Application number: 1-1253-11362 for Richemont DNS Inc.

Richemont DNS Inc.

Hinterbergstrasse 22
Steinhausen 6312
CH

+41 41 727 2303

+41 41 727 2356

http:⁄⁄www.richemont.com

Ms. Lorna Gradden

Operation Director

+44 207 421 8299

+44 870 011 8187

lorna.gradden.ri@valideus.com

Mr. Guillaume Pahud

Director of Digital Projects, Richemont International SA

+41 227 213 193

+41 227 213 486

guillaume.pahud@richemont.net

Corporation incorporated in Switzerland

Switzerland

Not Available

Richemont DNS is a wholly owned subsidiary of Richemont Holdings AG

N⁄A

ALBERT ERIC KAUFMANN
DIRECTOR
FREDERICK WILLEM MOSTERT
DIRECTOR
JAMES ALAN GRIEVE
DIRECTOR
LUCIANA ROBSON
DIRECTOR

Richemont Holdings AG
Not applicable

JEWELRY

Not Available

As the applied-for gTLD string is not an IDN and is consistent with the requirements of the Applicant Guidebook Section 2.2.1.3.2 (String Requirements), Richemont DNS does not believe there are any known operational or rendering problems concerning the string. This answer is based upon consultation with Richemont DNSʹs selected back-end provider, Neustar, which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, Neustar analyzed the following data:
- ICANN’s Security Stability Advisory Committee (SSAC) entitled Alternative TLD Name Systems and Roots: Conflict, Control and Consequences (SAC009);
- IAB - RFC3696 “Application Techniques for Checking and Transformation of Names”
- Known software issues which Neustar has encountered during the last decade launching new gTLDs;
- Character type and length;
- ICANN supplemental notes to Question 16; and
- ICANN’s presentation during its Costa Rica regional meeting on TLD Universal Acceptance.

Describe the Mission and Purpose of your gTLD

The content of this Answer to Question 18 set forth below which describes the plans for Richemont DNS’s registry constitutes the “purpose” of the registry as that term is used in paragraph 1.b. of Specification 9 of the Draft New gTLD Registry Agreement found in Module 5 of the Richemont DNS Guidebook dated January 11, 2012 (“the Purpose”). Richemont DNS will publish its Charter and its policies, guidelines, and other supporting documentation related to the implementation of the registry consistent with the Purpose, all prior to launch. All second level domain names registered by Richemont DNS on behalf of itself or an affiliate will be registered through an ICANN-accredited registrar and will be consistent with the Purpose. All registrants of second level domain names will be affiliates of Richemont DNS or will be parties operating under a written contractual agreement specifically allowing the registration of a second level domain name within this registry (the “Prerequisite Agreement”).

Over time, jewelry has had many uses: as currency, for functional reasons, to convey symbolism and protection and for artistic display. From earliest times, it has been used to denote status and most cultures have stored their wealth in the form of jewelry. 

According to a 2007 KPMG study, currently the largest jewelry market is the United States with a market share of 30.8%, although by 2015, it is predicted that China and India will increase their market share to over 13%. 

Together with luxury watch making and writing instruments, jewelry is one of the strengths of Compagnie Financière Richemont S.A. (“CFR”), ”), a Swiss luxury goods holding company, which was created in 1988, hence our interest in this term. This application is being made by Richemont DNS Inc.,(referred to herein as “Richemont DNS”), one of CFR’s indirect wholly-owned subsidiaries. The group of companies whose ultimate parent company is CFR are referred to herein collectively as “Richemont”. 

CFR owns several of the worldʹs leading companies, including Cartier and Van Cleef & Arpels, high profile leaders in their field. In 2011, our jewelry Maisons sales totalled €3,479 billion (up from €2,688 billion in 2010) representing 50% of Group sales with an operating profit of €1,062 billion, up from €742 million in 2010. 

Richemont’s luxury businesses operate globally. The largest market is Asia-Pacific, which generates more than 40 per cent of sales. We believe the diversity of our geographical operations, with a lack of dependency on any one market, represents a long-term competitive advantage. 

Richemont directly employs more than 20,000 people worldwide and has employees based in all major regions of the world. Two-thirds of Richemont’s employees are based in Europe, but Asia-Pacific and the Americas are also significant and growing areas of employment. The majority of Richemont’s employees in Europe are based in Switzerland, France, and Germany, where the manufacture of luxury goods is concentrated. Asia and the Far East are growing markets. In all regions, employees are engaged in retail, distribution, after sales service and⁄or administrative functions.

Richemont ‘A’ shares are listed on the SIX Swiss Exchange, Richemont’s primary listing, and are included in the Swiss Market Index (‘SMI’) of leading stocks. Richemont’s South African Depository Receipts are listed in Johannesburg, Richemont’s secondary listing. Richemont is the eighth largest company in the Swiss Market Index and, as of 2007, Richemont was the third-largest luxury goods company in the world by annual revenues. In the 2010⁄2011 financial year, Richemont sales were €6.892 billion, a rise of 33% on the previous year (at actual exchange rates) and our operating profit rose by 63% to €1.355 billion. 

Investments in research, development and innovation extend to watch movements, new product designs and marketing-related activities. The annual accounting charge for research and development costs n this product category is some €20 million.

The .Jewelry registry will be a standard, i.e. not a community-based, restricted registry. Its main purpose will be: 

• To provide a trusted source of good public information to benefit those interested in jewelry and all members of the jewelry industry, thereby counteracting any inaccurate information about jewelry. Richemont has a portfolio of jewelry brands with registered intellectual property rights around the world. Securing the term, .Jewelry will enable Richemont to harmonise its current brand protection policies and to mitigate counterfeiting, a scourge of the luxury goods industry, for governments and consumers alike;

• To provide a platform for the delivery of secure digital material for both industry professionals and consumers; 

• To ensure Richemont remains at the forefront of innovation by keeping pace with internet technology developments; and

• To provide a single, trusted source for the press and governments regarding our jewelry portfolio of businesses, models, and brands.

The success of the .Jewelry registry will be determined by the enhancement in the equity of Richemont’s jewelry making businesses and in terms of the security and stability it brings to our communications with customers, the press, and governments. Since there will be no market in second level domain name registrations in this registry, success will not be measured by the number of second level domain name registrations.

How do you expect that your proposed gTLD will benefit registrants, internet users and others?
The registry will be stringently controlled by authorised Richemont DNS personnel on behalf of the Richemont group of companies but it is predicted that it will also benefit the following stakeholders, all in the global public interest:
• Our customers: whether they are industry professionals or consumers, a new .Jewelry registry will benefit them by becoming a location for authentic, accessible information about the company and our collections. 
• Our employees: a new gTLD will reinforce our brand worldwide and provide a more secure communication channel. 

• Our authorized dealers: a new gTLD will provide our authorized dealer network with a space that sets them apart from counterfeiters and provides them with the direct relation to these specialist jewelry products in the minds of the public.

• Our investors: seeking accurate information regarding our jewelry making operations, management, goods and services.

• Law enforcement seeking information about genuine products.


What is the goal of your proposed gTLD in terms of areas of speciality, service levels 
reputation?
At Richemont, we pride ourselves on the integrity of our group brands and the high quality of our luxury goods. This will be reflected in the treatment of the new gTLD on our jewelers’ behalf. The goal is to position Richemont DNS, on behalf of our specialist jewelers, to exploit this latest internet advance in order to further enhance the Richemont group brands and reputation. We hope that this registry will be regarded by customers, as well as by the investors who follow our group companies, as the authentic location for accurate information on Richemont’s jewelry collections and products.


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

Richemont DNS is eager to operate a registry with shorter domain names that are universally applicable across the globe. We feel it offers clarity, simplicity and will enable our customers to place their trust in our registry while also providing potential for enhanced communication with them and with staff. 

Richemont DNS looks forward to utilising the new registry in conjunction with our current domains and are particularly keen to market under the term .Jewelry in the future if the new gTLD process is a success. This new gTLD also enables us to leave behind complex naming hierarchies inherent in country code extensions. 

Further, we believe that being an early adopter of the new gTLDs will provide us with a reputation as an industry leader. The free market and the Internet has a history of rewarding early adopters of innovations such as web presence (1990’s), social media (2000’s) and we are investing resources in a strategic bet that the new gTLDs will be the premier innovation of the 2010’s. 

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

Richemont hopes that customers and others who visit to communicate with our specialist jewelry brands know they are in a trusted and authentic destination once they arrive at the new gTLD. We want them to be confident that they will receive accurate information, that all products they view will be genuine, and that their sensitive personal details will be protected.

