the .au registry and data presented in the May 2011 ICANN reports for the .com & .net, .org, .mobi, .info, .biz and .asia [http:⁄⁄www.icann.org⁄en⁄resources⁄registries⁄reports] we know there is:
– An average of 30 SRS txs per domain, per month.
Which indicates an expected monthly transaction volume of 600M txs?
Through statistical analysis of the .au registry and backed up by the data published in the .net RFP responses [http:⁄⁄archive.icann.org⁄en⁄tlds⁄net-rfp⁄net-rfp-public-comments.htm] we also know:
– The peak daily transactions is 6% of the monthly total
– The peak 5 min is 5% of the peak day
Thus we expect a peak WhoIs tx rate of WhoIs 6,000 TPS.
For perspective on the conservativeness of this, the following numbers were taken from data in the May 2011 ICANN reports referenced above:
– .info ~7.8M domain names, peaks at ~1,300 TPS (projected peak TPS of ~3,400 with 20M names).
– .mobi ~1M domain names, peaks at ~150 TPS (projected peak TPS of ~3,000 TPS with 20M names).
– .org ~9.3M domain names, peaks at ~1,300 TPS (projected peak TPS of ~2,800 with 20M names).
ARI understand the limitations of these calculations but they serve as a best estimate of probable transaction load. ARI has built overcapacity of resources to account for limitations of this method, however as conservative numbers were used and these are greater than real world observations, we are confident these capacity numbers are sufficient.
ARI benchmarked their WhoIs infrastructure and used the results to calculate the required computing resources for each of the tiers within the WhoIs architecture – allowing ARI to accurately estimate the required CPU, IOPS, storage and memory requirements for each server within the architecture, as well as the network bandwidth and packet throughput requirements for the anticipated WhoIs traffic. These capacity numbers were then doubled to account for unanticipated traffic spikes, errors in predictions and head room for growth. The technical resource allocations are explored in question 32.
This TLD is projected to reach 6000 domains at its peak volume and will generate 1,8 WhoIs transactions per second. This will consume 0,03% of the resources of the WhoIs infrastructure. As is evident ARI’s WhoIs can easily accommodate this TLD’s growth plans. See attachment ‘Q26 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI expects to provide Registry services to 100 TLDs and a total of 12M domains by end of 2014. With all the TLDs and domains combined, ARI’s WhoIs infrastructure will be only 60% utilized. The WhoIs infrastructure capacity can also be easily scaled as described in question 32

7 ARCHITECTURE

WhoIs uses a database separate from the SRS database as it operates from the secondary site such that network and database resources are decoupled from the operation of the SRS. Oracle Data Guard ensures the two databases are synchronised in real-time. The WhoIs service is operated live from the SRS ‘failover’ site, with the SRS ‘primary’ site serving as the ‘failover’ site for the WhoIs service. Both sites have enough capacity to run both services simultaneously, however by separating them, in normal operating modes headroom above the already over provisioned capacity is available. The architecture and data flow diagrams are described below and shown in the attachment ‘Q26 – WhoIs.pdf’.
Traffic enters the network from the Internet through border routers and then firewalls. All traffic destined for this service except for TCP ports 43, 80 & 443 is blocked. Load balancers forward the request to one of the application servers running ARI built WhoIs software. Each server is connected to the database cluster through another firewall further restricting access to the. Each server uses a restricted Oracle user that has read only access to the registry data and can only access the data that is relevant to the WhoIs queries. This ensures that in the unlikely event of an application server compromise the effects are limited.
All components are configured and provisioned to provide N+1 redundancy. Multiple Internet providers with separate upstream bandwidth suppliers are used. At least one additional component of all hardware exists, enabling maintenance without downtime. This configuration provides a service exceeding the availability requirements in Specification 10.
The use of load balancing allows addition of application servers with no downtime. From a database perspective, the ability to scale is enabled by utilising Oracle RAC database clustering. The entire service, including routers, firewalls and application is IPv6 compatible and WhoIs is offered on both IPv4 and IPv6. Detail about this architecture is available in our response to Question 32.

7.1 Synchronisation
The WhoIs database is synchronised with the SRS database using Oracle Data Guard. Committed transactions in the SRS database are reflected in the WhoIs database in real-time. Should synchronisation break, WhoIs continues to operate with the latest available data until the issue is reconciled. The channel between the two sites consists of two independent dedicated point to point links as well as the Internet. Replication traffic flows via the dedicated links or if both links fail replication traffic flows over Internet tunnels.

7.2. Interconnectivity with Other Services
The WhoIs service is not directly interconnected with other registry services or systems. The software has been developed to provide the WhoIs service exclusively and retrieve response information from a database physically separate to the SRS transactional database. This database is updated as described in ‘Synchronisation’ above. Although for smaller system the WhoIs and SRS can be configured to use the same data store. The WhoIs servers log every request to a central repository that is logically separate from the WhoIs database. This repository is used for query counts, detection of data mining and statistical analysis on query trends.

7.3 IT and Infrastructure Resources
The WhoIs service is provided utilizing Cisco networking equipment, IBM servers & SAN. They are described in the attachment ‘Q26 – WhoIs.pdf’. For more information on the architecture including server specifications and database capabilities please see Questions 32 & 33.

8 COMPLIANCE

Compliance with WhoIs RFCs is achieved through design and QA. The WhoIs interface was designed to conform to the RFCs as documented and independent test cases have been developed.
QA processes provide confidence that any changes to the service don’t result in regression of the WhoIs. Automated build processes execute test suites that ensure every facet of the WhoIs service (including malformed input, commands sequencing and synchronisation, and boundary values) is covered and compliant with RFCs. These tests are executed prior to the committing of code and nightly. The final deliverable is packaged and tested again to ensure no defects were introduced in the packaging of the software.
New versions of the WhoIs follow a deployment schedule. The new version is deployed into an OT&E environment for Registrar integration testing. Registrars who rely on WhoIs functionality are encouraged during this stage to test their systems operate without change. After a fixed time in OT&E without issue, new versions are scheduled for production deployment. This ensures incompatibilities with RFCs that made it through QA processes are detected in test environments prior to reaching production.
ARI is committed to providing a WhoIs service that integrates with third party tools and as such tests are conducted using these tools such as jWhoIs, a popular UNIX command line WhoIs client. Any issues identified during integration fall into 1 of the following categories:
– Third-party tool not compliant with the WhoIs specification
– WhoIs service not compliant
– Both third-party tool and WhoIs service are compliant, however another operational issue causes a problem
Defects are raised and follow the change management. Change requests may also be raised to promote integration of third-party tools and to meet common practice.

9 RESOURCES

This function will be performed by ARI. The WhoIs system is supported by a number of ARI departments:
– Products and Consulting Team (7 staff)
– Production Support Group (27 staff)
– Development Team (11 staff)
– Legal, Abuse and Compliance Team (6 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q26 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q26 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
The products and consulting team is responsible for product management of the WhoIs solution including working with clients and the industry to identify new features or changes required to the system. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
ARI employ a development team responsible for the maintenance and continual improvement of the WhoIs software. The team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
ARI’s Production Support Team ensures the successful operation of the WhoIs system. The team comprises Database Administrators, Systems Administrators and Network Administrators. This team routinely checks and monitors bandwidth, disk and CPU usages to plan and respond to expected increases in the volume of queries, and perform maintenance of the system including security patches and failover and recovery testing. The team consists of:
– Production Support Manager
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support)
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrators
 – 1 Network Engineers
ARI’s registry provides abuse monitoring detection mechanisms to block data mining. ARI support staff may be contacted to remove blacklisted users during which they may be referred to the Legal, Abuse and Compliance Team for evaluation of their activities. Additionally the support team in conjunction with the Legal, Abuse and Compliance team administer requests for listing on the whitelist. The team consists of:
– 1 Legal Manager
– 1 Legal Counsel
– 4 Policy Compliance Officers
These resources sufficiently accommodate the needs of this TLD, and are included in ARI’s fees as described in our Financial responses.

The Applicant has engaged ARI to deliver services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q27 – ARI Background & Roles.pdf’. This response describes the Registration Lifecycle as implemented by ARI.

1 INTRODUCTION

The lifecycle described matches current gTLD registries. All states, grace periods and transitions are supported by the EPP protocol as described in RFC5730 – 5734 & the Grace Period Mapping published in RFC3915. An overview is in attachment ‘Q27 – Registration Lifecycle.pdf’.

2 REGISTRATION PERIODS

The registry supports registration up to 10 years and renewals for 1 to 10 years. The total current validity period can’t exceed 10 years.
Transfers under part A of the ICANN Policy on Transfer of Registrations between Registrars (Adopted 7 November 2008) extend registration by 1 year. The period truncates to 10 years if required.

3 STATES

The states that a domain can exist in are: Registered, Pending Transfer, Redemption, Pending Restore & Pending Delete.
All domain name statuses (RFC3915, 5730-5734 and 5910) are covered below

3.1 Registered
EPP Status: ok
In DNS: Yes
Allowed Operations: Update, Renew, Transfer (request) & Delete
The default state of a domain – no pending operations. The sponsoring Registrar may update the domain.

3.2 Pending Transfer
EPP Status: pendingTransfer
In DNS: Yes
Allowed Operations: Transfer (cancel, reject, approve)
Another Registrar has requested transfer of the domain and it is not yet completed All transform operations, other than those to cancel, reject, or approve the transfer are rejected.

3.3 Redemption
EPP Status: pendingDelete
RGP Status: redemptionPeriod
In DNS: No
Allowed Operations: Restore (request)
Domain has been deleted. The sponsor may request restoration of the domain. The domain continues to be withheld from the DNS unless it is restored. No transform operations other than restore are allowed.

3.4 Pending Restore
EPP Status: pendingDelete
RGP Status: pendingRestore
In DNS: Yes
Allowed Operations: Restore (report)
A restore request is pending. The sponsor must submit a restore report. The domain is provisioned the DNS. No transform operations other than the restore report are allowed.

3.5 Pending Delete
EPP Status: pendingDelete
RGP Status: pendingDelete
In DNS: No
Allowed Operations: None
The Redemption Grace Period has lapsed and the domain is pending purge from the registry. This state prohibits the sponsor from updating, restoring or modifying the domain. This status applies for 5 days. At the end of this period the domain is purged from the database and made available for registration.

4 GRACE PERIODS

The registry system supports 4 grace periods: add, renew, auto-renew, and transfer, described below with consideration for overlap of grace periods. States described here are additional to those above.

4.1 Add Grace Period
Length: 5 days
RGP Status: addPeriod
Allows for the no-cost cancellation of a domain registrations resulting from typing mistakes and other errors by Registrars and registrants – beginning on the creation of a domain and lasting for 5 days. When the following operations are performed during this period these rules apply:
– Delete: the sponsoring Registrar, who must have created the domain, may delete the domain and receive a refund. The domain is deleted with immediate effect. The refund is subject to the Add Grace Period Limits consensus policy. Excess deletions over 50 or 10% of creates (whichever is greater), are not subject to a refund, except in extraordinary circumstances.
– Renew: the sponsor may renew the domain but does not receive any refund for the initial registration fee. The Registrar is charged for the renewal operation. The total period for the domain is the sum of the initial period in the create and any renewal term, limited to a 10 year maximum.
– Transfer: Under ICANN policy a transfer can’t occur during the Add Grace Period or at any other time in the first 60 days after the initial registration. The registry system enforces this, rejecting such requests.
– Bulk Transfers: Under Part B of the ICANN Policy on Transfer of Registrations between Registrars, a bulk transfer can occur during the Add Grace Period. Any bulk transfer causes the Add Grace Period to not apply.
The Add Grace Period does not have any impact on other commands.

4.2 Renew Grace Period
Length: 5 days
RGP Status: renewPeriod
Allows the sponsoring Registrar to undo a renewal via the deletion of a domain – beginning on the receipt of a renewal command and lasting for 5 days. If any of the following operations are performed during this period these rules apply:
– Delete: the sponsoring Registrar, who must have initiated the renewal, may delete the domain and receive a renewal fee refund. The extension to the registration period caused by the preceding renew is reversed and unless the domain is also in the Add Grace Period, the domain enters the Redemption state. If also in the Add Grace Period it is deleted with immediate effect and availability for registration.
– Renew: the sponsoring Registrar, who must have performed the initial renew, can subsequently renew the domain again, causing a second independent Renewal Grace Period to start. The Registrar is charged for the operation and the total registration period for the domain is extended by the renewal term, limited to the 10 year maximum.
– Transfer: an approved transfer command ends the current Renew Grace Period without a refund and begins a Transfer Grace Period.
– Bulk Transfers: bulk transfers cause the Renew Grace Period to end without a refund, consequently registration periods are not changed.
The Renew Grace Period has no impact on other commands.

4.3 Auto-Renew Grace Period
Length: 45 days
RGP Status: autoRenewPeriod
Auto-Renew Grace Period allows for domains to remain in the DNS past registration expiration while giving adequate time for the sponsoring Registrar to obtain intention of renewal from the registrant.
This period begins on the expiration of the domain and lasts for 45 days. If any of the following are performed during this period these rules apply:
– Delete: the sponsoring Registrar, who must be the sponsor when the Auto-Renew Grace Period commenced, may delete the domain and receive an auto-renew fee refund. The registration period auto-renew extension is reversed and the domain enters the Redemption state.
– Renew: the sponsoring Registrar, who must be the sponsor when the auto-renew occurred, can renew the domain again causing an independent Renewal Grace Period to begin. The Registrar is charged and the registration period is extended by the renewal term, limited to the 10 year maximum.
– Transfer: an approved transfer command ends the current Auto-Renew Grace Period with a refund to the losing Registrar and begins a Transfer Grace Period. The registration period auto-renew extension is reversed and the registration is extended by the period specified in the transfer.
– Bulk Transfers: bulk transfers cause the Auto-Renew Grace Period to end without a refund consequently registration periods are not changed.
The Auto-Renew Grace Period does not have any impact on other commands.