Provide a complete description of the Richemont DNS’s intended registration policies in support of the goals above

Richemont DNS will be the operator of the .Jewelry registry. The Richemont DNS Domain Name Management team will be responsible for the development, maintenance and enforcement of the Richemont DNS Domain Management Policy. This policy will define the rules associated with eligibility and domain name allocation, set out the terms governing the use of a .Jewelry domain name (which require that registrant to be an affiliate of Richemont and⁄or will require the registrant to be a party to a Prerequisite Agreement) and describe the dispute resolution policies for the Jewelry gTLD. This policy is intended to be updated and revised regularly to reflect Richemont’s commercial and strategic interests and, where appropriate, ICANN consensus policies as they are developed. 
Registration of a .Jewelry domain name will be undertaken in four steps: Eligibility Confirmation, Naming Convention Check, Acceptable Use Review, and finally Registration. All domains in the .Jewelry registry will remain the property of Richemont DNS.
Each applied for A-label character string must conform to the .Jewelry rules of eligibility. Each .Jewelry name must:
• Be at least 3 characters and no more than 63 characters long 
• Not contain a hyphen on the 3rd and 4th position (except IDNs)
• Contain only letters (a-z), numbers (0-9) and hyphens or a combination of these
• Start and end with an alphanumeric character, not a hyphen
• Not match any character strings reserved by ICANN
• Not match any protected country names or geographical terms 
• Not match the character strings or intellectual property of any other company in sectors where Richemont operates
Internationalized domain names (IDN) may be supported in the .Jewelry registry at the second level. 
Users of .Jewelry names must utilise their domains solely for purposes that enhance Richemont’s strategic or commercial interests. .Jewelry domains may not be used in a way which knowingly infringes any third party intellectual property rights or gives rise to moral or public order questions.
Users of .Jewelry names may not delegate or assign any rights in .Jewelry domains to external organizations, institutions, or individuals.
All .Jewelry domains will carry accurate and up to date registration records.
The Richemont DNS Domain Name Management Team may revoke a .Jewelry domain name at any time in line with the Richemont group’s corporate and strategic interests. Termination of affiliate status and⁄or termination of any Prerequisite Agreement will result in revocation of any corresponding second level domain name registration.
The .Jewelry registry will be ICANN compliant: the registry will interface with the Trademark Clearinghouse, operate a Sunrise and IP Claims and all registrants must comply with the UDRP and the URS and other consensus policies as they are developed.

Will your proposed gTLD impose any measures for protecting the privacy of confidential information of registrants or users?

As a global luxury goods brand with a high profile, we take our responsibility to protect the confidential information of customers and staff very seriously.
 
The .Jewelry registry will continue our policy of protecting confidential information. Richemont DNS will comply with the Personal Data obligations of the ICANN Registry Agreement and all applicable data protection laws as interpreted and applied. As required, approved representatives will be registered as data handlers and trained to ensure compliance with ICANN’s requirements. 

We will:
• Document policies and procedures including an escalation process
• Use appropriate levels of encryption and physical security
• Train key staff and ensure responsibilities are understood and documented in rules of conduct
• Limit access to records only to those employees or service providers who need access for the performance of their job duties
• Test procedures
• Monitor best practice and ICANN’s mandated and recommended policies
• Audit the work of providers including the Escrow provider and checking data.


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

We will produce and publish guidelines for internal use. These are intended to provide clarity on who can apply for a .Jewelry domain and how it is to be used. This is a standard, restricted registry closed to third parties so these guidelines should ensure that .Jewelry domains are used in accordance with Richemont’s objectives by authorised Richemont DNS representatives. For example, it will be necessary to create a home page for the registry using straightforward messaging for the benefit of internal users so that our policies and the rules of eligibility are clearly understood.

What operating rules will you adopt to eliminate or minimize social costs (e.g. time or financial resource costs as well as various types of consumer vulnerabilities)? What other steps will you take to minimize negative consequences⁄costs imposed upon consumers?

As previously stated, the .Jewelry registry will be a standard, restricted registry closed to third parties for use only by pre-validated representatives of Richemont who are parties to an existing Prerequisite Agreement or appropriate affiliates of Richemont group companies. Social costs and negative consequences on domain name customers will therefore be minimised and possibly even eliminated. It is not intended that .Jewelry domains will be made available to anyone beyond Richemont or Richemont DNS. It could be that we will use .Jewelry domains to promote recognition of our affiliated network of authorized dealers in time but again Richemont DNS will be in control.

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

We have no plans to sell .Jewelry domains. We are applying to protect and enhance our position as a leading creator of jewelry of the highest quality. There will be no market in .Jewelry domains. Therefore we will not receive multiple applications for a particular domain and so there will be no need for any resolution. We will control eligibility very strictly.

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

We plan to register all .Jewelry domain names to Richemont group companies or Richemont DNS. Although we anticipate that our affiliated network of authorized dealers will benefit from the .Jewelry registry in terms of heightened profile, we do not see the need to devise cost benefits for registrants because we will be the registrant.

iii. The Registry Agreement requires that registrars be offered the option to obtain initial domain name registrations for periods of one to ten years at the discretion of the registrar, but no greater than 10 years. Additionally the Registry Agreement requires advance written notice of price increases. Do you intend to make contractual commitments to registrants regarding the magnitude of price escalation?

While we will comply with all ICANN consensus policies, the term of registration is the choice of the registrant of a second level domain name, not the choice of a registrar. The Richemont DNS Domain Name Management Team will set the period of registration for .Jewelry domains. We are applying for .Jewelry to support Richemont’s strategic goals and to protect Richemont’s IP not to generate revenues from selling domains. Therefore there will be no need to make contractual commitments, nor to consider issues around pricing including price escalation, though we will comply with the provisions of Section 2.10 of the Registry Agreement.

Before launching this TLD, Richemont DNS will develop and publish its Charter, policies and guidelines, setting out full details of how the registry will implement its vision and purpose as set out in this answer. Richemont DNS, on behalf of Richemont, may adapt its policies and proposed use of the gTLD, in a manner consistent with the Purpose, to reflect changes in its business and the adoption of new gTLDs by the community. 

No

Not Available

No

Richemont DNS is committed to running .Jewelry in full compliance with all applicable laws, consensus policies, best practice guidelines, RFCs and the Specifications of the Registry Agreement. Richemont DNS therefore commits that it will follow GAC advice and Specification 5 and block from initial registration those country and territory names contained in the following lists:

1. The short form (in English) of all country and territory names contained on the ISO 3166- 1 list, as updated from time to time, including the European Union; and
2. The United Nations Group of Experts on Geographical Names, Technical Reference Manual for the Standardization of Geographical Names, Part III Names of Countries of the World; and 
3. The list of United Nations member states in 6 official United Nations languages prepared by the Working Group on Country Names of the United Nations Conference on the Standardization of Geographical Names.

The process for reserving these names, and hence blocking them from registration, will be agreed with our technical service provider Neustar, who has committed to supporting this process. 

Because .Jewelry is a single entity registry, with all domains being held in the ownership of Richemont DNS, and for purposes which serve Richemont DNS’s strategic business aims, the reserved names cannot be offered to Governments or other official bodies for their own use as this would conflict with the Mission and Purpose of the TLD. For the same reason, they will not be offered to third parties. It is possible that at some future time limited use may be allowed to help Governments advertise their local anti-counterfeiting initiatives, but at the moment such plans are not finalized. Any decision to do so would be in coordination with such Governments. Reserved names will not be offered to third parties under any other circumstances.

We envisage that over time, there will be demand from brand TLDs leading to the development of a standardised process for requesting GAC review and ICANN approval for the release of country and territory names for registration by the Registry Operator when the registry is a single entity registry. When such a process is in place, Richemont DNS expects to apply for the release of country and territory names within .Jewelry .At this time Richemont DNS will develop a process to permit government, public authorities or other relevant bodies to challenge any use of a name which they perceive to be abusive.

23.1 Introduction 

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

IDN registrations are provided in full compliance with the IDNA protocol. Neustar possesses extensive experience offering IDN registrations in numerous TLDs, and its IDN implementation uses advanced technology to accommodate the unique bundling needs of certain languages. Character mappings are easily constructed to block out characters that may be deemed as confusing to users. A detailed description of the IDN implementation is presented in response to Question 44.
23.3 Unique Services 
Richemont DNS will not be offering services that are unique to .Jewelry.
23.4 Security or Stability Concerns 
All services offered are standard registry services that have no known security or stability concerns. Neustar has demonstrated a strong track record of security and stability within the industry. 
 

24.1 Introduction
Richemont DNS has partnered with Neustar Inc., an experienced TLD registry operator, for the operation of the .Jewelry Registry. Richemont DNS is confident that the plan in place for the operation of a robust and reliable Shared Registration System (SRS) as currently provided by Neustar will satisfy the criterion established by ICANN.
Neustar built its SRS from the ground up as an EPP based platform and has been operating it reliably and at scale since 2001. The software currently provides registry services to five TLDs (.BIZ, .US, TEL, .CO and .TRAVEL) and is used to provide gateway services to the .CN and .TW registries. Neustar’s state of the art registry has a proven track record of being secure, stable, and robust. It manages more than 6 million domains, and has over 300 registrars connected today. 
The following describes a detailed plan for a robust and reliable SRS that meets all ICANN requirements including compliance with Specifications 6 and 10.
24.2 The Plan for Operation of a Robust and Reliable SRS
High-level SRS System Description
 The SRS to be used for .Jewelry will leverage a production-proven, standards-based, highly reliable and high-performance domain name registration and management system that fully meets or exceeds the requirements as identified in the new gTLD Application Guidebook. 
The SRS is the central component of any registry implementation and its quality, reliability and capabilities are essential to the overall stability of the TLD. Neustar has a documented history of deploying SRS implementations with proven and verifiable performance, reliability and availability. The SRS adheres to all industry standards and protocols. By leveraging an existing SRS platform, Richemont DNS is mitigating the significant risks and costs associated with the development of a new system. Highlights of the SRS include:
 State-of-the-art, production proven multi-layer design
 Ability to rapidly and easily scale from low to high volume as a TLD grows
 Fully redundant architecture at two sites
 Support for IDN registrations in compliance with all standards 
 Use by over 300 Registrars
 EPP connectivity over IPv6
 Performance being measured using 100% of all production transactions (not sampling).
 
SRS Systems, Software, Hardware, and Interoperability 
The systems and software that the registry operates on are a critical element to providing a high quality of service. If the systems are of poor quality, if they are difficult to maintain and operate, or if the registry personnel are unfamiliar with them, the registry will be prone to outages. Neustar has a decade of experience operating registry infrastructure to extremely high service level requirements. The infrastructure is designed using best of breed systems and software. Much of the application software that performs registry-specific operations was developed by the current engineering team and a result the team is intimately familiar with its operations.
 The architecture is highly scalable and provides the same high level of availability and performance as volumes increase. It combines load balancing technology with scalable server technology to provide a cost effective and efficient method for scaling.
The Registry is able to limit the ability of any one registrar from adversely impacting other registrars by consuming too many resources due to excessive EPP transactions. The system uses network layer 2 level packet shaping to limit the number of simultaneous connections registrars can open to the protocol layer.
All interaction with the Registry is recorded in log files. Log files are generated at each layer of the system. These log files record at a minimum:
 The IP address of the client
 Timestamp
 Transaction Details
 Processing Time.
In addition to logging of each and every transaction with the SRS Neustar maintains audit records, in the database, of all transformational transactions. These audit records allow the Registry, in support of Richemont DNS, to produce a complete history of changes for any domain name.
SRS Design
The SRS incorporates a multi-layer architecture that is designed to mitigate risks and easily scale as volumes increase. The three layers of the SRS are:
 Protocol Layer
 Business Policy Layer
 Database. 
Each of the layers is described below. 
Protocol Layer
The first layer is the protocol layer, which includes the EPP interface to registrars. It consists of a high availability farm of load-balanced EPP servers. The servers are designed to be fast processors of transactions. The servers perform basic validations and then feed information to the business policy engines as described below. The protocol layer is horizontally scalable as dictated by volume.
The EPP servers authenticate against a series of security controls before granting service, as follows:
 The registrar’s host exchanges keys to initiates a TLS handshake session with the EPP server.
 The registrar’s host must provide credentials to determine proper access levels.
 The registrar’s IP address must be preregistered in the network firewalls and traffic-shapers.
Business Policy Layer 
The Business Policy Layer is the “brain” of the registry system. Within this layer, the policy engine servers perform rules-based processing as defined through configurable attributes. This process takes individual transactions, applies various validation and policy rules, persists data and dispatches notification through the central database in order to publish to various external systems. External systems fed by the Business Policy Layer include backend processes such as dynamic update of DNS, WHOIS and Billing. 
Similar to the EPP protocol farm, the SRS consists of a farm of application servers within this layer. This design ensures that there is sufficient capacity to process every transaction in a manner that meets or exceeds all service level requirements. Some registries couple the business logic layer directly in the protocol layer or within the database. This architecture limits the ability to scale the registry. Using a decoupled architecture enables the load to be distributed among farms of inexpensive servers that can be scaled up or down as demand changes.
The SRS today processes over 30 million EPP transactions daily. 
Database
The database is the third core components of the SRS. The primary function of the SRS database is to provide highly reliable, persistent storage for all registry information required for domain registration services. The database is highly secure, with access limited to transactions from authenticated registrars, trusted application-server processes, and highly restricted access by the registry database administrators. A full description of the database can be found in response to Question 33.
Figure 24-1 depicts the overall SRS architecture including network components.

  
Number of Servers
As depicted in the SRS architecture diagram above Neustar operates a high availability architecture where at each level of the stack there are no single points of failures. Each of the network level devices run with dual pairs as do the databases. For the .Jewelry registry, the SRS will operate with 8 protocol servers and 6 policy engine servers. These expand horizontally as volume increases due to additional TLDs, increased load, and through organic growth. In addition to the SRS servers described above, there are multiple backend servers for services such as DNS and WHOIS. These are discussed in detail within those respective response sections. 
Description of Interconnectivity with Other Registry Systems
The core SRS service interfaces with other external systems via Neustar’s external systems layer. The services that the SRS interfaces with include:
 WHOIS 
 DNS 
 Billing
 Data Warehouse (Reporting and Data Escrow). 
Other external interfaces may be deployed to meet the unique needs of a TLD. At this time there are no additional interfaces planned for .Jewelry.
 The SRS includes an “external notifier” concept in its business policy engine as a message dispatcher. This design allows time-consuming backend processing to be decoupled from critical online registrar transactions. Using an external notifier solution, the registry can utilize “control levers” that allow it to tune or to disable processes to ensure optimal performance at all times. For example, during the early minutes of a TLD launch, when unusually high volumes of transactions are expected, the registry can elect to suspend processing of one or more back end systems in order to ensure that greater processing power is available to handle the increased load requirements. This proven architecture has been used with numerous TLD launches, some of which have involved the processing of over tens of millions of transactions in the opening hours. The following are the standard three external notifiers used the SRS: 
WHOIS External Notifier
The WHOIS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on WHOIS. It is important to note that, while the WHOIS external notifier feeds the WHOIS system, it intentionally does not have visibility into the actual contents of the WHOIS system. The WHOIS external notifier serves just as a tool to send a signal to the WHOIS system that a change is ready to occur. The WHOIS system possesses the intelligence and data visibility to know exactly what needs to change in WHOIS. See response to Question 26 for greater detail.
DNS External Notifier
The DNS external notifier dispatches a work item for any EPP transaction that may potentially have an impact on DNS. Like the WHOIS external notifier, the DNS external notifier does not have visibility into the actual contents of the DNS zones. The work items that are generated by the notifier indicate to the dynamic DNS update sub-system that a change occurred that may impact DNS. That DNS system has the ability to decide what actual changes must be propagated out to the DNS constellation. See response to Question 35 for greater detail.
Billing External Notifier
The billing external notifier is responsible for sending all billable transactions to the downstream financial systems for billing and collection. This external notifier contains the necessary logic to determine what types of transactions are billable. The financial systems use this information to apply appropriate debits and credits based on registrar.
Data Warehouse
The data warehouse is responsible for managing reporting services, including registrar reports, business intelligence dashboards, and the processing of data escrow files. The Reporting Database is used to create both internal and external reports, primarily to support registrar billing and contractual reporting requirement. The data warehouse databases are updated on a daily basis with full copies of the production SRS data. 
Frequency of Synchronization between Servers
The external notifiers discussed above perform updates in near real-time, well within the prescribed service level requirements. As transactions from registrars update the core SRS, update notifications are pushed to the external systems such as DNS and WHOIS. These updates are typically live in the external system within 2-3 minutes.
Synchronization Scheme (e.g., hot standby, cold standby) 
Neustar operates two hot databases within the data center that is operating in primary mode. These two databases are kept in sync via synchronous replication. Additionally, there are two databases in the secondary data center. These databases are updated real time through asynchronous replication. This model allows for high performance while also ensuring protection of data. See response to Question 33 for greater detail. 
Compliance with Specification 6 Section 1.2
The SRS implementation for .Jewelry is fully compliant with Specification 6, including section 1.2. EPP Standards are described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. Extensible Provisioning Protocol or EPP is defined by a core set of RFCs that standardize the interface that make up the registry-registrar model. The SRS interface supports EPP 1.0 as defined in the following RFCs shown in Table 24-1. 
 
Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.
Compliance with Specification 10
Specification 10 of the New TLD Agreement defines the performance specifications of the TLD, including service level requirements related to DNS, RDDS (WHOIS), and EPP. The requirements include both availability and transaction response time measurements. As an experienced registry operator, Neustar has a long and verifiable track record of providing registry services that consistently exceed the performance specifications stipulated in ICANN agreements. This same high level of service will be provided for the .Jewelry Registry. The following section describes Neustar’s experience and its capabilities to meet the requirements in the new agreement.
To properly measure the technical performance and progress of TLDs, Neustar collects data on key essential operating metrics. These measurements are key indicators of the performance and health of the registry. Neustar’s current .biz SLA commitments are among the most stringent in the industry today, and exceed the requirements for new TLDs. Table 24-2 compares the current SRS performance levels compared to the requirements for new TLDs, and clearly demonstrates the ability of the SRS to exceed those requirements.
 
Their ability to commit and meet such high performance standards is a direct result of their philosophy towards operational excellence. See response to Question 31 for a full description of their philosophy for building and managing for performance.
24.3 Resourcing Plans 
The development, customization, and on-going support of the SRS are the responsibility of a combination of technical and operational teams, including:
 Development⁄Engineering
 Database Administration
 Systems Administration
 Network Engineering.
Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will be involved in the design and testing. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably.
The necessary resources will be pulled from the pool of operational resources described in detail in the response to Question 31. Neustar’s SRS implementation is very mature, and has been in production for over 10 years. As such, very little new development related to the SRS will be required for the implementation of the .Jewelry registry. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Database Administration- 10 employees
Systems Administration – 24 employees
Network Engineering – 5 employees
The resources are more than adequate to support the SRS needs of all the TLDs operated by Neustar, including the .Jewelry registry. 
 

25.1 Introduction
Richemont DNS’s back-end registry operator, Neustar, has over 10 years of experience operating EPP based registries. They deployed one of the first EPP registries in 2001 with the launch of .biz. In 2004, they were the first gTLD to implement EPP 1.0. Over the last ten years Neustar has implemented numerous extensions to meet various unique TLD requirements. Neustar will leverage its extensive experience to ensure Richemont DNS is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .Jewelry registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1.
 
25.2 EPP Interface
Registrars are provided with two different interfaces for interacting with the registry. Both are EPP based, and both contain all the functionality necessary to provision and manage domain names. The primary mechanism is an EPP interface to connect directly with the registry. This is the interface registrars will use for most of their interactions with the registry. 
However, an alternative web GUI (Registry Administration Tool) that can also be used to perform EPP transactions will be provided. The primary use of the Registry Administration Tool is for performing administrative or customer support tasks. 
The main features of the EPP implementation are: 
 Standards Compliance: The EPP XML interface is compliant to the EPP RFCs. As future EPP RFCs are published or existing RFCs are updated, Neustar makes changes to the implementation keeping in mind of any backward compatibility issues.
 Scalability: The system is deployed keeping in mind that it may be required to grow and shrink the footprint of the Registry system for a particular TLD. 
 Fault-tolerance: The EPP servers are deployed in two geographically separate data centers to provide for quick failover capability in case of a major outage in a particular data center. The EPP servers adhere to strict availability requirements defined in the SLAs.
 Configurability: The EPP extensions are built in a way that they can be easily configured to turn on or off for a particular TLD.
 Extensibility: The software is built ground up using object oriented design. This allows for easy extensibility of the software without risking the possibility of the change rippling through the whole application. 
 Auditable: The system stores detailed information about EPP transactions from provisioning to DNS and WHOIS publishing. In case of a dispute regarding a name registration, the Registry can provide comprehensive audit information on EPP transactions.
 Security: The system provides IP address based access control, client credential-based authorization test, digital certificate exchange, and connection limiting to the protocol layer. 

25.3 Compliance with RFCs and Specifications
The registry-registrar model is described and embodied in a number of IETF RFCs, ICANN contracts and practices, and registry-registrar agreements. As shown in Table 25-1, EPP is defined by the core set of RFCs that standardize the interface that registrars use to provision domains with the SRS. As a core component of the SRS architecture, the implementation is fully compliant with all EPP RFCs. 
 

Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to EPP. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

Neustar has a long history of providing exceptional service that exceeds all performance specifications. The SRS and EPP interface have been designed to exceed the EPP specifications defined in Specification 10 of the Registry Agreement and profiled in Table 25-2. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

 
EPP Toolkits
Toolkits, under open source licensing, are freely provided to registrars for interfacing with the SRS. Both Java and C++ toolkits will be provided, along with the accompanying documentation. The Registrar Tool Kit (RTK) is a software development kit (SDK) that supports the development of a registrar software system for registering domain names in the registry using EPP. The SDK consists of software and documentation as described below.
The software consists of working Java and C++ EPP common APIs and samples that implement the EPP core functions and EPP extensions used to communicate between the registry and registrar. The RTK illustrates how XML requests (registration events) can be assembled and forwarded to the registry for processing. The software provides the registrar with the basis for a reference implementation that conforms to the EPP registry-registrar protocol. The software component of the SDK also includes XML schema definition files for all Registry EPP objects and EPP object extensions. The RTK also includes a “dummy” server to aid in the testing of EPP clients.
The accompanying documentation describes the EPP software package hierarchy, the object data model, and the defined objects and methods (including calling parameter lists and expected response behavior). New versions of the RTK are made available from time to time to provide support for additional features as they become available and support for other platforms and languages.

25.4 Proprietary EPP Extensions
 
The .Jewelry registry will not include proprietary EPP extensions. Neustar has implemented various EPP extensions for both internal and external use in other TLD registries. These extensions use the standard EPP extension framework described in RFC 5730. Table 25-3 provides a list of extensions developed for other TLDs. Should the .Jewelry registry require an EPP extension at some point in the future, the extension will be implemented in compliance with all RFC specifications including RFC 3735.
 

The full EPP schema to be used in the .Jewelry registry is attached in the document titled “EPP Schema.”

25.5 Resourcing Plans
The development and support of EPP is largely the responsibility of the Development⁄Engineering and Quality Assurance teams. As an experience registry operator with a fully developed EPP solution, on-going support is largely limited to periodic updates to the standard and the implementation of TLD specific extensions.
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Quality Assurance - 7 employees.
These resources are more than adequate to support any EPP modification needs of the .Jewelry registry.

 

26.1 Introduction
Richemont DNS recognizes the importance of an accurate, reliable, and up-to-date WHOIS database to governments, law enforcement, intellectual property holders and the public as a whole and is firmly committed to complying with all of the applicable WHOIS specifications for data objects, bulk access, and lookups as defined in Specifications 4 and 10 to the Registry Agreement. Richemont DNS’s back-end registry services provider, Neustar, has extensive experience providing ICANN and RFC-compliant WHOIS services for each of the TLDs that it operates both as a Registry Operator for gTLDs, ccTLDs and back-end registry services provider. As one of the first “thick” registry operators in the gTLD space, Neustar’s WHOIS service has been designed from the ground up to display as much information as required by a TLD and respond to a very stringent availability and performance requirement.
Some of the key features of .Jewelry’s solution include: 
 Fully compliant with all relevant RFCs including 3912
 Production proven, highly flexible, and scalable with a track record of 100% availability over the past 10 years
 Exceeds current and proposed performance specifications 
 Supports dynamic updates with the capability of doing bulk updates 
 Geographically distributed sites to provide greater stability and performance
 In addition, .Jewelry’s thick-WHOIS solution also provides for additional search capabilities and mechanisms to mitigate potential forms of abuse as discussed below. (e.g., IDN, registrant data).
26.2 Software Components
The WHOIS architecture comprises the following components:
 An in-memory database local to each WHOIS node: To provide for the performance needs, the WHOIS data is served from an in-memory database indexed by searchable keys. 
 Redundant servers: To provide for redundancy, the WHOIS updates are propagated to a cluster of WHOIS servers that maintain an independent copy of the database. 
 Attack resistant: To ensure that the WHOIS system cannot be abused using malicious queries or DOS attacks, the WHOIS server is only allowed to query the local database and rate limits on queries based on IPs and IP ranges can be readily applied.
 Accuracy auditor: To ensure the accuracy of the information served by the WHOIS servers, a daily audit is done between the SRS information and the WHOIS responses for the domain names which are updated during the last 24-hour period. Any discrepancies are resolved proactively.
 Modular design: The WHOIS system allows for filtering and translation of data elements between the SRS and the WHOIS database to allow for customizations.
 Scalable architecture: The WHOIS system is scalable and has a very small footprint. Depending on the query volume, the deployment size can grow and shrink quickly.
 Flexible: It is flexible enough to accommodate thin, thick, or modified thick models and can accommodate any future ICANN policy, such as different information display levels based on user categorization.
 SRS master database: The SRS database is the main persistent store of the Registry information. The Update Agent computes what WHOIS updates need to be pushed out. A publish-subscribe mechanism then takes these incremental updates and pushes to all the WHOIS slaves that answer queries.
26.3 Compliance with RFC and Specifications 4 and 10
Neustar has been running thick-WHOIS Services for over 10+ years in full compliance with RFC 3912 and with Specifications 4 and 10 of the Registry Agreement.RFC 3912 is a simple text based protocol over TCP that describes the interaction between the server and client on port 43. Neustar built a home-grown solution for this service. It processes millions of WHOIS queries per day.
Table 26-1 describes Neustar’s compliance with Specifications 4 and 10.
 