4.4 Transfer Grace Period
Length: 5 days
RGP Status: transferPeriod
Transfer Grace Period allows the sponsoring Registrar to undo the registration period extension (due to a transfer command), via the deletion of a domain. This period begins on a transfer completion and lasts for 5 calendar days. If the following are performed during the period these rules apply:
– Delete: the sponsoring Registrar, who must have initiated the transfer, may delete the domain and receive a transfer fee refund. The extension to the registration period of the preceding transfer is reversed and the Redemption state is entered.
– Renew: the sponsoring Registrar can renew the domain thus causing an independent Renewal Grace Period to begin. The Registrar is charged and the registration period for the domain is extended by the renewal term, limited to the 10 year maximum.
– Transfer: under Part A of the ICANN Policy on Transfer of Registrations between Registrars a transfer may not occur during the 60 day period after transfer (except in special circumstances). The registry system enforces this – effects of transfer do not require consideration. Should a special situation require transfer back to the losing Registrar, this is dealt with by taking into account the specific situation. The registry system does not allow this without intervention by registry staff.
– Bulk Transfers: bulk transfers cause the Transfer Grace Period to end without a refund; consequently registration periods are not changed.
The Transfer Grace Period does not have any impact on other commands.

4.5 Redemption Grace Period
Length: 30 days
RGP Status: as described in Redemption state
Redemption Grace Period refers to the period of time the domain spends in the Redemption state, starting after a domain is deleted. The Redemption state description provides information on operations during this period.

4.6 Overlap of Grace Periods
The 4 possible overlapping grace periods are:
– Add Grace Period with 1 or more Renew Grace Periods.
– Renew Grace Period with 1 or more other Renew Grace Periods.
– Transfer Grace Period with 1 or more Renew Grace Periods.
– Auto-Renew Grace Period with 1 or more Renew Grace Periods.
These are treated independently with respect to timelines however action that is taken has the combined effects of all grace periods still current.

4.6.1 Transfer Clarification
If several billable operations, including a transfer, are performed on a domain and it is deleted in the operations’ grace periods, only those operations performed after⁄including the latest transfer are eligible for refund.

5 TRANSITIONS

5.1 Available 〉 Registered
Triggered by the receipt of a create command to register the domain. The sponsoring Registrar is charged for the creation amount. This transition begins the Add Grace Period.

5.2 Registered 〉 Pending Transfer
Triggered by the receipt of a request transfer command. The transfer must result in domain registration extension – the gaining Registrar is charged for the transfer. Requests to transfer the domain within 60 days of creation or a previous transfer are rejected. As per ‘4.4 Transfer Grace Period’, exceptions specified in ICANN’s Transfer Policy apply – dealt with individually.

5.3 Pending Transfer 〉 Registered
Triggered by 1 of 4 operations:
– Operation 1 (Cancel): during the Pending Transfer period the gaining Registrar may cancel the transfer by issuing a cancel transfer command. The gaining Registrar is refunded the transfer fee, the registration period remains unchanged and all existing grace periods at the time of transfer request remain in effect.
– Operation 2 (Reject): during the Pending Transfer period the losing Registrar may reject the transfer by issuing a reject transfer command. The gaining Registrar is refunded the transfer. The registration period remains unchanged and all grace periods existing at the time of transfer request remain in effect if not elapsed.
– Operation 3 (Approve): During the Pending Transfer period the losing Registrar may approve the transfer by issuing an approve transfer command. If the transfer was requested during the Auto-Renew Grace Period, the extension to the registration period is reversed and the losing Registrar is refunded the auto-renew. The registration period is extended by the amount specified in the transfer request. This begins the Transfer Grace Period.
– Operation 4 (Auto-Approve): If after 5 days, no action has been taken, the system approves the transfer. If the transfer was requested during the Auto-Renew Grace Period the extension to the registration period is reversed and the losing Registrar is refunded the auto-renew. The registration period is extended by the amount specified in the transfer request. This begins the Transfer Grace Period.

5.4 Registered 〉 Deleted
On receipt of a delete command if the domain is in the Add Grace Period, it is purged from the Database and immediately available for registration. Renew Grace Period may also be in effect.

5.5 Registered 〉 Redemption
On receipt of a delete command if the domain is not in the Add Grace Period, it transitions to the Redemption Period state and all grace periods in effect are considered.

5.6 Redemption 〉 Pending Restore
On receipt of a restore command if the Redemption Period has not lapsed, the domain transitions to the Pending Restore state. The domain is provisioned in the DNS. The sponsoring Registrar is charged a fee for the restore request.

5.7 Pending Restore 〉 Registered
During the Pending Restore period the sponsoring Registrar may complete the restore via a restore report containing the WhoIs information – submitted prior to the deletion, the WhoIs information at the time of the report, and the reason for the restoration.

5.8 Pending Restore 〉 Redemption
Seven calendar days after the transition to the Pending Restore state, if no restore report is received the domain transitions to the Redemption state, which begins a new redemption period. The domain is removed from the DNS. The restore has no refund.

5.9 Redemption 〉 Pending Delete
Thirty calendar days after the transition to the Redemption state, if no restore request is received the domain transitions to the Pending Delete state.

5.10 Pending Delete 〉 Deleted
Five calendar days after the transition to the Pending Delete state, the domain is removed from the Database and is immediately available for registration.

6 LOCKS

Locks may be applied to the domain to prevent specific operations occurring. The sponsoring Registrar may set the locks prefixed with ‘client’ while locks prefixed with ‘server’ are added and removed by the registry operator. Locks are added and removed independently but they can be combined to facilitate the enforcement of higher processes, such as ‘Registrar Lock’, and outcomes required as part of UDRP. All locks are compatible with EPP RFCs. The available locks are:
– clientDeleteProhibited, serverDeleteProhibited – Requests to delete the object are rejected
– clientHold, serverHold – DNS information is not published
– clientRenewProhibited, serverRenewProhibited – Requests to renew the object are rejected. Auto-renew is allowed
– clientTransferProhibited, serverTransferProhibited – Requests to transfer the object are rejected
– clientUpdateProhibited, serverUpdateProhibited – Requests to update the object are rejected, unless the update removes this status

7 SPECIAL CONSIDERATIONS

7.1 ICANN-Approved Bulk Transfers
ICANN-Approved Bulk Transfers do not follow the typical transfer lifecycle. Existing grace periods are invalidated and no refunds are credited to the losing Registrar. The prohibition of transfer period on domains created or transferred within 60 days does not apply.

7.2 Uniform Rapid Suspension
In the Uniform Rapid Suspension (URS) process, as described in the ‘gTLD Applicant Guidebook’ 11th January 2012, the following modification to the above processes is required.
Remedy allows for the addition of a year to the registration period, limited to the 10 year maximum. During this time no transform operations may be performed other than to restore the domain as allowed by Appeal. At the expiration of the registration period the domain is not automatically renewed, but proceeds to the Redemption state as per the lifecycle described above, and it is not eligible for restoration.

8 UPDATE⁄DNS

The update command does not impact the state of the domain through the Registration Lifecycle, however the command can be used to add and remove delegation information, which changes the DNS state of the domain.
A domain is required to have 2 or more nameservers published in the DNS. An update that results in a domain having less than 2 nameservers removes the domain from the DNS. An exception is when 1 nameserver remains assigned to a domain due to deletion of its other nameservers due to purge of their parent domain. The next update that modifies delegation information ends the exception and from then on the domain requires 2 nameservers be in the DNS.

9 RESOURCES

This function will be performed by ARI. ARI’s registry performs all time-based transitions automatically and enforces all other business rules – without requiring human resources for normal operation. If changes to the automatic behaviours or restrictions enforced by the policy system are required, ARI has a development team for this.
Domain Name Lifecycle aspects requiring human resources to manage are included in the ARI outsourcing include:
– Processing Add Grace Period exemptions as requested by Registrars.
– Processing restore reports provided by Registrars.
– Meeting the registry operator’s obligations under ICANN’s Transfer Dispute Policy.
– Performing exception processing in the case of approved transfers during the 60 day transfer prohibition window.
The Registration Lifecycle is designed, built, operated and supported by these ARI departments:
– Products and Consulting Team (7 staff)
– Legal, Abuse and Compliance Team (6 staff)
– Development Team (11 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q27 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q27 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
The Products and Consulting team is responsible for product management of the Registration Lifecycle, including working with clients and the industry to identify new features or changes required to the system. The team consists of:
– 1 Products and Consulting Manager
– 1 Product Manager
– 1 Technical Product Manager
– 4 Domain Name Industry Consultants
Most manual tasks fall to the Legal, Abuse and Compliance team, with staff experienced in development of policy for policy rich TLD environments. They have the required legal and industry background to perform this function. The team consists of:
– 1 Legal Manager
– 1 Legal Counsel
– 4 Policy Compliance Officers
The automated aspects of the Registration lifecycle are supported by ARI’s Domain Name Registry software. ARI has a development team for maintenance and improvement of the software. The team consist of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts
Information on these roles is in Resources in our response to Question 31. These resources sufficiently accommodate the needs of this TLD, and are included in ARI’s fees as described in our Financial responses.

The Applicant has engaged ARI Registry Services (ARI) to provide registry services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q28 – ARI Background & Roles.pdf’.

This response describes the efforts that will be undertaken in this TLD by the registry operator and ARI to minimise abusive registrations and other activities that have a negative impact on Internet users.

1 INTRODUCTION

The efforts that will be undertaken in this TLD to minimise abusive registrations and other activities that have a negative impact on Internet users are described below. This includes a discussion of the registry operator’s internal processes as well as aspects of the ARI Managed Registry Service as this relates to abuse prevention and mitigation.
We intend to request an exemption from clause 1b of the Registry Operator Code of Conduct (Specification 9) pursuant to clause 6 of the Code of Conduct to enable us to register domain names in our own right in this TLD. Registrations will not be made commercially available; all domain name registrations in the TLD will be registered to and maintained by us in our capacity as the registry operator, for our own exclusive use. We will not sell, distribute or transfer control or use of any registration in the TLD to any third party that is not our Affiliate.
For clarification and to reflect the unique roles of the stakeholders in our TLD, the following terms, where used in this response, have the following meaning:
“Registry operator” means the entity submitting an application to ICANN for the operation and management of a TLD. All references to “us”, “we” or “our” are to be taken as references to the registry operator.
“Affiliate” means, as defined in Clause 2.9(c) of the Registry Agreement, “a person or entity that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with, the person or entity specified, and (ii) ‘control’ (including the terms ‘controlled by’ and ‘under common control with’) means the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of a person or entity, whether through the ownership of securities, as trustee or executor, by serving as an employee or a member of a board of directors or equivalent governing body, by contract, by credit arrangement or otherwise.”
“Registrant” means the registered holder of a domain name, in this case the Registry Operator, consistent with the eligibility restrictions in our TLD as described in our response to Question 18.
Our comprehensive Acceptable Registration and Use Policy, developed in consultation with ARI, clearly defines abusive behaviour, identifies particular types of abusive behaviour and the mitigation response that ARI will initiate when abusive behaviour is determined. ARI will, owing to their extensive industry experience and established anti-abuse operations, implement and manage on our behalf various procedures and measures adopted through this policy. This robust policy and procedure framework, which will be continually improved, updated and rigidly enforced, will preclude abusive registrations from being made.
Despite utilisation of ARI’s anti-abuse service we are nonetheless cognisant of our responsibility to minimise abusive registrations and other activities that have a negative impact on Internet users in our TLD. In recognition of this responsibility, we will play an instrumental role in overseeing the implementation of the anti-abuse service by ARI. As well as having contractual commitments in the form of SLA’s in place to ensure that ARI’s delivery of the anti-abuse service is aligned with our strong commitment to minimise abuse in our TLD.
That strong commitment is further demonstrated by our adoption of many of the requirements proposed in the ‘2011 Proposed Security, Stability and Resiliency Requirements for Financial TLDs’ (at http:⁄⁄www.icann.org⁄en⁄news⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf) (the ‘BITS Requirements). We acknowledge that these requirements were developed by the financial services sector in relation to financial TLDs, but nevertheless believe that their adoption in this TLD (which is not financial-related) results in a more robust approach to combating abuse. 
Consistent with Requirement 6 of the BITS Requirements, we will certify to ICANN on an annual basis our compliance with our Registry Agreement.
Please note that the various policies and practices that we will implement to minimise abusive registrations and other activities that affect the rights of trademark holders, are specifically described in the response to Question 29.

2 ACCEPTABLE REGISTRATION AND USE POLICY

In consultation with ARI we have developed a comprehensive Acceptable Registration and Use Policy, which is the main instrument that captures our strategy in relation to identifying and handling abuse in our TLD. This is consistent with Requirements 3 and 4 of the BITS Requirements. Because, at least initially, all domain names will be registered to and maintained by the Applicant or its afiliates in the capacity as registry operator, the Acceptable Registration and Use Policy applies solely to the Applicant. However, the mitigation response described in the policy will be implemented by ARI. Any breach of the Acceptable Registration and Use Policy by an employee will be considered as a breach of the relevant employee’s employment conditions. Any breach by an Affiliate will be handled in accordance with the Acceptable Registration and Use Policy. The mitigation of any such breach, as described by the policy, will be implemented by ARI.