Neustar ensures compliance with all RFCs through a variety of processes and procedures. Members from the engineering and standards teams actively monitor and participate in the development of RFCs that impact the registry services, including those related to WHOIS. When new RFCs are introduced or existing ones are updated, the team performs a full compliance review of each system impacted by the change. Furthermore, all code releases include a full regression test that includes specific test cases to verify RFC compliance.

26.4 High-level WHOIS System Description
26.4.1 WHOIS Service (port 43)
The WHOIS service is responsible for handling port 43 queries. Our WHOIS is optimized for speed using an in-memory database and master-slave architecture between the SRS and WHOIS slaves.
The WHOIS service also has built-in support for IDN. If the domain name being queried is an IDN, the returned results include the language of the domain name, the domain name’s UTF-8 encoded representation along with the Unicode code page.
26.4.2 Web Page for WHOIS queries
In addition to the WHOIS Service on port 43, Neustar provides a web based WHOIS application (www.whois.jewelry). It is an intuitive and easy to use application for the general public to use. WHOIS web application provides all of the features available in the port 43 WHOIS. This includes full and partial search on:
 Domain names
 Nameservers
 Registrant, Technical and Administrative Contacts
 Registrars
It also provides features not available on the port 43 service. These include:
1. Redemption Grace Period calculation: Based on the registry’s policy, domains in pendingDelete can be restorable or scheduled for release depending on the date⁄time the domain went into pendingDelete. For these domains, the web based WHOIS displays “Restorable” or “Scheduled for Release” to clearly show this additional status to the user.
2. Extensive support for international domain names (IDN)
3. Ability to perform WHOIS lookups on the actual Unicode IDN
4. Display of the actual Unicode IDN in addition to the ACE-encoded name
5. A Unicode to Punycode and Punycode to Unicode translator
6. An extensive FAQ
7. A list of upcoming domain deletions
26.5 IT and Infrastructure Resources
As described above the WHOIS architecture uses a workflow that decouples the update process from the SRS. This ensures SRS performance is not adversely affected by the load requirements of dynamic updates. It is also decoupled from the WHOIS lookup agent to ensure the WHOIS service is always available and performing well for users. Each of Neustar’s geographically diverse WHOIS sites use:
 Firewalls, to protect this sensitive data 
 Dedicated servers for MQ Series, to ensure guaranteed delivery of WHOIS updates 
 Packetshaper for source IP address-based bandwidth limiting 
 Load balancers to distribute query load 
 Multiple WHOIS servers for maximizing the performance of WHOIS service.
The WHOIS service uses HP BL 460C servers, each with 2 X Quad Core CPU and a 64GB of RAM. The existing infrastructure has 6 servers, but is designed to be easily scaled with additional servers should it be needed.
Figure 26-1 depicts the different components of the WHOIS architecture.

 
26.6 Interconnectivity with Other Registry System
As described in Question 24 about the SRS and further in response to Question 31, “Technical Overview”, when an update is made by a registrar that impacts WHOIS data, a trigger is sent to the WHOIS system by the external notifier layer. The update agent processes these updates, transforms the data if necessary and then uses messaging oriented middleware to publish all updates to each WHOIS slave. The local update agent accepts the update and applies it to the local in-memory database. A separate auditor compares the data in WHOIS and the SRS daily and monthly to ensure accuracy of the published data.
26.7 Frequency of Synchronization between Servers
Updates from the SRS, through the external notifiers, to the constellation of independent WHOIS slaves happens in real-time via an asynchronous publish⁄subscribe messaging architecture. The updates are guaranteed to be updated in each slave within the required SLA of 95% ≤ 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95% ≤ 15 minutes) of .BIZ. The vast majority of updates tend to happen within 2-3 minutes.
26.8 Provision for Searchable WHOIS Capabilities
Neustar will create a new web-based service to address the new search features based on requirements specified in Specification 4 Section 1.8. The application will enable users to search the WHOIS directory using any one or more of the following fields: 
 Domain name
 Registrar ID
 Contacts and registrant’s name
 Contact and registrant’s postal address, including all the sub-fields described in EPP (e.g., street, city, state or province, etc.)
 Name server name and name server IP address
 The system will also allow search using non-Latin character sets which are compliant with IDNA specification.
The user will choose one or more search criteria, combine them by Boolean operators (AND, OR, NOT) and provide partial or exact match regular expressions for each of the criterion name-value pairs. The domain names matching the search criteria will be returned to the user.
Figure 26-2 shows an architectural depiction of the new service. 

 


Potential Forms of Abuse
 As recognized by the Terms of Reference for Whois Misuse Studies, http:⁄⁄gnso.icann.org⁄issues⁄whois⁄tor-whois-misuse-studies-25sep09-en.pdf, a number of reported and recorded harmful acts, such as spam, phishing, identity theft, and stalking which Registrants believe were sent using WHOIS contact information. Although these Whois studies are still underway, there is a general belief that public access to Whois data may lead to a measurable degree of misuse – that is, to actions that cause actual harm, are illegal or illegitimate, or otherwise contrary to the stated legitimate purpose. One of the other key focuses of these studies will be to correlate the reported incidents of harmful acts with anti-harvesting measures that some Registrars and Registries apply to WHOIS queries (e.g., rate limiting, CAPTCHA, etc.). 

Neustar firmly believes that adding the increased search capabilities, without appropriate controls could exacerbate the potential abuses associated with the Whois service. To mitigate the risk of this powerful search service being abused by unscrupulous data miners, a layer of security will be built around the query engine which will allow the registry to identify rogue activities and then take appropriate measures. Potential abuses include, but are not limited to:
• Data Mining
• Unauthorized Access
• Excessive Querying
• Denial of Service Attacks
To mitigate the abuses noted above, Neustar will implement any or all of these mechanisms as appropriate:
 Username-password based authentication 
 Certificate based authentication
 Data encryption
 CAPTCHA mechanism to prevent robo invocation of Web query
 Fee-based advanced query capabilities for premium customers.
The searchable WHOIS application will adhere to all privacy laws and policies of the .Jewelry registry.
26.9 Resourcing Plans 
As with the SRS, the development, customization, and on-going support of the WHOIS service is the responsibility of a combination of technical and operational teams. The primary groups responsible for managing the service include:
 Development⁄Engineering – 19 employees
 Database Administration – 10 employees
 Systems Administration – 24 employees
 Network Engineering – 5 employees 
Additionally, if customization or modifications are required, the Product Management and Quality Assurance teams will also be involved. Finally, the Network Operations and Information Security play an important role in ensuring the systems involved are operating securely and reliably. The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. Neustar’s WHOIS implementation is very mature, and has been in production for over 10 years. As such, very little new development will be required to support the implementation of the .Jewelry registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .Jewelry registry. 
 

27.1 Registration Life Cycle
Introduction
.Jewelry will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be used for .Jewelry.
Domain Lifecycle - Description
The registry will use the EPP 1.0 standard for provisioning domain names, contacts and hosts. Each domain record is comprised of three registry object types: domain, contacts, and hosts 
Domains, contacts and hosts may be assigned various EPP defined statuses indicating either a particular state or restriction placed on the object. Some statuses may be applied by the Registrar; other statuses may only be applied by the Registry. Statuses are an integral part of the domain lifecycle and serve the dual purpose of indicating the particular state of the domain and indicating any restrictions placed on the domain. The EPP standard defines 17 statuses, however only 14 of these statuses will be used in the .Jewelry registry per the defined .Jewelry business rules.
The following is a brief description of each of the statuses. Server statuses may only be applied by the Registry, and client statuses may be applied by the Registrar.
 OK – Default status applied by the Registry.
 Inactive – Default status applied by the Registry if the domain has less than 2 nameservers.
 PendingCreate – Status applied by the Registry upon processing a successful Create command, and indicates further action is pending. This status will not be used in the .Jewelry registry.
 PendingTransfer – Status applied by the Registry upon processing a successful Transfer request command, and indicates further action is pending.
 PendingDelete – Status applied by the Registry upon processing a successful Delete command that does not result in the immediate deletion of the domain, and indicates further action is pending.
 PendingRenew – Status applied by the Registry upon processing a successful Renew command that does not result in the immediate renewal of the domain, and indicates further action is pending. This status will not be used in the .Jewelry registry.
 PendingUpdate – Status applied by the Registry if an additional action is expected to complete the update, and indicates further action is pending. This status will not be used in the .Jewelry registry.
 Hold – Removes the domain from the DNS zone.
 UpdateProhibited – Prevents the object from being modified by an Update command.
 TransferProhibited – Prevents the object from being transferred to another Registrar by the Transfer command.
 RenewProhibited – Prevents a domain from being renewed by a Renew command.
 DeleteProhibited – Prevents the object from being deleted by a Delete command. 
The lifecycle of a domain begins with the registration of the domain. All registrations must follow the EPP standard, as well as the specific business rules described in the response to Question 18 above. Upon registration a domain will either be in an active or inactive state. Domains in an active state are delegated and have their delegation information published to the zone. Inactive domains either have no delegation information or their delegation information in not published in the zone. Following the initial registration of a domain, one of five actions may occur during its lifecycle:
 Domain may be updated
 Domain may be deleted, either within or after the add-grace period
 Domain may be renewed at anytime during the term
 Domain may be auto-renewed by the Registry
 Domain may be transferred to another registrar. 
Each of these actions may result in a change in domain state. This is described in more detail in the following section. Every domain must eventually be renewed, auto-renewed, transferred, or deleted. A registrar may apply EPP statuses described above to prevent specific actions such as updates, renewals, transfers, or deletions.

27.1.1 Registration States
Domain Lifecycle – Registration States
 As described above the .Jewelry registry will implement a standard domain lifecycle found in most gTLD registries today. There are five possible domain states:
 Active 
 Inactive
 Locked
 Pending Transfer
 Pending Delete.
All domains are always in either an Active or Inactive state, and throughout the course of the lifecycle may also be in a Locked, Pending Transfer, and Pending Delete state. Specific conditions such as applied EPP policies and registry business rules will determine whether a domain can be transitioned between states. Additionally, within each state, domains may be subject to various timed events such as grace periods, and notification periods. 
Active State
The active state is the normal state of a domain and indicates that delegation data has been provided and the delegation information is published in the zone. A domain in an Active state may also be in the Locked or Pending Transfer states.
Inactive State
The Inactive state indicates that a domain has not been delegated or that the delegation data has not been published to the zone. A domain in an Inactive state may also be in the Locked or Pending Transfer states. By default all domain in the Pending Delete state are also in the Inactive state.
Locked State
The Locked state indicates that certain specified EPP transactions may not be performed to the domain. A domain is considered to be in a Locked state if at least one restriction has been placed on the domain; however up to eight restrictions may be applied simultaneously. Domains in the Locked state will also be in the Active or Inactive, and under certain conditions may also be in the Pending Transfer or Pending Delete states.
Pending Transfer State
The Pending Transfer state indicates a condition in which there has been a request to transfer the domain from one registrar to another. The domain is placed in the Pending Transfer state for a period of time to allow the current (losing) registrar to approve (ack) or reject (nack) the transfer request. Registrars may only nack requests for reasons specified in the Inter-Registrar Transfer Policy.
Pending Delete State
The Pending Delete State occurs when a Delete command has been sent to the Registry after the first 5 days (120 hours) of registration. The Pending Delete period is 35-days during which the first 30-days the name enters the Redemption Grace Period (RGP) and the last 5-days guarantee that the domain will be purged from the Registry Database and available to public pool for registration on a first come, first serve basis.
27.1.2 Typical Registration Lifecycle Activities
Domain Creation Process
The creation (registration) of domain names is the fundamental registry operation. All other operations are designed to support or compliment a domain creation. The following steps occur when a domain is created. 
1. Contact objects are created in the SRS database. The same contact object may be used for each contact type, or they may all be different. If the contacts already exist in the database this step may be skipped.
2. Nameservers are created in the SRS database. Nameservers are not required to complete the registration process; however any domain with less than 2 name servers will not be resolvable.
3. The domain is created using the each of the objects created in the previous steps. In addition, the term and any client statuses may be assigned at the time of creation.
The actual number of EPP transactions needed to complete the registration of a domain name can be as few as one and as many as 40. The latter assumes seven distinct contacts and 13 nameservers, with Check and Create commands submitted for each object. 
Update Process
Registry objects may be updated (modified) using the EPP Modify operation. The Update transaction updates the attributes of the object. 
For example, the Update operation on a domain name will only allow the following attributes to be updated:
 Domain statuses
 Registrant ID
 Administrative Contact ID
 Billing Contact ID
 Technical Contact ID
 Nameservers
 AuthInfo
 Additional Registrar provided fields.

The Update operation will not modify the details of the contacts. Rather it may be used to associate a different contact object (using the Contact ID) to the domain name. To update the details of the contact object the Update transaction must be applied to the contact itself. For example, if an existing registrant wished to update the postal address, the Registrar would use the Update command to modify the contact object, and not the domain object. 
Renew Process 
The term of a domain may be extended using the EPP Renew operation. ICANN policy general establishes the maximum term of a domain name to be 10 years, and Neustar recommends not deviating from this policy. A domain may be renewed⁄extended at any point time, even immediately following the initial registration. The only stipulation is that the overall term of the domain name may not exceed 10 years. If a Renew operation is performed with a term value will extend the domain beyond the 10 year limit, the Registry will reject the transaction entirely.
Transfer Process
The EPP Transfer command is used for several domain transfer related operations: 
 Initiate a domain transfer
 Cancel a domain transfer
 Approve a domain transfer
 Reject a domain transfer.
To transfer a domain from one Registrar to another the following process is followed:
4. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.
5. If the AuthInfo code is valid and the domain is not in a status that does not allow transfers the domain is placed into pendingTransfer status
6. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue
7. The domain remains in pendingTransfer status for up to 120 hours, or until the losing (current) Registrar Acks (approves) or Nack (rejects) the transfer request
8. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer
9. The requesting Registrar may cancel the original request up until the transfer has been completed.
A transfer adds an additional year to the term of the domain. In the event that a transfer will cause the domain to exceed the 10 year maximum term, the Registry will add a partial term up to the 10 year limit. Unlike with the Renew operation, the Registry will not reject a transfer operation.
Deletion Process
A domain may be deleted from the SRS using the EPP Delete operation. The Delete operation will result in either the domain being immediately removed from the database or the domain being placed in pendingDelete status. The outcome is dependent on when the domain is deleted. If the domain is deleted within the first five days (120 hours) of registration, the domain is immediately removed from the database. A deletion at any other time will result in the domain being placed in pendingDelete status and entering the Redemption Grace Period (RGP). Additionally, domains that are deleted within five days (120) hours of any billable (add, renew, transfer) transaction may be deleted for credit.
27.1.3 Applicable Time Elements
The following section explains the time elements that are involved. 
Grace Periods
There are six grace periods:
 Add-Delete Grace Period (AGP)
 Renew-Delete Grace Period
 Transfer-Delete Grace Period
 Auto-Renew-Delete Grace Period
 Auto-Renew Grace Period
 Redemption Grace Period (RGP). 
The first four grace periods listed above are designed to provide the Registrar with the ability to cancel a revenue transaction (add, renew, or transfer) within a certain period of time and receive a credit for the original transaction.
The following describes each of these grace periods in detail.
Add-Delete Grace Period 
The APG is associated with the date the Domain was registered. Domains may be deleted for credit during the initial 120 hours of a registration, and the Registrar will receive a billing credit for the original registration. If the domain is deleted during the Add Grace Period, the domain is dropped from the database immediately and a credit is applied to the Registrar’s billing account. 
Renew-Delete Grace Period 
The Renew-Delete Grace Period is associated with the date the Domain was renewed. Domains may be deleted for credit during the 120 hours after a renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly renewed. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP (see below). 
Transfer-Delete Grace Period 
The Transfer-Delete Grace Period is associated with the date the Domain was transferred to another Registrar. Domains may be deleted for credit during the 120 hours after a transfer. It should be noted that domains that are deleted during the renew grace period will be placed into pendingDelete and will enter the RGP. A deletion of domain after a transfer is not the method used to correct a transfer mistake. Domains that have been erroneously transferred or hijacked by another party can be transferred back to the original registrar through various means including contacting the Registry.
Auto-Renew-Delete Grace Period 
The Auto-Renew-Delete Grace Period is associated with the date the Domain was auto-renewed. Domains may be deleted for credit during the 120 hours after an auto-renewal. The grace period is intended to allow Registrars to correct domains that were mistakenly auto-renewed. It should be noted that domains that are deleted during the auto-renew delete grace period will be placed into pendingDelete and will enter the RGP. 
Auto-Renew Grace Period 
The Auto-Renew Grace Period is a special grace period intended to provide registrants with an extra amount of time, beyond the expiration date, to renew their domain name. The grace period lasts for 45 days from the expiration date of the domain name. Registrars are not required to provide registrants with the full 45 days of the period.
Redemption Grace Period 
The RGP is a special grace period that enables Registrars to restore domains that have been inadvertently deleted but are still in pendingDelete status within the Redemption Grace Period. All domains enter the RGP except those deleted during the AGP. 
The RGP period is 30 days, during which time the domain may be restored using the EPP RenewDomain command as described below. Following the 30day RGP period the domain will remain in pendingDelete status for an additional five days, during which time the domain may NOT be restored. The domain is released from the SRS, at the end of the 5 day non-restore period. A restore fee applies and is detailed in the Billing Section. A renewal fee will be automatically applied for any domain past expiration.
Neustar has created a unique restoration process that uses the EPP Renew transaction to restore the domain and fulfill all the reporting obligations required under ICANN policy. The following describes the restoration process.
27.2 State Diagram
Figure 27-1 provides a description of the registration lifecycle. 