2.1 Definition of Abuse
Defining abusive behaviour by reference to the stage in the domain name lifecycle in which the behaviour occurs presents difficulty because a particular type of abuse may occur at various stages of the life cycle.
With this in mind, we have fully adopted the definition of abuse developed by the Registration Abuse Policies Working Group (Registration Abuse Policies Working Group Final Report 2010, at http:⁄⁄gnso.icann.org⁄issues⁄rap⁄rap-wg-final-report-29may10-en.pdf), which does not focus on any particular stage in the domain name life cycle.
Abusive behaviour in a TLD may be defined as an action that:
– Causes actual and substantial harm, or is a material predicate of such harm; or
– Is illegal or illegitimate, or is otherwise considered contrary to the intention and design of the mission⁄purpose of the TLD.
In applying this definition the following must be noted:
(1) The party or parties harmed, and the severity and immediacy of the abuse, should be identified in relation to the specific alleged abuse.
(2) The term ʺharmʺ is not intended to shield a party from fair market competition.
(3) A predicate is a related action or enabler. There must be a clear link between the predicate and the abuse, and justification enough to address the abuse by addressing the predicate (enabling action).
For example, WhoIs data can be used in ways that cause harm to domain name registrants, intellectual property (IP) rights holders and Internet users. Harmful actions may include the generation of spam, the abuse of personal data, IP infringement, loss of reputation or identity theft, loss of data, phishing and other cybercrime-related exploits, harassment, stalking, or other activity with negative personal or economic consequences. Examples of predicates to these harmful actions are automated email harvesting, domain name registration by proxy⁄privacy services to aid wrongful activity, support of false or misleading registrant data, and the use of WhoIs data to develop large email lists for commercial purposes. The misuse of WhoIs data is therefore considered abusive because it is contrary to the intention and design of the stated legitimate purpose of WhoIs data.
It should be noted that this definition of abuse serves to inform us and clarify certain behaviours, specific to domain names that may cause harm. However malicious conduct of any kind relating to the use of IT resources, which includes the TLD, is strictly against company policy and does not rely on the wording contained herein. Put simply, an abusive or malicious act is against our organisation’s documented standard of acceptable behaviour and will be dealt with technically within the registry and directly with any employee or Affiliate.

2.2 Aims and Overview of the Acceptable Registration and Use Policy
Our Acceptable Registration and Use Policy will put those registering and using domain names on notice of the ways in which abuse will be identified and responded to, and serve as a deterrent to those seeking to register and use domain names for abusive purposes.
Consistent with Requirements 15 and 16 of the BITS Requirements, our policy:
– Defines abusive behaviour in our TLD.
– Identifies types of actions that constitute abusive behaviour consistent with our adoption of the RAPWG definition of “abuse”.
– Classifies abusive behaviours based on the severity and immediacy of the harm caused.
– Identifies how abusive behaviour can be notified to ARI and the steps that ARI will take to determine whether the notified behaviour is abusive.
– Identifies the actions that may be taken in response to behaviour determined to be abusive.
The planned single registrant⁄single user model of this TLD will enable a close working relationship between registry operator and Registrar and full Registrar awareness of and compliance with our Acceptable Registration and Use Policy. This will be contractually enforceable through our RRA, which will oblige all Registrars to comply with the Acceptable Registration and Use Policy. Our RRA will additionally incorporate the following proposed BITS Requirements:
– Requirement 7: Registrars must certify annually to ICANN and us compliance with ICANN’s Registrar Accreditation Agreement (RAA) our Registry-Registrar Agreement (RRA).
– Requirement 9: Registrars must provide and maintain valid primary contact information (name, email address, and phone number) on their website.
– Requirement 14: Registrars must notify us immediately regarding any investigation or compliance action, including the nature of the investigation or compliance action by ICANN or any outside party (eg law enforcement, etc.) along with the TLD impacted.
We will re-validate our RRA at least annually, consistent with Requirement 10.

2.3 Acceptable Registration and Use Policy
Our Acceptable Registration and Use Policy is as follows:

Acceptable Registration and Use Policy

Introduction:
The abusive registration and use of domain names in the TLD is not tolerated given that the inherent nature of such abuses creates security and stability issues for all participants in the Internet environment.

Definition of Abusive Behaviour:
Abusive behaviour is an action that:
– Causes actual and substantial harm, or is a material predicate of such harm; or
– Is illegal or illegitimate, or is otherwise considered contrary to the intention and design of the mission⁄purpose of the TLD.
A ‘predicate’ is an action or enabler of a harm.
‘Material’ means that something is consequential or significant.

Examples of abusive behaviour falling within this definition:
– Spam: the use of electronic messaging systems to send unsolicited bulk messages. The term applies to email spam and similar abuses such as instant messaging spam, mobile messaging spam, and the spamming of web sites and Internet forums. An example, for purposes of illustration, would be the use of email in denial-of-service attacks.
– Phishing: the use of a fraudulently presented web site to deceive Internet users into divulging sensitive information such as usernames, passwords or financial data.
– Pharming: the redirecting of unknowing users to fraudulent websites or services, typically through DNS hijacking or poisoning, in order to deceive Internet users into divulging sensitive information such as usernames, passwords or financial data.
– Wilful distribution of malware: the dissemination of software designed to infiltrate or cause damage to devices or to collect confidential data from users without the owner’s informed consent.
– Fast Flux hosting: the use of DNS to frequently change the location on the Internet to which the domain name of an Internet host or nameserver resolves in order to disguise the location of web sites or other Internet services, or to avoid detection and mitigation efforts, or to host illegal activities. Fast flux hosting may only be used with prior permission of the registry operator.
– Botnet command and control: the development and use of a command, agent, motor, service or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
– Distribution of pornography: the storage, publication, display and⁄or dissemination of pornographic materials.
– Illegal access to other computers or networks: the illegal accessing of computers, accounts, or networks belonging to another party, or attempt to penetrate security measures of another individual’s system (hacking). Also, any activity that might be used as a precursor to an attempted system penetration.

Detection of Abusive Behaviour:
Although we do not anticipate abusive behaviour in the TLD, it may be detected in the following ways:
– By the designated person with the Applicant through ongoing monitoring of all domain name transactions.
– By ARI through their on-going monitoring activities and industry participation.
– By third parties (general public, law enforcement, government agencies, industry partners) through notification submitted to the abuse point of contact on our website or industry alerts.
Reports of abusive behaviour will be notified immediately to the Registrar of record.

Handling of Abusive Behaviour:
When ARI detects or receives notification of abusive behaviour by the registry operator or a third party, a preliminary assessment will be performed to determine whether the notification is legitimately made. Applying the definitions of types of abusive behaviours identified in this policy, ARI will classify each incidence of legitimately reported abuse into one of two categories based on the probable severity and immediacy of harm to registrants and Internet users. These categories are provided below and are defined by reference to the action that may be taken by ARI. The examples of types of abusive behaviour falling within each category are illustrative only.

Category 1:
Probable Severity or Immediacy of Harm: Low
Examples of types of abusive behaviour: Spam, Malware
Mitigation steps:
1. Investigate
2. Notify registrant

Category 2:
Probable Severity or Immediacy of Harm: Medium to High
Examples of types of abusive behaviour: Fast Flux Hosting, Phishing, Illegal Access to other Computers or Networks, Pharming, Botnet command and control
Mitigation steps:
1. Suspend domain name
2. Investigate
3. Restore or terminate domain name
In the event that we receive specific instructions regarding a domain name from a law enforcement agency, government or quasi-governmental agency utilising the expedited process for such agencies, our mitigation steps will be in accordance with those instructions provided that they do not result in the contravention of applicable law. In addition, we will take all reasonable efforts to notify law enforcement agencies of abusive behaviour in our TLD which we believe may constitute evidence of a commission of a crime, eg, distribution of child pornography.
Note that these expected actions are intended to provide a guide to our response to abusive behaviour rather than any guarantee that a particular action will be taken.
The identification of abusive behaviour in the TLD, as defined above, shall give us the right, but not the obligation, to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status or instruct Registrars to take such an action as we deem necessary, in our discretion to:
1. Protect the integrity and stability of the registry.
2. Comply with any applicable laws, government rules or requirements, requests of law enforcement, or dispute resolution process.
3. Avoid any liability, civil or criminal, on the part of the registry operator, as well as its Affiliates, subsidiaries, officers, directors, and employees.
4. Correct mistakes made by the registry operator or any Registrar in connection with a domain name registration.
We reserve the right to place upon Registry Lock, Hold or similar status a domain name during resolution of a dispute. We may amend or otherwise modify this policy to keep abreast of changes in consensus policy or new and emerging types of abusive behaviour in the Internet.

3 ABUSE PREVENTION AND MITIGATION BY THE REGISTRY OPERATOR

This section of the response describes abuse related processes implemented by the registry operator regarding:
– Building awareness of the Acceptable Registration and Use Policy
– Mitigating the potential for abusive behaviour
– Identifying abusive behaviour
Due to the complete control of all registrations made in the TLD that is provided by an exemption to clause 1b of the Registry Operator Code of Conduct, these processes are anticipated to will form the bulk of our efforts to minimise abusive registrations, as they function to control the behaviour of those in a position to engage in such behaviour.

3.1 Awareness of the Acceptable Registration and Use Policy
As mentioned above, the Acceptable Registration and Use Policy will govern the manner in which domain names may be used. Efforts will be undertaken to ensure that all those registering in and using this TLD within the registry operator’s organisation are made aware of the Acceptable Registration and Use Policy. Awareness will be generated by requiring relevant employees and Affiliates of the registry operator to attend compulsory information sessions which describe the Acceptable Registration and Use Policy and the ramifications of breaching the policy. Following the attendance of the information session, all attendees will be required to execute documentation which states that the employee or Affiliate has read, acknowledged and understood the policy. The Acceptable Registration and Use Policy will be published on the registry operator’s intranet as well as on the abuse page of our registry website, which will be accessible and have clear links from the home page.
It is anticipated that these efforts will place all employees and Affiliates on notice of the applicability of the Acceptable Registration and Use Policy to all domains in the TLD and furthermore emphasise and evidence our commitment to combating abusive registrations by clearly identifying what our policy on abuse is and what effect our implementation of the policy may have on those registering and using domain names. We anticipate that the clear message, which communicates our commitment to combating abusive registrations, will serve to minimise abusive registrations in our TLD.

3.2 Pre-emptive – Mitigating the Potential for Abuse
The following practices and procedures will be adopted by the registry operator to mitigate the potential for abusive behaviour in the TLD.

3.2.1 Mitigating the Potential for Abusive Registrations that Affect the Legal Rights of Others
Many of the examples of abusive behaviour identified in our Acceptable Registration and Use Policy may affect the rights of trademark holders. While our Acceptable Registration and Use Policy addresses abusive behaviour in a general sense, we have additionally developed specific policies and procedures to combat behaviours that affect the rights of trademark holders at start-up and on an ongoing basis. These include the implementation of a trademark claims service and a sunrise registration service at start-up and implementation of the UDRP, URS and PDDRP on an ongoing basis. Additionally, our registration policy will involve internal procedures to identify and address potential conflicts with others’ trademarks before such names are registered. The implementation of these policies and procedures serves to mitigate the potential for abuse in the TLD by ensuring that domain names are allocated to those who hold a corresponding trademark. These policies and procedures are described in detail in our response to Question 29.

3.2.2 Increasing Security Awareness
In accordance with our commitment to operating a secure and reliable TLD, we will attempt to improve awareness amongst those registering and using domain names of the threats of domain name hijacking, registrant impersonation and fraud, and emphasise the need to keep registration information accurate. Awareness will be raised by:
– Conducting biannual information sessions describing new and emerging threats and manners in which they may be mitigated.
– Publishing relevant information on our intranet in the form of videos, presentations and FAQ’s.
– Developing and providing to those registering and using domains in this TLD Best Common Practices that describe appropriate use and assignment of domain auth Info codes and risks of misuse when the uniqueness property of these codes are not preserved.
The increase in awareness renders us, as the only eligible registrant in the TLD, less susceptible to attacks on our domain names owing to the adoption of the recommended best practices that mitigate the potential for abuse in the TLD.

3.2.3 Registry Operator’s Internal Processes that Mitigate the Potential for Abuse
Eligibility, naming and use restrictions will be imposed in this TLD, consistent with proposed Requirements 1, 3 and 4 of the BITS Requirements, and enforced through internal processes that require approvals within established reporting lines and the use of username and password to verify eligibility to register domain names. As described in detail in our response to Question 18, we will be the only eligible registrant in this TLD. 
This arrangement grants us a high degree of control and facilitates the implementation of measures to minimise abuse by significantly decreasing the number of individuals capable of registering and using a domain name and thus having the potential to engage in abusive behaviour. This is in contrast to the inherent decrease in control associated with granting multiple and varied individuals the capability to register and use domain names as demonstrated by many existing TLDs. Our planned single registrant⁄single user operating model precludes the abusive registration and use of domains in this TLD by unauthorised individuals not within our organisation, whilst also providing no incentive for those within our organisation to engage in abusive behaviour given that our brand is inherently intertwined with all uses of domains in this TLD. 
Internal processes regarding the registration and use of domains in this TLD are aimed at maintaining the integrity of this arrangement by ensuring that the registration and use of domains in this TLD is restricted to authorised individuals whose use complies with the Acceptable Registration and Use Policy. These internal processes, which include safeguards against allowing for unqualified registration and use of domains in this TLD, are described below.
The primary safeguard against allowing for registrations in violation of eligibility restrictions is the technical incapability of those not authorised by the registry operator to register domain names in the TLD. We will initially only authorise the designated people from the Applicant’s organization to be the Administrative Contact and the Domain Administrator to be the Technical Contact for all domains in this TLD. The registry operator will provide and keep current the contact details of the designated person with the Applicant and the Domain Administrator to the Registrar, who will grant these individuals access to an authenticated web portal to register and manage domain names in the TLD. Individual credentials for accessing this portal will be provided to the Designated person with the Applicant and the Domain Administrator by the Registrar via alternative sources. In the event that these credentials are compromised, direct communication with the account manager on the Registrar’s end is available. Various security measures will be implemented to ensure that only those personnel authorised to register and update domain names have access to the web portal. These measures are further described in our response to Question 30.
We will review the level of access that personnel have to the web portal, ensuring account permissions are relevant to the employee’s role as well as removing permissions of an employee promptly upon termination of employment. All domain name registrations will require the approval of the Designated person with the Applicant who will ensure that the Domain Administrator is authorised to create the domain name. In addition, the Designated person with the Applicant will perform a monthly audit of all domain name transactions to verify that all transactions and the use of domains complies with the Acceptable Registration and Use Policy.
This arrangement effectively mitigates the potential for abuse by restricting the capability to register domain names to a small number of trusted and authorised employees under our direct control and establishing various internal controls to that effect.