 
The different states of the lifecycle are active, inactive, locked, pending transfer, and pending delete. Please refer to section 27.1.1 for detail description of each of these states. The lines between the states represent triggers that transition a domain from one state to another. 

The details of each trigger are described below:
 Create: Registry receives a create domain EPP command.
 WithNS: The domain has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
 WithOutNS: The domain has not met the minimum number of nameservers required by registry policy. The domain will not be in the DNS zone.
 Remove Nameservers: Domainʹs nameserver(s) is removed as part of an update domain EPP command. The total nameserver is below the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
 Add Nameservers: Nameserver(s) has been added to domain as part of an update domain EPP command. The total number of nameservers has met the minimum number of nameservers required by registry policy in order to be published in the DNS zone.
 Delete: Registry receives a delete domain EPP command.
 DeleteAfterGrace: Domain deletion does not fall within the add grace period.
 DeleteWithinAddGrace: Domain deletion falls within add grace period.
 Restore: Domain is restored. Domain goes back to its original state prior to the delete command.
 Transfer: Transfer request EPP command is received.
 Transfer Approve⁄Cancel⁄Reject: Transfer requested is approved or cancel or rejected.
 TransferProhibited: The domain is in clientTransferProhibited and⁄or serverTranferProhibited status. This will cause the transfer request to fail. The domain goes back to its original state.
 DeleteProhibited: The domain is in clientDeleteProhibited and⁄or serverDeleteProhibited status. This will cause the delete command to fail. The domain goes back to its original state.
Note: the locked state is not represented as a distinct state on the diagram as a domain may be in a locked state in combination with any of the other states: inactive, active, pending transfer, or pending delete.
27.2.1 EPP RFC Consistency
As described above, the domain lifecycle is determined by ICANN policy and the EPP RFCs. Neustar has been operating ICANN TLDs for the past 10 years consistent and compliant with all the ICANN policies and related EPP RFCs. 
27.3 Resources
The registration lifecycle and associated business rules are largely determined by policy and business requirements; as such the Product Management and Policy teams will play a critical role in working with Richemont DNS to determine the precise rules that meet the requirements of the TLD. Implementation of the lifecycle rules will be the responsibility of Development⁄Engineering team, with testing performed by the Quality Assurance team. Neustar’s SRS implementation is very flexible and configurable, and in many case development is not required to support business rule changes. 
The .Jewelry registry will be using standard lifecycle rules, and as such no customization is anticipated. However should modifications be required in the future, the necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Development⁄Engineering – 19 employees
Registry Product Management – 4 employees
These resources are more than adequate to support the development needs of all the TLDs operated by Neustar, including the .Jewelry registry. 
 

28.1 Abuse Prevention and Mitigation
Strong abuse prevention of a new gTLD is an important benefit to the Internet community. Richemont DNS and its back-end registry services provider, Neustar, agree that a registry must not only aim for the highest standards of technical and operational competence, but also needs to act as a steward of the space on behalf of the Internet community and ICANN in promoting the public interest. Neustar brings extensive experience establishing and implementing registration policies. This experience will be leveraged to help .Jewelry combat abusive and malicious domain activity within the new gTLD space.
One of those public interest functions for a responsible domain name registry includes working towards the eradication of abusive domain name registrations, including, but not limited to, those resulting from:
 Illegal or fraudulent actions 
 Spam
 Phishing
 Pharming 
 Distribution of malware 
 Fast flux hosting 
 Botnets 
 Distribution of child pornography 
 Online sale or distribution of illegal pharmaceuticals.
More specifically, although traditionally botnets have used Internet Relay Chat (IRC) servers to control registry and the compromised PCs, or bots, for DDoS attacks and the theft of personal information, an increasingly popular technique, known as fast-flux DNS, allows botnets to use a multitude of servers to hide a key host or to create a highly-available control network. This ability to shift the attacker’s infrastructure over a multitude of servers in various countries creates an obstacle for law enforcement and security researchers to mitigate the effects of these botnets. But a point of weakness in this scheme is its dependence on DNS for its translation services. By taking an active role in researching and monitoring these sorts of botnets Richemont DNS partner, Neustar, has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.
Policies and Procedures to Minimize Abusive Registrations
A Registry must have the policies, resources, personnel, and expertise in place to combat such abusive DNS practices. As Richemont DNS’s registry provider, Neustar is at the forefront of the prevention of such abusive practices and has developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.
Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique, even in a private brand registry, should not be entered into lightly. Richemont DNS has an extensive, defined, and documented process for taking the necessary action of removing a domain from the zone when its presence in the zone poses a threat to the security and stability of the infrastructure of the Internet or the registry. 
Abuse Point of Contact 
As required by the Registry Agreement, Richemont DNS will establish and publish on its website a single abuse point of contact responsible for addressing inquiries from law enforcement and the public related to malicious and abusive conduct. Richemont DNS will also provide such information to ICANN prior to the delegation of any domain names in the TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information is kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar, shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices. 