3.2.4 Promoting WhoIs Accuracy
Inaccurate WhoIs information significantly hampers the ability to enforce policies in relation to abuse in the TLD by allowing the registrant to remain anonymous. In addition, LEAs rely on the integrity and accuracy of WhoIs information in their investigative processes to identify and locate wrongdoers. Restricting the ability to register domain names in this TLD to the Designated person with the Applicant and the Domain Administrator means that a domain’s contacts are well known and accessible by clear and reliable contact details. These employees will be continually made aware of their responsibility to provide and maintain accurate WhoIs information and the potential ramifications of a failure to do so, including termination of their employment. There can only be two parties responsible for abusive registrations, thus identifying them will require little effort from LEA and the ARI Abuse and Compliance Team. ARI will maintain correspondence with multiple points of contact within the registry operator’s organisation including but not limited to the Designated person with the Applicant, Domain Administrator and Legal Counsel in order to ensure that all relevant stakeholders are keep abreast of important issues as they occur. Published WhoIs information will thus accurately reflect the identity and contact information of the individual who created the domain name in the name of the registry operator.
In addition, the Designated person with the Applicant will perform a monthly audit of all domain names registered in the TLD to ensure that WhoIs information is complete and accurate. 

3.2.5 Prompt Notification following Mitigation of Abuse
Our contractual arrangement with ARI dictates that in the unlikely event that a domain name is suspended or cancelled due to the implementation of the Acceptable Registration and Use Policy, ARI will promptly notify us. This notification will allow us to amend internal processes to prevent such behaviour from re-occurring. This notification mitigates the potential for abuse by ensuring that we are responsive to internal breaches of the Acceptable Registration and Use Policy whilst simultaneously putting employees on notice of the ramifications of breach.

3.3 Identification of Abusive Behaviour
Although we do not anticipate the identification of abusive behaviour owing to our internal processes to mitigate the potential for abuse, we will rely on the monthly audit of all domain name transactions conducted by the Designated person with the Applicant as well as notification of abuse to the Designated person with the Applicant by third parties through alternate communication channels to identify abusive behaviour in our TLD. In the event that an audit reveals an unauthorised domain name transaction or other behaviour indicative of abuse, the Designated person with the Applicant will notify ARI, who will take the appropriate mitigation response described below. 

4 ABUSE PREVENTION AND MITIGATION BY ARI

This section of the response includes ARI’s description of the abuse related processes they will implement regarding:
– Mitigating the potential for abusive behaviour
– Identifying abusive behaviour
– Handling abusive behaviour
These processes form part of ARI’s standard anti-abuse service and are designed with a multi-registrant model in mind. We have elected to utilise ARI’s anti-abuse service to comply with the requirements of Question 28 and do not anticipate relying strongly on these processes owing to our effective internal abuse prevention and mitigation processes described above. Note, however, that the Registry Lock service described below – beneficial in preventing the unintentional transfer, modification or deletion of the domain name – is best provided by ARI as an independent third party to maintain the separation of parties, which underpins the benefit of the service.

4.1 Pre-emptive – Mitigating the Potential for Abuse
The following practices and procedures will be adopted by ARI to mitigate the potential for abusive behaviour in our TLD.

4.1.1 Registry Lock
Certain mission-critical domain names such as transactional sites, email systems and site supporting applications may warrant a higher level of security. Whilst we will take efforts to promote the awareness of security amongst those authorised to register domain names, it is recognised that an added level of security may be provided by ‘registry locking’ the domain name and prohibiting updates thereby preventing unintentional transfer, modification or deletion of the domain name. This service mitigates the potential for abuse by prohibiting any unauthorised updates that may be associated with fraudulent behaviour. For example, an attacker may update nameservers of a mission critical domain name, thereby redirecting customers to an illegitimate website without actually transferring control of the domain name.
Upon receipt of a list of domain names to be placed on Registry Lock by an authorised representative of the registry operator, ARI will:
1. Verify the identity of the authorised representative.
2. Set or modify the status codes for the names submitted to serverUpdateProhibited, serverDeleteProhibited and⁄or serverTransferProhibited depending on the request.
3. Record the status of the domain name in the Shared Registration System (SRS).
4. Provide a monthly report to the registry operator indicating the names for which the Registry Lock service was provided in the previous month.

4.1.2 ICANN Prescribed Measures
In accordance with our obligations as a registry operator we will comply with all requirements in the ‘gTLD Applicant Guidebook’. In particular, we will comply with the following measures prescribed by ICANN which serve to mitigate the potential for abuse in the TLD:
– DNSSEC deployment, which reduces the opportunity for pharming and other man-in-the-middle attacks. We will encourage Registrars and Internet Service Providers to deploy DNSSEC capable resolvers in addition to encouraging DNS hosting providers to deploy DNSSEC in an easy to use manner in order to facilitate deployment by registrants. DNSSEC deployment is further discussed in the context of our response to Question 43.
– Prohibition on Wild Carding as required by section 2.2 of specification 6 of the Registry Agreement.
– Removal of Orphan Glue records (discussed below in section 4.1.3).

4.1.3 Orphan Glue Record Management
The ARI registry SRS database does not allow orphan records. Glue records are removed when the delegation point NS record is removed. Other domains that need the glue record for correct DNS operation may become unreachable or less reachable depending on their overall DNS service architecture. It is the registrant’s responsibility to ensure that their domain name does not rely on a glue record that has been removed and that it is delegated to a valid nameserver. The removal of glue records upon removal of the delegation point NS record mitigates the potential for use of orphan glue records in an abusive manner.

4.2 Reactive – Identification
The methods by which abusive behaviour in our TLD may be identified are described below. These include detection by ARI and notification from third parties. These methods serve to merely identify and not determine whether abuse actually exists. Upon identification of abuse the behaviour will be handled in accordance with section 4.3 – Abuse Handling.
Any abusive behaviour identified through one of the methods below will, in accordance with Requirement 13 of the BITS Requirements, be notified immediately to relevant Registrars.

4.2.1 Detection – Analysis of Data
ARI will routinely analyse registry data in order to identify abusive domain names by searching for behaviours typically indicative of abuse. The following are examples of the data variables that will serve as indicators of a suspicious domain name and may trigger further action by the ARI Abuse and Compliance Team:
– Unusual Domain Name Registration Practices: practices such as registering hundreds of domains at a time, registering domains which are unusually long or complex or include an obvious series of numbers tied to a random word (abuse40, abuse50, abuse60) may when considered as a whole be indicative of abuse.
– Domains or IP addresses identified as members of a Fast Flux Service Network (FFSN): ARI uses the formula developed by the University of Mannheim and tested by participants of the Fast Flux PDP WG to determine members of this list. IP addresses appearing within identified FFSN domains, as either NS or A records shall be added to this list.
– An Unusual Number of Changes to the NS record: the use of fast-flux techniques to disguise the location of web sites or other Internet services, to avoid detection and mitigation efforts, or to host illegal activities is considered abusive in the TLD. Fast flux techniques use DNS to frequently change the location on the Internet to which the domain name of an Internet host or nameserver resolves. As such an unusual number of changes to the NS record may be indicative of the use of fast-flux techniques given that there is little, if any, legitimate need to change the NS record for a domain name more than a few times a month.

4.2.2 Abuse Reported by Third Parties
Whilst we are confident in our abilities to detect abusive behaviour in the TLD owing to our robust ongoing monitoring activities we recognise the value of notification from third parties to identify abuse. To this end, we will incorporate notifications from the following third parties in our efforts to identify abusive behaviour:
– Industry partners through ARI’s participation in industry forums which facilitate the sharing of information.
– Law enforcement agencies (LEA) through a single abuse point of contact (our Abuse page on the registry website, as discussed in detail in ‘4.3 Abuse Handling’) and an expedited process for LEA.
– Members of the general public through a single abuse point of contact (our Abuse page on the registry website).

4.2.2.1 Industry Participation and Information Sharing
ARI is a member of the Registry Internet Safety Group (RISG), whose mission is to facilitate data exchange and promulgate best practices to address internet identity theft, especially phishing and malware distribution. In addition, ARI coordinates with the Anti-Phishing Working Group (APWG) and other DNS abuse organisations and is subscribed to the NXdomain mailing list. ARI’s strong participation in the industry facilitates collaboration with relevant organisations on abuse related issues and ensures that ARI is responsive to new and emerging domain name abuses.
The information shared as a result of this industry participation will be used to identify domain names registered or used for abusive purposes. Information shared may include a list of registrants known to partake in abusive behaviour in other TLDs. While presence on such lists will not constitute grounds for registrant disqualification, ARI will investigate domain names registered to those listed registrants and take action in accordance with our Acceptable Registration and Use Policy. In addition, information shared regarding practices indicative of abuse will facilitate detection of abuse by our own monitoring activities.

4.2.2.2 Single Abuse Point of Contact on Website
In accordance with section 4.1 of specification 6 of the Registry Agreement, we will establish a single abuse point of contact (“SAPOC”) responsible for addressing and providing a timely response to abuse complaints concerning all names registered in the TLD. Complaints may be received from members of the general public, other registries, Registrars, LEA, government and quasi-governmental agencies and recognized members of the anti-abuse community.
The SAPOC’s accurate contact details (email and mailing address as well as a primary contact for handling inquiries related to abuse in our TLD) will be provided to ICANN and published on the Abuse page of our registry website, which will also include:
– All policies in relation to the TLD including the Acceptable Registration and Use Policy.
– Registrant Best Practices.
As such, the SAPOC may receive complaints regarding a range of matters including but not limited to violations of the Acceptable Registration and Use Policy.
The SAPOC will be the primary method by which ARI and the registry operator will receive notification of abusive behaviour from third parties. It must be emphasised that the SAPOC will be the initial point of contact following which other processes will be triggered depending on the identity of the reporting organisation. Accordingly, separate processes for identifying abuse exist for reports by LEA⁄government and quasi-governmental agencies and members of the general public. These processes will be described in turn below.

4.2.2.2.1 Notification by Agencies of Abuse
We recognise that LEA, governmental and quasi-governmental agencies may be privy to information beyond the reach of others which may prove critical in the identification of abusive behaviour in our TLD. As such, we will provide an expedited process which serves as a direct channel of communication with the registry operator for LEA, government and quasi-governmental agencies to, amongst other things, report illegal conduct in connection with the use of the TLD.
The process will involve prioritisation and prompt investigation of reports identifying abuse from those organisations. The steps in the expedited process are summarised as follows:
1. We will publish contact details on the Abuse page of the registry website for the SAPOC to be utilised by only those taking part in the expedited process;
2. All calls to this number will be responded to by the registry operator’s Legal Counsel within 24 hours and handled according to the process outlined in 4.3.4 below;
3. Should ARI be notified by LEA of abuse, ARI will request that the notifying agency contact directly the registry operator’s Legal Counsel. ARI will promptly notify the registry operator’s Legal Counsel of its having been contacted by LEA regarding abuse.

4.2.2.2.2 Notification by General Public of Abuse
Abusive behaviour in the TLD may also be identified by members of the general public including but not limited to other registries, Registrars or security researchers. The steps in this notification process are summarised as follows:
1. We will publish contact details on the Abuse page of the registry website for the SAPOC (note that these contact details are not the same as those provided for the expedited process).
2. All calls to this number will be responded to by the ARI Service Desk on a 24⁄7 basis. All calls will result in the generation of a ticket in ARI’s case management system (CMS).
3. The details of the report identifying abuse will be documented in the CMS ticket using a standard information gathering template.
4. Tickets will be forwarded to ARI’s Abuse and Compliance Team to be dealt with in accordance with section 4.3 – Abuse Handling.

4.2.2.2.3 Notification by the Designated person with the Applicant
It is anticipated that notification by the Designated person with the Applicant of abuse or potential abuse will serve as the primary method by which ARI identifies abuse in the TLD given that such behaviour is likely to be detected by the Designated person with the Applicant. In the event that the monthly audit of domain name transactions by the Designated person with the Applicant reveals an unauthorised domain name transaction or other behaviour indicative of abuse, the Designated person with the Applicant will notify ARI’s Service Desk. All such calls will result in the generation of a CMS ticket, which will be forwarded to ARI’s Abuse and Compliance team to be dealt with in accordance with section 4.3 – Abuse Handling, below.

4.3 Abuse Handling
Although we do not anticipate the occurrence of abusive behaviour in our TLD owing to the high degree of control inherent in restricting domain name registrations to authorised employees within our organisation, ARI has processes in place to handle abuse once identified. Upon being made aware of abuse in the TLD, whether by ongoing monitoring activities or notification from third parties, ARI’s Abuse and Compliance Team will perform the following functions.

4.3.1 Preliminary Assessment and Categorisation
Each report of purported abuse will undergo an initial preliminary assessment by ARI’s Abuse and Compliance Team to determine the legitimacy of the report. This step may involve simply visiting the offending website and is intended to weed out spurious reports. This will not at this stage involve the in-depth investigation needed to make a determination as to whether the reported behaviour is abusive.
Where the report is assessed as being legitimate, the type of activity reported will be classified as one of the types of abusive behaviour falling within the scope of the Acceptable Registration and Use Policy by the application of the definitions provided in that policy. In order to make this classification, ARI’s Abuse and Compliance Team must establish a clear link between the activity reported and the alleged type of abusive behaviour such that addressing the reported activity will address the abusive behaviour.
While we recognise that each incident of abuse represents a unique security threat and should be mitigated accordingly, we also recognise that prompt action justified by objective criteria are key to ensuring that mitigation efforts are effective. With this in mind, we have categorised the actions that ARI may take on our behalf in response to various types of abuse by reference to the severity and immediacy of harm. This categorisation will be applied to each validated report of abuse and actions will be taken in accordance with the table below. It must be emphasised that the actions to mitigate the identified type of abuse in the table are merely intended to provide a rough guideline and may vary upon further investigation.

Category 1:
Probable Severity or Immediacy of Harm: Low
Examples of types of abusive behaviour: Spam, Malware
Mitigation steps:
1. Investigate
2. Notify registrant

Category 2:
Probable Severity or Immediacy of Harm: Medium to High
Examples of types of abusive behaviour: Fast Flux Hosting, Phishing, Illegal Access to other Computers or Networks, Pharming, Botnet command and control
Mitigation steps:
1. Suspend domain name 
2. Investigate
3. Restore or terminate domain name
The mitigation steps for each category will now be described.

4.3.2 Investigation – Category 1
Types of abusive behaviour that fall into this category include those that represent a low severity or immediacy of harm to registrants and Internet users. These generally include behaviours that result in the dissemination of unsolicited information or the publication of illegitimate information. While undesirable, these activities do not generally present such an immediate threat as to justify suspension of the domain name in question. We will contact the Designated person with the Applicant, Domain Administrator and Legal Counsel of the registry operator’s organisation to instruct that the breach of the Acceptable Registration and Use Policy be rectified. If the investigation by ARI’s Abuse and Compliance Team reveals that the severity or immediacy of harm is greater than originally anticipated, the abusive behaviour will be escalated to Category 2 and mitigated in accordance with the applicable steps. These are described below. The assessment made and actions taken will be recorded against the relevant CMS ticket.

4.3.3 Suspension – Category 2
Types of abusive behaviour that fall into this category include those that represent a medium to high severity or immediacy of harm to registrants and Internet users. These generally include behaviours that result in intrusion into other computers’ networks and systems or financial gain by fraudulent means. Following notification of the existence of such behaviours, ARI’s Abuse and Compliance Team will suspend the domain name pending further investigation to determine whether the domain name should be restored or cancelled. Cancellation will result if upon further investigation the behaviour is determined to be one of the types of abuse defined in the Acceptable Registration and Use Policy. Restoration of the domain name will result where further investigation determines that abusive behaviour, as defined by the Acceptable Registration and Use Policy, does not exist. Due to the higher severity or immediacy of harm attributed to types of abusive behaviour in this category, ARI will, in accordance with their contractual commitment to us in the form of SLA’s, carry out the mitigation response within 24 hours by either restoring or cancelling the domain name. The assessment made and actions taken will be recorded against the relevant CMS ticket.
Phishing is considered to be a serious violation of the Acceptable Registration and Use Policy owing to its fraudulent exploitation of consumer vulnerabilities for the purposes of financial gain. Given the direct relationship between phishing uptime and extent of harm caused, we recognise the urgency required to execute processes that handle phish domain termination in a timely and cost effective manner. Accordingly, ARI’s Abuse and Compliance Team will prioritise all reports of phishing from brand owners, anti-phishing providers or otherwise and carry out the appropriate mitigation response within 12 hours in accordance with the SLA’s in place between us and ARI. In addition, since a majority of phish domains are subdomains we believe it is necessary to ensure that subdomains do not represent an unregulated domain space to which phishers are known to gravitate. Regulation of the subdomain space is achieved by holding the registrant of the parent domain liable for any actions that may occur in relation to subdomains. In reality, this means that where a subdomain determined to be used for phishing is identified, the parent domain may be suspended and possibly cancelled effectively neutralising every subdomain hosted on the parent. 

4.3.4 Executing Agency Instructions
We understand the importance of our role as a registry operator in addressing consumer vulnerabilities and we are cognisant of our obligations to assist law enforcement, government and quasi– governmental agencies in the execution of their responsibilities. As such, we will make all reasonable efforts to ensure the integration of these agencies into our processes for the identification and handling of abuse by, amongst other things:
1. Providing expedited channels of communication (discussed above).
2. Notifying LEA of abusive behaviour believed to constitute evidence of a commission of a crime eg distribution of child pornography.
3. Sharing all available information upon request from LEA utilising the expedited process, including results of our investigation.
4. Providing bulk WhoIs information upon request from LEA utilising the expedited process.
5. Acting on instructions by the agency.
It is anticipated that these actions will assist agencies in the prevention, detection, investigation, prosecution or punishment of criminal offences or breaches of laws imposing penalties. The relevant agencies are not limited to those enforcing criminal matters, but may also include those enforcing civil matters in order to eliminate consumer vulnerabilities.
Upon notification of abusive behaviour by LEA, government or quasi-governmental agencies through the expedited process described in 4.2.2.2.1 above, one of the following may occur:
1. The reported behaviour will be notified to ARI and subjected to a preliminary assessment and categorisation by ARI, as described in 4.3.1 above. The reported behaviour will then be mitigated based on the results of the categorisation. A report describing the manner in which the notification from the notifying agency was handled will be provided to us by ARI within 24 hours, for provision to the notifying agency by us. This report will also be recorded against the relevant CMS ticket.
OR
2. Where specific instructions are received from the notifying agency in a format acceptable to the registry operator’s Legal Counsel, we will act in accordance with those instructions provided that they do not result in the contravention of applicable law. We will execute the instructions of the notifying agency within 12 hours. Following prompt execution of the request, a report will be provided to the agency in a timely manner.
Finally, whilst we do not anticipate the occurrence of a security situation owing to ARI’s robust systems and processes deployed to combat abuse, we are aware of the availability of the Expedited Registry Security Request Process to inform ICANN of a present or imminent security situation and to request a contractual waiver for actions we might take or have taken to mitigate or eliminate the security concern.

5 RESOURCING

The efforts to minimise abusive registrations and other activities that have a negative impact on Internet users in this TLD will be undertaken jointly by employees of the registry operator and ARI.

5.1 ARI
This function will be performed by ARI. Abuse services are supported by the following departments:

– Abuse and Compliance Team (6 staff)
– Development Team (11 staff)
– Service Desk (14 staff)

A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q28 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q28 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
ARI’s anti-abuse service serves to prevent and mitigate abusive behaviour in the TLD as well as activities that may infringe trademarks. These responsibilities will be undertaken by three teams. ARI’s Development Team will be responsible for developing the technical platforms and meeting technical requirements needed to implement the procedures and measures adopted to mitigate the potential for abuse, identify abuse and handle identified abuse. ARI’s Abuse and Compliance Team will be responsible for the ongoing implementation of measures to minimise abusive registrations and other activities that have a negative impact on Internet users. ARI’s Service Desk will be responsible for responding to reports of abuse received through the abuse point of contact on the registry’s website and logging these in a ticket in ARI’s case management system.
The responsibilities of these teams relevant to the initial implementation and ongoing maintenance for our measures to minimise abusive registrations and other activities that affect the rights of trademark holders are described in our response to Question 29 – Rights Protection Mechanisms.
All of the responsibilities undertaken by ARI’s Development Team, Abuse and Compliance Team, and Service Desk are inclusive in ARI’s Managed Registry Services fee, which is accounted for as an outsourcing cost and explained in our responses to Question 47. The resourcing needs of these teams have been determined by applying the conservative growth projections for our TLD (which are identified in our answer to Question 48) to the team’s responsibilities at start-up and on an ongoing basis.

5.1.1 ARI Development Team
All tools and systems needed to support the initial and ongoing implementation of measures adopted to mitigate the potential for abuse, identify abuse and handle identified abuse will be developed and maintained by ARI. ARI has a software development department dedicated to this purpose which will ensure that the tools are fit for purpose and adjusted as requirements change.
ARI’s Development Team participate actively in the industry; this facilitates collaboration with relevant organisations on abuse related issues and ensures that the ARI Development Team is responsive to new and emerging domain name abuses and the tools and systems required to be built to address these abuses. This team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts

5.1.2 ARI Abuse and Compliance Team
ARI’s Abuse and Compliance Team will be staffed by four full-time equivalent Policy Compliance Officers. These roles will entail the following:
A principal responsibility of the Policy Compliance Officers will be handling notifications of abuse through the SAPOC. This will involve identifying and categorising suspected abuse according to our Acceptable Registration and Use Policy and carrying out the appropriate mitigation response for all categorised abuses. Policy Compliance Officers will also be responsible for analysing registry data in search of behaviours indicative of abuse and reviewing industry lists in search of data that may identify abuse in the TLD. Furthermore, Policy Compliance Officers will provide training to the Designated person with the Applicant of the registry operator’s organisation regarding abuse prevention and mitigation in order to enable the Designated person with the Applicant to competently manage the registration and use of domain names and conduct information sessions which highlight the application of the Acceptable Registration and Use Policy.
Policy Compliance Officers will act on the instructions of verified agencies or dispute resolution providers and participate in ICANN and industry groups involved in the promulgation of policies and best practices to address abusive behaviour. They will escalate complaints and issues to the registry operator’s Legal Counsel when necessary and communicate with all relevant stakeholders (Registrars, registrants, LEA, general public) as needed in fulfilling these responsibilities. This role will be provided on a 24⁄7 basis, supported outside of ordinary business hours by ARI’s Service Desk.

Policy Compliance Officers will be required to have the following skills⁄qualifications: customer service⁄fault handling experience, comprehensive knowledge of abusive behaviour in a TLD and related policies, Internet industry knowledge, relevant post-secondary qualification, excellent communication and professional skills, accurate data entry skills, high-level problem solving skills, and high-level computer skills.

5.1.3 ARI Service Desk
ARI’s Service Desk will be staffed by 14 full-time equivalent positions. Responsibilities of Service Desk relevant to ARI’s Anti-Abuse Service include the following: responding to notifications of abuse through the abuse point of contact and expedited process for LEA, logging notifications as a ticket in ARI’s case management system, notifying us of a report received through the expedited process for LEA, government and quasi-governmental agencies, and forwarding tickets to ARI’s Abuse and Compliance team for resolution in accordance with the Acceptable Registration & Use Policy.

For more information on the skills and responsibilities of these roles, please see the in-depth resource section in answer to Question 31.

5.2 Registry Operator
The following is a description of the resources that are allocated to performing the tasks required by the registry operator. These tasks will be absorbed by the individuals currently performing the following roles within the registry operator’s organisation.

5.2.1 Designated person with the Applicant
In the context of operating this TLD the registry operator’s designated person will be responsible for managing the creation of all domains in this TLD. The Designated person with the Applicant must pre-approve all requests to create and⁄or update domain names by the Domain Administrator. In addition, the Designated person with the Applicant will perform a monthly audit of all domain name transactions to verify that they were authorised and that the use of the domain name complies with the Acceptable Registration and Use Policy. The Designated person with the Applicant will review the level of access that personnel have to the web portal, ensuring account permissions are relevant to the employee’s role as well as removing permissions of an employee promptly upon termination of employment. Finally the Designated person with the Applicant will conduct biannual information sessions to improve awareness of the threat of domain name hijacking and fraud as well as raising awareness of the Acceptable Registration and Use Policy.

5.2.2 Domain Administrator
The registry operator’s existing Domain Administrator will be responsible for managing the registry operator’s domain name portfolio, which will involve creating, updating and maintaining all domains in this TLD in the name of and for the exclusive use of the registry operator.

5.2.3 Legal Counsel
The registry operator’s existing Legal Counsel will be responsible for responding to all reports and requests by LEA and managing the expedited process for those agencies and handling all escalated complaints and potential disputes arising in connection with the implementation of ARI’s anti-abuse service and related policies. This will involve assessing escalated complaints and issues, resolving disputes and liaising with all relevant stakeholders (Registrars, registrants, LEA, general public) as needed in fulfilling these responsibilities.
Based on the projections and the experience of ARI, the resources described here are more than sufficient to accommodate the needs of this TLD.

The Applicant has engaged ARI Registry Services (ARI) to deliver services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q29 – ARI Background & Roles.pdf’.

1 INTRODUCTION
Rights protection is a core objective of this TLD, facilitated by its planned operating model and well-developed rights protection mechanism (RPM) implementation plans. We intend to request an exemption pursuant to clause 6 from clause 1b of the Registry Operator Code of Conduct to enable us to register domain names in our own right in this TLD. Registrations will not be made commercially available. The control inherent in this model will assist us in protecting the legal rights of others. Our commitment to rights protection is further demonstrated by our adoption of many of the requirements proposed in the ‘2011 Proposed Security, Stability and Resiliency Requirements for Financial TLDs’ (at http:⁄⁄www.icann.org⁄en⁄news⁄correspondence⁄aba-bits-to-beckstrom-crocker-20dec11-en.pdf) (the ‘BITS Requirements’). We acknowledge that these requirements were developed by the financial services sector in relation to financial TLDs, but nevertheless believe that their adoption in this TLD (which is not financial-related) results in a more robust approach to combating abuse. In particular, we will adopt the following Requirements:
8: we will provide and maintain valid primary contact information (name, email address, and phone number) on our registry website.
10: we will re-validate our Registry-Registrar Agreements (RRA) at least annually.
13: we will notify Registrars immediately regarding any RPM investigation or compliance action including the nature of the investigation or compliance action by ICANN or any outside party (eg law enforcement etc).
Eligibility, naming and use restrictions will be imposed in this TLD (per Requirements 1, 3 and 4 of the BITS Requirements), supported at the time of registration by registrant warranty and enforced through internal processes requiring approvals within established reporting lines and the use of username⁄password to verify eligibility to register. As described in our response to Question 18, we will be the only eligible registrant in the TLD. This offers complete control over and responsibility for all registrations; the central point of control will ensure that multiple applications for the same name are not made, thus addressing Requirement 2 of the BITS Requirements. This robust policy and procedure framework, which will be continually improved, updated and rigidly enforced, will preclude abusive registrations from being made. 
The abusive behaviour primarily targeted by sunrise, the TM Claims service, URS, UDRP, and Trademark PDDRP is cybersquatting, which is the registration of domain names constituting trademarks by registrants lacking rights in such marks. We note that different RPMs define the scope of protectable trademarks slightly differently; we therefore clearly identify the scope of protectable trademarks as respects each RPM. Cybersquatting is one of the many forms of abuse we will seek to minimise in our TLD. Our approach to combating abusive behaviour other than cybersquatting is described in our response to Question 28. Some overlap between the responses to Questions 28 and 29 is inherent because the prevention of cybersquatting can also serve to minimise other abusive behaviours such as phishing and pharming. By implementing the RPMs discussed below we thus aim also to minimise abuse as identified in our response to Question 28. 
We recognise that RPMs implemented in this TLD are targeted at abusive behaviour not by others but by ourselves. We will be the respondent in all RPM proceedings. We nevertheless consider that such proceedings are unlikely to be raised due to the controls exercised within our organisation over registration.
For clarification, for the purposes of this response, references to the Registry Operator are references to the applicant entity; references to ‘we’, ‘us’, and ‘our’ refer to the same. References to a domain name registrant are references to a registrant authorised by us meeting the eligibility restrictions identified in our response to Question 18. Validation of the identity of domain name applicants will be easily achieved by Registrars given the internal-only nature of the TLD and the resultant close relationship between registry operator and Registrar.

2 START-UP RPMs
Below we identify our start-up RPM timeline and describe the way in which we will implement:
– A sunrise registration service
– The TM Claims service

2.1 Start-up RPMs Timeline
The timeline for start-up RPMs in our TLD is as follows:
Day 1: Single sunrise round opens
Day 30: Sunrise round closes
Day 31: Sunrise allocation period
Day 32: General registration begins, TM Claims Service begins
Day 92: TM Claims Service ends

2.2 Sunrise Registration Service
Our sunrise will provide trademark holders satisfying the eligibility restrictions identified in our response to Question 18 with a 30-day priority period in which to register their marks as domain names. Due to the application of the eligibility restrictions we will be the only eligible registrant, but holders of trademarks registered in the Trademark Clearinghouse (TMCH) will have the benefit of notice of sunrise registrations constituting an ‘Identical Match’ to their marks. 
The following stakeholders are involved in implementation of the sunrise registration service:
– TMCH Service Provider⁄s
– Registrars
– Registry Operator
The role played by these stakeholders is described below with reference to:
– A summary of our Sunrise Policy and Sunrise Dispute Resolution Policy (SDRP)
– Our Sunrise Implementation Plan
– Our SDRP Implementation Plan
– Our implementation of sunrise and SDRP through contractual relationships

2.2.1 Sunrise Policy Summary and SDRP Summary
Through our Sunrise Policy we will offer a single, 30-day sunrise round in which trademark holders satisfying (i), (iii) and (iv) of the Sunrise Eligibility Requirements (SERs) proposed in the Applicant Guidebook at Trademark Clearinghouse s6.2.3 and the eligibility restrictions identified in our response to Question 18 will be eligible to apply for a domain name. This will be the first opportunity for registration in our TLD. Our Sunrise Policy will specify that applications received by an ICANN-accredited Registrar within the 30-day Sunrise Period and satisfying the SERs will be accepted for participation in the sunrise. Our Sunrise Policy will mandate that the trademarks upon which sunrise applications are based must fall within the Applicant Guidebook at Trademark Clearinghouse s7.2 and be supported by an entry in the TMCH. Internal registration processes will ensure that multiple applications for the same name are not made. Domains registered during sunrise will have a term of 1 year from the date of registration.
We will adopt (as registry operator) and submit (registrant) to a Sunrise Dispute Resolution Policy (SDRP) to allow any party to raise a challenge on the four grounds identified in the Applicant Guidebook at Trademark Clearinghouse s6.2.4. The remedy offered will be cancellation or deletion of a successfully challenged domain. The SDRP will specify that claims may be raised against a domain applied for during sunrise and will require that complaints clearly identify the challenger, the challenged domain name, and the ground⁄s upon which the complaint is based, and explain why the challenger believes that the ground⁄s are satisfied. If a TMCH service provider is not able to receive challenges directly as part of its undertaking to ‘maintain the SERs, validate and authenticate marks, as applicable, and hear challenges’ (Applicant Guidebook at Trademark Clearinghouse s6.2.5), ARI will receive SDRP challenges on our behalf and communicate these to the SDRP provider.

2.2.2 Sunrise Implementation Plan
1. Prior to or during our 30-day sunrise period, trademark holders can apply for validation of trademarks by the TMCH and inclusion of validated marks in the TMCH database.
2. ARI will develop a website and make available on that website our Sunrise Policy and SDRP.
3. An authorised employee will submit to an ICANN-accredited Registrar an application to register a domain name corresponding to a TMCH entry with evidence of the corresponding TMCH entry. If additional information or evidence of identity is required for validation by the Registrar this will be provided with the application. Compliance with registration policies implemented through internal processes will ensure that multiple applications are not made for the same name.
4. Registrars will be required through our RRA to validate the identity of all applicants and communicate sunrise application information to ARI.
5. ARI will perform standard checks (including IDN validity checks where relevant, reserved and restricted words in accordance with the Registry Agreement, composition requirements, etc.) to ensure that the domain being applied for is technically valid; an error message will be returned to the Registrar if the domain fails any of these checks.
6. Through an interface with the TMCH, ARI will identify all sunrise applications constituting an ‘Identical Match’ (as defined in the Applicant Guidebook at Trademark Clearinghouse s6.1.5) with a TMCH entry and provide notice to the holders of those trademarks of the filing of a corresponding sunrise registration. 
7. A one-day quiet period will commence at the conclusion of the sunrise period. ARI will enable the sponsoring Registrar to CREATE (using EPP or the SRS web interface).

2.2.3 SDRP Implementation Plan
1. If a TMCH service provider is not able to directly receive complaints under our SDRP, we will specify in our SDRP the email address to which SDRP filings must be sent. This address will be monitored by ARI’s Abuse and Compliance Team.
2. ARI will develop a process of manual or automatic interface with the TMCH to communicate our SERs and any SDRP challenges received by ARI. This interface will also enable the TMCH service provider to notify ARI of successful SDRP challenges.
3. On notification from a TMCH service provider of a successful SDRP challenge, ARI will cancel or delete the domain name the subject of the successful challenge.

2.3 TM Claims Service
Immediately following the one-day sunrise allocation period, a 60-day period will commence during which we will offer the TM Claims Service. This is a service whereby prospective domain registrants receive notice of existing trademark rights matching their applied-for domain and trademark owners receive notice of registrations matching their mark. In accordance with the Applicant Guidebook our TM Claims service will be supported exclusively by the TMCH and will recognise and honour all word marks falling within the Applicant Guidebook at Trademark Clearinghouse s7.1.
The following stakeholders are involved in implementation of the TM Claims Service:
– TMCH Service Provider⁄s
– Trademark owners
– Registrars
– Registry Operator
The role played by these stakeholders is described below by reference to:
– Our TM Claims Service Implementation Plan
– Our implementation of the TM Claims service through contractual relationships

2.3.1 Implementation

2.3.1.1 TM Claims Service Implementation Plan
1. Prior to or during the 60-day TM Claims period, trademark holders can apply for validation of their marks by the TMCH and inclusion in the TMCH database. This enables the provision of notice to applicants during this period of entries in the TMCH and notice to trademark holders of registrations matching TMCH entries (how and by whom this will be achieved is detailed in subsequent steps of this implementation plan).
2. An authorised employee will submit to an ICANN-accredited Registrar an application for a domain. If additional information or evidence of identity is required for validation by the Registrar, this will be provided with the application. Compliance with registration policies implemented through internal processes will ensure that multiple applications are not made for the same name.
3. Registrars will be required through our RRA to validate the identity of all applicants. 
4. For all applications received during this 60-day period, Registrars will be required to interface with the TMCH to determine whether an applied-for domain constitutes an ‘Identical Match’ with a trademark in the TMCH. If an ‘Identical Match’ is identified, the Registrar will provide to the applicant a TM Claims Notice in the form prescribed by the Applicant Guidebook. Following receipt of this notice the applicant must communicate to the Registrar its decision either to proceed with or abandon the application. If the applied-for name does not constitute an ‘Identical Match’ with a mark in the TMCH, no TM Claims Notice will be generated.
5. ARI will utilise the manual or automatic interface established for implementation of the SDRP (described above in ‘SDRP IMPLEMENTATION PLAN’) to facilitate reporting to registries by the TMCH of attempts to register domain names that are an ‘Identical Match’ with a trademark (as defined in the Applicant Guidebook at Trademark Clearinghouse s7.1) in the TMCH database.
6. We will conduct a review to determine whether to proceed with the application. If a decision is made to proceed, the Registrar will be required through our RRA to communicate the application information to ARI.
7. ARI will perform standard checks to ensure that the applied-for domain is technically valid; an error message will be returned to the Registrar if the domain fails any of these checks. If the domain passes these checks, ARI will enable the sponsoring Registrar to CREATE (using EPP or the SRS web interface) the domain.
8. Registrars will be required through our RRA to interface with the TMCH to promptly notify relevant mark holders of the registration of a domain constituting an ‘Identical Match’ to their TMCH entry.

2.3.1.2 Implementation through Contractual Relationships
The TM Claims Service Implementation Plan above will additionally be executed by the inclusion of the following clauses in our RRA:
– Registrars must use the TMCH as required by ICANN and the TMCH service provider⁄s.
– Registrars must not in their provision of the TM Claims Service make use of any trademark information aggregation, notification or validation service other than the TMCH.
– In order to prevent a chilling effect on registration, Registrars must ensure that applicants are not prevented from registering domain names considered an ‘Identical Match’ with a mark in the TMCH.
– Registrars must provide clear notice in the specific form provided by the ‘gTLD Applicant Guidebook’ to the prospective registrant of relevant entries in the TMCH.

3 ONGOING RPMs
As the only eligible registrant in our TLD, the ongoing RPMs described below are targeted at abusive behaviour by us, but such abuse will be prevented by internal processes that control domain name registration. We take seriously our responsibilities as Registry Operator and as registrant and acknowledge that as the registrant, we are subject to the URS and UDRP, as well as the Trademark PDDRP (to which all registry operators, regardless of the operating model of the TLD, are bound). We will abide by decisions rendered through those RPMs.
We also highlight that the single registrant⁄single user (SRSU) TLD model we intend to adopt, enabled by being granted an exemption to clause 1b of the Registry Operator Code of Conduct, is a new TLD model; RPMs designed prior to the new gTLD program were not designed with this model in mind. Even the newly designed URS and Trademark PDDRP are from conceptual and implementation perspectives not entirely practicable for the SRSU TLD model. Where gaps exist in current policy we have noted and addressed these in our implementation plans.

3.1 URS
The URS is a new RPM the implementation of which is mandated in all new gTLDs. It is targeted at providing a rapid takedown solution to clear-cut cases of cybersquatting. It is intended to have a deterrent effect and reduce the number of disputes under the UDRP. 
Due to the complete control of all registrations in our planned SRSU model, we do not anticipate any situation in which it could be argued in good faith both that we have ‘no legitimate right or interest to the domain name’ in question and ‘that the domain name was registered and is being used in bad faith’. The risk of URS complaints will be minimised through internal processes controlling domain name registration. However, these processes would not stop a claimant from making a URS claim (even one in bad faith) against us. If that occurs we will to the extent practicable respond in a timely fashion and take steps to avoid default. In summary, we will have in place robust registration policies and internal procedures to prevent infringement of trademark rights by our registrations and therefore do not anticipate that URS claims will arise in our TLD, but nevertheless have developed an implementation plan to ensure that this mechanism is in place and is compliant with our obligations as a Registry Operator.
The URS is intended to supplement and not replace the UDRP, and the Applicant Guidebook foreshadows (at URS ss8.6 and 13) the likelihood of URS claimants also commencing UDRP claims. For this reason, we have considered in our URS Implementation Plan the potential interaction between URS stakeholders and UDRP stakeholders.
The following stakeholders are involved in implementation of the URS:
– URS claimants (holders of valid and enforceable trade or service marks)
– Registrar
– Registry Operator
– URS provider⁄s 
– URS Examiner 
The role played by these stakeholders is described below by reference to:
– Our URS Implementation Plan
– Our implementation of the URS through contractual relationships

3.1.1 Implementation
In our URS Implementation Plan below we identify certain aspects of implementation that are required under the Applicant Guidebook but nevertheless are not possible or practical to implement in the context of this TLD given its SRSU model. As the only eligible registrant, we acknowledge that we are prohibited from making changes to the WhoIs information of a registration if we have failed to respond to a URS complaint (default) in accordance with the Applicant Guidebook at URS s6.1. We also acknowledge we are prohibited from making changes to a domain name in locked status. 
Understanding that a fundamental aim of the URS is expediency, all of the steps in the implementation plan will be undertaken as soon as practical but without compromising security or accuracy.

3.1.1.1 URS Implementation Plan
1. As an initial step, ARI will notify to each URS provider an email address for all URS-related correspondence. On an ongoing basis, ARI’s Abuse and Compliance Team will monitor this address for communications from URS providers including the Notice of Complaint, Notice of Default, URS Determination, Notice of Appeal and Appeal Panel Findings.
2. ARI will validate correspondence from a URS provider to ensure that it originates from the URS Provider.
3. ARI will within 24 hours of receipt of a URS Notice of Complaint lock the domain name⁄s the subject of that complaint by restricting all changes to the registration data, including transfer and deletion of the domain. The domain will continue to resolve while in this locked status.
4. ARI will immediately notify the URS provider in the manner requested by the provider once the domain⁄s have been locked.
5. On receipt of a favourable URS Determination ARI will lock the domain the subject of Determination for the balance of the registration period and redirect the nameservers to an informational web page provided by the URS provider. While a domain is locked, ARI will continue to display all of the WhoIs information of the original registrant except for the redirection of the nameservers and the additional statement that the domain will not be able to be transferred, deleted or modified for the life of the registration.
6. On receipt of notification from the URS provider of termination of a URS proceeding ARI will promptly unlock the domain and return full control to the registrant.
7. Where a default has occurred (because we have not submitted a response to a URS complaint in accordance with the Applicant Guidebook at URS s6.1) and a Determination has been made in favour of the complainant, in the event that ARI receives notice from a URS provider that a Response has been filed in accordance with the Applicant Guidebook at URS s6.4, ARI will as soon as practical restore a domain to resolve to the original IP address while preserving its locked status until a Determination from de novo review is notified to ARI.
8. ARI will ensure that no changes are made to the resolution of a registration the subject of a successful URS Determination until expiry of the registration or the additional registration year unless otherwise instructed by a UDRP provider.
We note that the Applicant Guidebook requires that registry operators make available to successful URS complainants an optional extension of the registration period for one additional year at commercial rates. This is rendered impractical in the context of our TLD by the fact that we are the only eligible registrant; any such extension will be undertaken by ourselves at wholesale cost.

3.1.1.2 Implementation of the URS through Contractual Relationships
We will require through our RRA that Registrars not take any action relating to a URS proceeding except as in accordance with a validated communication from ARI or a URS provider.

3.2 UDRP
The UDRP is applicable to domain name registrations in all new gTLDs. It is available to parties with rights in valid and enforceable trade or service marks and is actionable on proof of all three grounds identified in the policy as on ICANN’s website: http:⁄⁄archive.icann.org⁄en⁄udrp⁄udrp-policy-24oct99.htm
As the only eligible registrant in the TLD, we will be the respondent in all UDRP complaints in relation to the TLD. Because we will have control of all registrations we do not anticipate many, if any, situations in which it could be argued in good faith both that we have ‘no rights or legitimate interest in respect of the domain name’ in question and that the name ‘has been registered and is being used in bad faith’. The risk of UDRP complaints will be minimised through internal processes controlling registration. However, these processes would not stop a claimant from making a claim (even one in bad faith) against us. If a complaint is raised, we will to the extent practicable respond in a timely fashion and take steps to avoid default. In summary, while we expect that UDRP claims will not arise in our TLD, we have developed an implementation plan to ensure that this mechanism is in place and is compliant with our obligations as registry operator.
The remedies offered by the UDRP are cancellation or transfer of a registration to a successful UDRP claimant. We note, however, that transfer is rendered impossible in the context of this TLD; where an exemption to clause 1b of the Registry Operator Code of Conduct has been granted enabling the registry operator to register domain names in its own right, transfer of domains is prohibited. For this reason, it appears that the only applicable remedy to a UDRP claim raised against us is cancellation of the disputed domain. We will place cancelled names on a list to prevent their subsequent registration.
The following stakeholders are involved in implementation of the UDRP:
– UDRP claimants
– Registrar
– Registry Operator
– UDRP providers
The role played by these stakeholders is described below by reference to:
– Our UDRP Implementation Plan
– Our implementation of the UDRP through contractual relationships
Our UDRP Implementation Plan considers the potential overlap between URS implementation and UDRP implementation because we consider it likely that URS complainants will commence UDRP claims as a second recourse or simultaneously. We note that neither policy prohibits complainants from commencing proceedings simultaneously.

3.2.1 Implementation
Our UDRP Implementation Plan is set out below followed by a description of the implementation that will take place through contractual relationships.

3.2.1.1 UDRP Implementation Plan
From a policy compliance perspective as the registrant of domain names in our TLD, we acknowledge that we are subject to the UDRP.
From a technical perspective, our UDRP Implementation Plan focuses on interaction with Registrars because there is currently no interaction between existing gTLD registry operators and UDRP providers. On this basis we consider that ARI has one principal responsibility in facilitating Registrars’ implementation of the UDRP: ARI’s Development Team (described in ‘4 RESOURCES’ below) will maintain awareness of UDRP requirements and be capable of taking action when required and sufficiently skilled and flexible to respond to any changes to UDRP policy.
UDRP implementation would also ordinarily require that ARI provide EPP and the SRS web interface to enable Registrars to perform required UDRP functions in accordance with the Policy on Transfer of Registrations between Registrars. Transfers between Registrars are not likely to arise in our TLD and transfer is not a viable remedy for UDRP violation in the context of our TLD as explained above.

3.2.1.2 Implementation of the UDRP through Contractual Relationships
The UDRP is applicable to domain name registrations in all new gTLDs by force of a contractual obligation (Registry Agreement Art. 2.9) on registry operators to use only ICANN-accredited Registrars, who in turn are contractually required (RAA, 21 May 2009, at 3.8) to incorporate the UDRP in their Registration Agreements. Consistent with Requirement 7 of the BITS Requirements, we will require through our RRA that Registrars certify annually to ICANN their compliance with ICANN’s RAA.

3.3 Preventing Trademark Infringement in Operating the Registry
The new Trademark PDDRP, which targets infringement arising from the registry operator’s manner of operation or use of its TLD, is primarily directed at the situation in which the registry operator and registrant are not the same or affiliated entities. In that situation, trademark holders have no clear recourse against the registry operator. Because the Registry Operator in our TLD is also the registrant, trademark owners do in fact have recourse against us under the URS, UDRP. However, the grounds of those RPMs differ from grounds for claims under the Trademark PDDRP. Grounds for raising a Trademark PDDRP claim are as follows:
(i) There is a substantial pattern or practice of specific bad faith intent by the registry operator to profit from the sale of trademark infringing domain names; and
(ii) The registry operator’s bad faith intent to profit from the systematic registration of domain names within the gTLD that are identical or confusingly similar to the complainant’s mark, which:
(a) Takes unfair advantage of the distinctive character or reputation of the complainant’s mark; or
(b) impairs the distinctive character or reputation of the complainant’s mark; or
(c) creates a likelihood of confusion with the complainant’s mark.
While we will as required under the Registry Agreement agree to participate in all Trademark PDDRP procedures and be bound by resulting determinations, we consider the risk of claims being raised against us eliminated because it will not be possible for claimants to satisfy the two grounds cited above. Specifically, it cannot be shown that there exists a ‘substantial pattern or practice... to profit from the sale of trademark infringing domain names’ because domain names will not be sold in our TLD.
We will implement the Trademark PDDRP in accordance with our implementation plan below, but will have in place procedures to identify and address potential conflicts with others’ trademarks before domains are registered, and do not otherwise foresee that any Trademark PDDRP claims raised against us could succeed.
The following stakeholders are involved in our implementation of measures to prevent trademark infringement in our running of the TLD:
– Trademark holders
– Registry Operator
– Trademark PDDRP provider⁄s
The role played by these stakeholders is described below by reference to:
– Our Trademark PDDRP Implementation Plan
– Our implementation of our Trademark PDDRP through contractual relationships

3.3.1 Implementation
Our Trademark PDDRP Implementation Plan is set out below followed by a description of the implementation that will take place through contractual relationships.

3.3.1.1 Trademark PDDRP Implementation Plan
1. ARI will notify to the Trademark PDDRP provider⁄s contact details for communications regarding the Trademark PDDRP.
2. As described in our response to Question 28, ARI will publish our Acceptable Registration and Use Policy on a website specifically dedicated to abuse handling in our TLD. Consistent with Requirement 8 of the BITS Requirements, this website will include contact details to enable trademark holders to raise concerns regarding infringement of their trademarks by us and resultant harm caused by our operation or use of our TLD. 
3. All calls will be responded to by ARI’s Service Desk on a 24⁄7 basis and will result in the generation of a ticket in ARI’s case management system (CMS). The details of the complaint (which will at a minimum include the information below) will be documented using a standard information gathering template, which will be recorded against the CMS ticket:
– Complainant name
– Contact details
– Trademark name
– Jurisdiction
– Registration date
– Registration number
– Nature of entitlement to trademark
– Explanation of why complainant believes that its mark has been infringed and harm caused by our operation or use of the TLD
4. Tickets will be forwarded to ARI’s Abuse and Compliance Team. A Policy Compliance Officer will conduct a preliminary assessment to ensure that a complaint is not spurious. If it is determined that a complaint is not spurious, the Policy Compliance Officer will use the contact details provided in the complaint to acknowledge receipt of the complaint and commence investigation and good faith negotiation with the complainant in accordance with the Applicant Guidebook at Trademark PDDRP s7.2.3(d). Any actions taken will be recorded against the CMS ticket.
5. On an ongoing basis, ARI’s Abuse and Compliance Team will monitor the email address notified to the Trademark PDDRP provider⁄s for all communications from the Trademark PDDRP provider including the threshold determination, Trademark PDDRP complaint, complainant’s reply, notice of default, expert panel determinations, notice of appeal and determinations of an appeal panel.
6. In the event that a complaint cannot be resolved and a Trademark PDDRP claim is made, ARI’s Abuse and Compliance Team will on our instruction do the following:
– File a response in accordance with the Applicant Guidebook at Trademark PDDRP s10 (thus avoiding, whenever possible, default);
– Where appropriate, make and communicate to the Trademark PDDRP provider decisions regarding the Trademark PDDRP proceeding, including whether to request a three-person Trademark PDDRP Expert Panel (Trademark PDDRP s13.2), request discovery (s15.1), request a hearing (s16), request a de novo appeal (s20.1), challenge an ICANN-imposed Trademark PDDRP remedy (s21.3), initiate dispute resolution under the Registry Agreement (s21.4), or commence litigation in the event of a dispute arising under the Trademark PDDRP (s22); and
– Where appropriate, undertake discovery in compliance the Applicant Guidebook at Trademark PDDRP s15, attend hearings raised under s16, and gather evidence in compliance with ss20.5 and 20.6.
7. ARI will on notification of an Expert Panel finding in favour of the Claimant (Trademark PDDRP s14.3), reimburse the Claimant.
8. ARI will implement any remedial measures recommended by the expert panel pursuant to Trademark PDDRP s18.3.1 and take all steps necessary to cure violations found by the expert panel (Trademark PDDRP s18.3.2) and notified by ICANN (Trademark PDDRP s21.3).

3.3.1.2 Implementation of Trademark PDDRP through Contractual Relationships
All new gTLD registry operators are bound to comply with the Trademark PDDRP by Specification 7, cl 2 of the Registry Agreement. In accordance with Requirement 6 of the BITS Requirements, we will certify annually to ICANN our compliance with the Registry Agreement.

4 RESOURCES
ARI’s abuse services are supported by the following departments:
– Abuse and Compliance Team (6 staff)
– Development Team (11 staff)
– Service Desk (14 staff)
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q29 – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system. Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q29 – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. 
The measures described in the context of the responses to Questions 28 and 29 – which serve to prevent and mitigate abusive behaviour in the TLD as well as activities that may infringe trademarks – will be implemented and managed by ARI on our behalf. These responsibilities will be undertaken by three teams. ARI’s Development Team will be responsible for developing the technical platforms and meeting technical requirements needed to implement the RPMs discussed above. ARI’s Abuse and Compliance Team will be responsible for the ongoing operations of our measures to minimise abusive registrations and other activities that affect trademark rights recognised through RPMs. ARI’s Service Desk will be responsible for responding to reports of trademark infringement received through the abuse point of contact on the registry website and logging these in a ticket in ARI’s case management system.
The responsibilities of these teams relevant to the initial implementation and ongoing maintenance for our measures to minimise the potential in our TLD for abuse not specifically affecting trademark rights are described in our response to Question 28.
All of the responsibilities undertaken by ARI’s Development Team, Abuse and Compliance Team and Service Desk are inclusive in ARI’s Managed Registry services fee, which is accounted for as an outsourcing cost in our response to Question 47. The resourcing needs of these teams have been determined by applying the conservative growth projections for our TLD (identified in our response to Question 48) to the teams’ responsibilities at start-up and on an ongoing basis.

4.1 ARI Development Team
All tools and systems used for the transmission and receipt of information related to RPMs will be developed and maintained by ARI. ARI has a Development Team dedicated to this purpose which will ensure that the tools are fit for purpose and adjusted as requirements change.
ARI will ensure that systems and tools will be compliant with the appropriate processes for dealing with Registrars, the TMCH, URS and Trademark PDDRP providers as these processes are defined. ARI has been and will remain active in the formulating of these processes. ARI will use its resources to remain current with the approved measures for exchange of any material relevant to RPMs, whether during sunrise or on an ongoing basis. This team consists of:
– 1 Development Manager
– 2 Business Analysts
– 6 Developers
– 2 Quality Analysts

4.2 ARI Abuse and Compliance Team
ARI’s Abuse and Policy Compliance Team will be staffed by five full-time equivalent positions:
– 4 Policy Compliance Officers
– 1 Legal Manager
Policy Compliance Officers will be responsible for managing sunrise applications, supporting the SDRP, TM Claims Service, URS, UDRP and Trademark PDDRP, managing communications with the TMCH, receiving, assessing and managing trademark infringement complaints received through the single abuse point of contact, escalating complaints and issues to the Legal Manager when necessary, and communicating with all relevant stakeholders (Registrars, registrants, trademark holders, general public) as needed in fulfilling these responsibilities. This role will be provided on a 24⁄7 basis supported by the ARI Service Desk. Policy Compliance Officers will be required to have the following skills⁄qualifications: customer service⁄fault handling experience, complete knowledge of all RPMs offered by the TLD and related policies, Internet industry knowledge, relevant post-secondary qualification, excellent communication and professional skills, accurate data entry skills, high-level problem solving skills, and high-level computer skills.
The Legal Manager will be responsible for handling all potential disputes arising in connection with RPMs and related policies. This will involve assessing complaints and issues, liaising with legal counsel and management, resolving disputes and communicating with all relevant stakeholders (Registrars, registrants, trademark holders, general public) as needed in fulfilling these responsibilities. The Legal Manager will be required to have the following skills⁄qualifications: legal background (in particular, intellectual property⁄information technology law) or experience with relevant tertiary or post-graduate qualifications, dispute resolution experience, Internet industry experience, excellent communication, negotiation, problem solving and professional skills and good computer skills.

4.3 ARI Service Desk
ARI’s Service Desk will be staffed by 14 full-time equivalent positions. Responsibilities of the Service Desk relevant to RPMs include the following: responding to notifications of trademark infringement through the single abuse point of contact, logging notifications as a ticket in ARI’s case management system, and forwarding tickets to ARI’s Abuse and Compliance team for resolution in accordance with relevant RPM implementation plans. 
For more information on the skills and responsibilities of these roles, please see the in-depth resources section in response to Question 31.
Based on the projections and the experience of ARI, the resources described here are more than sufficient to accommodate the needs of this TLD.
The use of these resources and the services they enable is included in the fees paid to ARI, which are described in response to Question 47.

The Applicant has engaged ARI Registry Services (ARI) to deliver services for this TLD. ARI provide registry services for a number of TLDs including the .au ccTLD. For more background information on ARI please see the attachment ‘Q30a – ARI Background & Roles.pdf’. This response describes Security as implemented by ARI under direction from the registry operator, taking into account any specific needs for this TLD.

1 SECURITY POLICY SUMMARY

ARI operates an ISO27001 compliant Information Security Management System (ISMS) for Domain Name Registry Operations; see attachment ‘Q30a – SAI Global Certificate of Compliance.pdf’. The ISMS is an organisation-wide system encompassing all levels of Information Security policy, procedure, standards, and records. Full details of all the policies and procedures included in the ISMS are included in the attachment to Question 30b.

1.1 The ISMS
ARI’s ISMS’s governing policy:
– Defines the scope of operations to be managed (Domain Name Registry Operations).
– Designates the responsible parties (COO, CTO and Information Security Officer) for governance, Production Support Group for implementation and maintenance, and other departments for supporting services.
– Requires a complete Risk Assessment (a developed Security Threat Profile for the Service – in this case registry services for the TLD – and a Risk Analysis tracing threats and vulnerabilities through to Risks) and Risk Treatment Plan (each major risk in the Risk Assessment references the Statement of Applicability indicating controls to be implemented, responsible parties, and the effectiveness metrics for each).
– Includes a series of major sub policies governing security, which include but are not limited to:
 – ICT acceptable use policy and physical security policies.
 – PSG Security Policy which outlines the registry operations policies, the management of end-user devices, classification of networks and servers according to the classification of information they contain, networking, server & database configuration and maintenance guidelines, vulnerability and patch management, data integrity controls, access management, penetration testing, third party management, logging and monitoring, and cryptography.
– Requires ongoing review:
 – Of risks, threats, the Risk Treatment Plan, client requirements and commitments, process and policy compliance, process and policy effectiveness, user etc.
 – Regular internal and external penetration testing & vulnerability scanning.
 – Ad-hoc review raised during normal operations, common sources being change management processes, scheduled maintenance or project debriefs, and security incidents.
 – Yearly review cycle which includes both internal and external audits, including external surveillance audits for compliance.
 – Additional yearly security controls assessment reviews, which include analysis of the security control implementations themselves (rather than compliance with any particular standard).
 – At 24 month intervals, external penetration testing of selected production services.
 – periodic ISO reaccreditation
ARI’s ISMS encompasses the following ARI standards:
– Configuration standards for operating systems, networking devices and databases based on several key publications, including those released by NIST (eg SP800-123, SP800-44v2, SP-800-40, SP800-41) and the NSA, staff testing and experience, and vendor supplied standards.
– Security Incident Classification, which identifies the various classifications of security incidents and events to ensure that events that qualify as security incidents.
– Information Classification and Handling which specifies the information classification scheme and the specific requirements of handling, labelling, management and destruction for each level of classification.

1.2 SECURITY PROCESSES
Processes are used to implement the policies. These include, but are not limited to:

1.2.1 Change Management
This includes change management and its sub-processes for access management, software deployment, release of small changes and scheduled maintenance. This process includes:
– The classification of changes and the flow into sub processes by classification.
– The release and deployment process for change control into production environments, outlining peer review, testing steps, approval points, checklist sets, staging requirements and communication requirements.
– The software release and deployment process with its specific testing and staged rollout requirements.
– The scheduled maintenance process and its various review points.

1.2.2 Incident Management
This includes incident management process and its sub-process for unplanned outages. These outline:
– How incidents are managed through escalation points, recording requirements, communication requirements etc.
– The unplanned outage procedure which applies directly to situations where the registry itself or other critical services are unexpectedly offline.

1.2.3 Problem Management
The goal of problem management is to drive long term resolution of underlying causes of incidents. This process centres on finding and resolving the root causes of incidents. It defines escalation points to third parties or other ARI departments such as Development, as well as verification of the solution prior to problem closure.

1.2.4 Security Incident Management
This process deals with the specific handling of security incidents. It outlines the requirements and decision points for managing security incidents. Decision points, escalation points to senior management and authorities are defined, along with evidence-gathering requirements, classification of incidents and incident logging.

1.2.5 Access Management
This process handles all access changes to systems. HR must authorize new users, and access changes are authorized by departmental managers and approved by the Information Security Officer.
When staff leave or significantly change roles, a separation process is followed which ensures all access that may have been granted during their employment (not just their initially granted access) is checked and where appropriate, revoked.
Finally, quarterly review of all access is undertaken by the ISO, reviewing and approving or rejecting (with an action ticket) as appropriate.

2 ARI’s SECURITY INFRASTRUCTURE SOLUTIONS

ARI has developed a layered approach to IT security infrastructure. At a high level, some of the layers are as follows:
– DDoS countermeasures are employed outside ARI networks. These include routing traps for DDoS attacks, upstream provider intervention, private peering links and third party filtering services.
– Routing controls at the edge of the network at a minimum ensures that only traffic with valid routing passes into ARI networks.
– Overprovisioning and burstable network capabilities help protect against DoS and DDoS attacks.
– Network firewalls filter any traffic not pre-defined by network engineering staff as valid.
– Application layer firewalls then analyse application level traffic and filter any suspicious traffic. Examples of these would be an attempt at SQL injection, script injection, cross-site scripting, or session hijacking.
– Server firewalls on front-end servers again filter out any traffic that is not strictly defined by systems administrators during configuration as valid traffic.
– Only applications strictly necessary for services are running on the servers.
– These applications are kept up-to-date with the latest security patches, as are all of the security infrastructure components that protect them or that they run on.
– ARI infrastructure is penetration-tested by external tools and contracted security professionals for vulnerabilities to known exploits.
– ARI applications are designed, coded and tested to security standards such as OWASP and penetration-tested for vulnerabilities to common classes of exploits by external tools and contracted security professionals.
– ARI configures SELinux on its production servers. Specific details of this configuration is confidential; essentially any compromised application is extremely limited in what it can do.
– Monitoring is used to detect security incidents at all layers of the security model. Specifically:
 – Network Intrusion Detection systems are employed to monitor ARI networks for suspicious traffic.
 – ARI maintains its own host-based Intrusion Detection system based on tripwire, which has now undergone four years of development. Specific details are confidential, but in summary, the system can detect any unusual activity with respect to configuration, program files, program processes, users, or network traffic.
 – More generic monitoring systems are used as indicators of security incidents. Any behaviour outside the norm across over 1,100 individual application, database, systems, network and environmental checks is investigated.
– Capacity management components of the monitoring suite are also used to detect and classify security incidents. Some examples are:
 – Network traffic counts, packet counts and specific application query counts.
 – Long term trend data on network traffic vs. specific incident windows.
 – CPU, Storage, Memory and Process monitors on servers.
– A second layer of hardware firewalling separates application and middle tier servers from database servers.
– Applications only have as much access to database information as is required to perform their function.
– Finally, database servers have their own security standards, including server-based firewalls, vulnerability management for operating system and RDBMS software, and encryption of critical data.

2.1 Physical Security Infrastructure
ARI maintains a series of physical security infrastructure measures including but not limited to biometric and physical key access control to secured areas and security camera recording, alarm systems and monitoring.

3 COMMITMENTS TO REGISTRANTS

We commit to the following:
– Safeguarding the confidentiality, integrity and availability of registrant’s data.
– Compliance with the relevant regulation and legislation with respect to privacy.
– Working with law enforcement where appropriate in response to illegal activity or at the request of law enforcement agencies.
– Maintaining a best practice information security management system that continues to be ISO27001-compliant.
– Validating requests from external parties requesting data or changes to the registry to ensure the identity of these parties and that their request is appropriate. This includes requests from ICANN.
– That access to DNS and contact administrative facilities requires multi-factor authentication by the Registrar on behalf of the registrant.– That Registry data cannot be manipulated in any fashion other than those permitted to authenticated Registrars using the EPP or the SRS web interface. Authenticated Registrars can only access Registry data of domain names sponsored by them.
– A Domain transfer can only be done by utilizing the AUTH CODE provided to the Domain Registrant.
– Those emergency procedures are in place and tested to respond to extraordinary events affecting the integrity, confidentiality or availability of data within the registry.

4 AUGMENTED LEVEL OF SECURITY

This TLD is a SRSU TLD (.brand style) and as such requires security considerations that are commensurate with its purpose. Our goal with this TLD is to use the TLD internally and adequate protect it against unauthorized registrations or modifications to the namespace, without making the internal process too onerous and thus increasing costs. Whilst, due to the SRSU nature, it is relatively straightforward to restrict and enforce restrictions on registrations, the impact of an unauthorised registration can be high, potentially damaging.
The following attributes describe the security with respect to the TLD:
– ARI, follows the highest security standards with respect to its Registry Operations. ARI is ISO 27001 certified and has been in the business of providing a Registry backend for 10 years. ARI have confirmed their adherence to all of the security standards as described in this application. As per recommendation 24 this ensures that the technical implementations do not compromise elevated security standards
– A single Registrar will be nominated for this TLD, facilitating the tightest possible control over Registrant validity enforcement and domain registration restrictions.
– Registrant will only be permitted to make changes to their domain name after a authenticating to their Registrar.
– Registrants will only be able to access all interfaces for domain registration and management via HTTPS. A reputed digital certificate vendor will provide the SSL certificate of the secure site.
– Registrar identity will be manually verified before they are accredited within this TLD. This will include verification of corporate identity, identity of individuals involved ⁄ mentioned, and verification of contact information
– Registrars will only be permitted to connect with the SRS via EPP after a multi-factor authentication that validates their digital identity. This is described further ahead.
– Registrars will only be permitted to use a certificate signed by ARI to connect with the Registry systems. Self-signed certificates will not be permitted.
– The Registry is DNSSEC enabled and the TLD zone will be DNSSEC enabled. This is described in detail in our response to question 43. The following additional requirements will exist for Registrars who want to get accredited to sell this TLD:
 – Registrars must support DNSSEC capabilities within its control panels.
 – If the Registrar provides Managed DNS services to Registrants within this TLD they must provide DNSSEC for the same. This ensures that DNSSEC is deployed at each zone and subsequent sub-zones at Registry, Registrar and Registrant level as per recommendation 26.
– Registrar access to all Registry Systems will be via TLS and secured with multi-factor authentication as per recommendation 27. This is described in detail in our responses to Question 24 and Question 25.
– Registrant access to all Registrar and Registry Systems will be via TLS and secured with multi-factor authentication as per recommendation 28. This is described in detail in our response to Question 25, Question 27 and Question 29.
 – All communication between the Registrar or the Registrars systems and the registry system is encrypted using at least 128 bit encryption which been designated as ‘Acceptable’ till ‘2031 and beyond’ by NIST Special Publication 800-57. This includes the following communication:
 – Secure websites and control panels provided by the Registrar to the Registrant.
 – Ticketing systems provided by the Registrar to the Registrant.
 – Web and EPP interfaces provided by ARI to the Registrars.
 – Ticketing systems provided by ARI to the Registrar.
 – Any communication between the Registrant, Registrar and Registry that is deemed as critical or contains credentials or sensitive information.
Where these requirements put controls on Registrars these will be enforced through the RRA.

5 RESOURCES

This function will be performed by ARI. The following resources are allocated to performing the tasks required to deliver the services described:
– Executive Management Team (4 staff)
– Production Support Group (27 staff)
ARI has ten years’ experience designing, developing, deploying, securing and operating critical Registry systems, as well as TLD consulting and technology leadership.
As a technology company, ARI’s senior management are technology and methodology leaders in their respective fields who ensure the organisation maintains a focus on technical excellence and hiring, training and staff management.
Executive Management is heavily involved in ensuring security standards are met and that continued review and improvement is constantly undertaken. This includes the:
– Chief Operations Officer
– Chief Technology Officer
A detailed list of the departments, roles and responsibilities in ARI is provided as attachment ‘Q30a – ARI Background & Roles.pdf’. This attachment describes the functions of the above teams and the exact number and nature of staff within.
The number of resources required to design, build, operate and support the SRS does not vary significantly with, and is not linearly proportional to, the number or size of TLDs that ARI provides registry services to.
ARI provides registry backend services to 5 TLDs and has a wealth of experience in estimating the number of resources required to support a registry system.
Based on past experience ARI estimates that the existing staff is adequate to support a registry system that supports in excess of 50M domains. Since this TLD projects 6000 domains, 0,01% of these resources are allocated to this TLD. See attachment ‘Q30a – Registry Scale Estimates & Resource Allocation.xlsx’ for more information.
ARI protects against loss of critical staff by employing multiple people in each role. Staff members have a primary role plus a secondary role for protection against personnel absence. Additionally ARI can scale resources as required. Additional trained resources can be added to any of the above teams with a 2 month lead time.
The Production Support Group is responsible for the deployment and operation of TLD registries. 
The group consists of:
– Production Support Manager (also the ISO)
– Service Desk:
 – 1 Level 1 Support Team Lead
 – 8 Customer Support Representatives (Level 1 support)
 – 1 Level 2 Support Team Lead
 – 4 Registry Specialists (Level 2 support)
– Operations (Level 3 support):
 – 1 Operations Team Lead
 – 2 Systems Administrators
 – 2 Database Administrators
 – 2 Network Engineers
– Implementation:
 – 1 Project Manager
 – 2 Systems Administrators
 – 1 Database Administrators
 – 1 Network Engineers
ARI employs a rigorous hiring process and screening (Police background checks for technical staff and Australian Federal Government ‘Protected’ level security clearances for registry operations staff).