28.2 Policies Regarding Abuse Complaints
One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. Even though .Jewelry will be a single entity registry, with all domains registered to Richemont DNS for use only in pursuit of commercial and strategic goals, strict policies will be established and enforced. These include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. 
Richemont DNS will adopt an Acceptable Use Policy that clearly defines the types of activities that will not be permitted in the TLD and reserves the right of Richemont DNS to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow the Registry where and when appropriate to share information with law enforcement. As there will be no re-sellers in .Jewelry and there will be no market in .Jewelry domains, opportunities for bad faith use are restricted. Below is the Registry’s initial Acceptable Use Policy that we will use in connection with the .Jewelry registry.
It is important to note that .Jewelry will be managed as a single entity registry, whose sole registrants will be internal stakeholders of the Richemont DNS or the Richemont DNS’s affiliates. Therefore, the potential for abusive registrations and other activities that have a negative impact on Internet users is minimal. In the unlikely event that such abuse should occur, Richemont DNS with its registry operator, Neustar, will implement the following policies and processes to manage such activities.
.Jewelry Acceptable Use Policy
This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .Jewelry domain name, either temporarily or permanently, if the domain name is being used in a manner that appears to threaten the stability, integrity or security of the Registry, or any of its registrar partners – and⁄or that may put the safety and security of any registrant or user at risk. The process also allows the Registry to take preventive measures to avoid any such criminal or security threats.
The Acceptable Use Policy may be triggered through a variety of channels, including, among other things, private complaint, public alert, government or enforcement agency outreach, and the on-going monitoring by the Registry or its partners. In all cases, the Registry or its designees will alert Registry’s registrar partners about any identified threats, and will work closely with them to bring offending sites into compliance.
The following are some (but not all) activities that may be subject to rapid domain compliance:
 Phishing: the attempt to acquire personally identifiable information by masquerading as a website other than .Jewelry’s own.
 Pharming: the redirection of Internet users to websites other than those the user intends to visit, usually through unauthorized changes to the Hosts file on a victim’s computer or DNS records in DNS servers.
 Dissemination of Malware: the intentional creation and distribution of ʺmaliciousʺ software designed to infiltrate a computer system without the owner’s consent, including, without limitation, computer viruses, worms, key loggers, and Trojans.
 Fast Flux Hosting: a technique used to shelter Phishing, Pharming and Malware sites and networks from detection and to frustrate methods employed to defend against such practices, whereby the IP address associated with fraudulent websites are changed rapidly so as to make the true location of the sites difficult to find.
 Botnetting: the development and use of a command, agent, motor, service, or software which is implemented: (1) to remotely control the computer or computer system of an Internet user without their knowledge or consent, (2) to generate direct denial of service (DDOS) attacks.
 Malicious Hacking: the attempt to gain unauthorized access (or exceed the level of authorized access) to a computer, information system, user account or profile, database, or security system.
 Child Pornography: the storage, publication, display and⁄or dissemination of pornographic materials depicting individuals under the age of majority in the relevant jurisdiction.
The Registry reserves the right, in its sole discretion, to take any administrative and operational actions necessary, including the use of computer forensics and information security technological services, among other things, in order to implement the Acceptable Use Policy. In addition, the Registry reserves the right to deny, cancel or transfer any registration or transaction, or place any domain name(s) on registry lock, hold or similar status, that it deems necessary, in its discretion; (1) to protect the integrity and stability of the registry; (2) to comply with any applicable laws, government rules or requirements, requests of law enforcement, or any dispute resolution process; (3) to avoid any liability, civil or criminal, on the part of Registry as well as its affiliates, subsidiaries, officers, directors, and employees; (4) per the terms of the registration agreement or (5) to correct mistakes made by the Registry or any Registrar in connection with a domain name registration. Registry also reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute. 

Taking Action Against Abusive and⁄or Malicious Activity
The Registry is committed to ensuring that those domain names associated with abuse or malicious conduct in violation of the Acceptable Use Policy are dealt with in a timely and decisive manner. These include taking action against those domain names that are being used to threaten the stability and security of the TLD, or is part of a real-time investigation by law enforcement. 
Once a complaint is received from a trusted source, third-party, or detected by the Registry, the Registry will use commercially reasonable efforts to verify the information in the complaint. If that information can be verified to the best of the ability of the Registry, the sponsoring registrar will be notified and be given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the Registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “ServerHold”. (This is unlikely to be necessary, as Richemont DNS will be using a single, gateway registrar with whom it has a contract reflecting these policies). Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.
Coordination with Law Enforcement
With the assistance of Neustar as its back-end registry services provider, Richemont DNS can meet its obligations under Section 2.8 of the Registry Agreement where required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. The Registry will respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, Questions or comments concerning the request, and an outline of the next steps to be taken by Richemont DNS for rapid resolution of the request. 
In the event such request involves any of the activities which can be validated by the Registry and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “serverHold”. 


Richemont DNS is aware that Neustar provides additional monitoring for malicious activity upon request. Following Reveal Day, 2 May 2012, Richemont DNS will be talking to Neustar with the intention of determining how the following services and policies can be introduced. 
Monitoring for Malicious Activity
Richemont DNS’s partner, Neustar is at the forefront of the prevention of abusive DNS practices. Neustar has developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names. 
Neustar targets verified abusive domain names and removes them within 12 hours regardless of whether or not there is cooperation from the domain name registrar. This is because Neustar has determined that the interest in removing such threats from the consumer outweighs any potential damage to the registrar⁄registrant relationship. This is very unlikely to be required in Richemont DNS registry as it has rules or eligibility that exclude third parties beyond Richemont DNS and it will only be using one registrar with which it has a close contractual relationship with requirements to co-operate in stemming abusive behaviors.
Neustar’s active prevention policies stem from the notion that registrants in the TLD have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet, including malware, bot command and control, pharming, and phishing, the best preventative measure to thwart these attacks is often to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.
Rapid Takedown Process
Since implementing the program, Neustar has developed two basic variations of the process. The more common process variation is a light-weight process that is triggered by “typical” notices. The less-common variation is the full process that is triggered by unusual notices. These notices tend to involve the need for accelerated action by the registry in the event that a complaint is received by Neustar, which alleges that a domain name is being used to threaten the stability and security of the TLD, or is part of a real-time investigation by law enforcement or security researchers. These processes are described below:
Lightweight Process 
In addition to having an active Information Security group that, on its own initiatives, seeks out abusive practices in the TLD, Neustar is an active member in a number of security organizations that have the expertise and experience in receiving and investigating reports of abusive DNS practices, including but not limited to, the Anti-Phishing Working Group, Castle Cops, NSP-SEC, the Registration Infrastructure Safety Group and others. Each of these sources are well-known security organizations that have developed a reputation for the prevention of harmful agents affecting the Internet. Aside from these organizations, Neustar also actively participates in privately run security associations whose basis of trust and anonymity makes it much easier to obtain information regarding abusive DNS activity.
Once a complaint is received from a trusted source, third-party, or detected by Neustar’s internal security group, information about the abusive practice is forwarded to an internal mail distribution list that includes members of the operations, legal, support, engineering, and security teams for immediate response (“CERT Team”). Although the impacted URL is included in the notification e-mail, the CERT Team is trained not to investigate the URLs themselves since often times the URLs in Question have scripts, bugs, etc. that can compromise the individual’s own computer and the network safety. Rather, the investigation is done by a few members of the CERT team that are able to access the URLs in a laboratory environment so as to not compromise the Neustar network. The lab environment is designed specifically for these types of tests and is scrubbed on a regular basis to ensure that none of Neustar’s internal or external network elements are harmed in any fashion.
Once the complaint has been reviewed and the alleged abusive domain name activity is verified to the best of the ability of the CERT Team, the sponsoring registrar is given 12 hours to investigate the activity and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. 
If the registrar has not taken the requested action after the 12-hNeustar’s period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “ServerHold”. Although this action removes the domain name from the TLD zone, the domain name record still appears in the TLD WHOIS database so that the name and entities can be investigated by law enforcement should they desire to get involved.
Full Process
In the event that Neustar receives a complaint which claims that a domain name is being used to threaten the stability and security of the TLD or is a part of a real-time investigation by law enforcement or security researchers, Neustar follows a slightly different course of action.
Upon initiation of this process, members of the CERT Team are paged and a teleconference bridge is immediately opened up for the CERT Team to assess whether the activity warrants immediate action. If the CERT Team determines the incident is not an immediate threat to the security and the stability of critical Internet infrastructure, they provide documentation to the Neustar Network Operations Center to clearly capture the rationale for the decision and either refers the incident to the Lightweight process set forth above. If no abusive practice is discovered, the incident is closed. 
However, if the CERT TEAM determines there is a reasonable likelihood that the incident warrants immediate action as described above, a determination is made to immediately remove the domain from the zone. As such, Customer Support will contact Richemont DNS‘s registrar immediately to communicate that there is a domain involved in a security and stability issue. The registrar is provided only the domain name in Question and the broadly stated type of incident. Given the sensitivity of the associated security concerns, it may be important that the registrar not be given explicit or descriptive information in regards to data that has been collected (evidence) or the source of the complaint. The need for security is to fully protect the chain of custody for evidence and the source of the data that originated the complaint. 
Coordination with Law Enforcement & Industry Groups
Neustar has extensive experience of dealing with abusive and malicious domain name incidents. It has a close working relationship with a number of law enforcement agencies, both in the United States and internationally. For example, in the United States, Neustar is in constant communication with the Federal Bureau of Investigation, US CERT, Homeland Security, the Food and Drug Administration, and the National Center for Missing and Exploited Children. 
Neustar is also a participant in a number of industry groups aimed at sharing information amongst key industry players about the abusive registration and use of domain names. These groups include the Anti-Phishing Working Group and the Registration Infrastructure Safety Group (where Neustar served for several years as on the Board of Directors). Through these organizations and others, Neustar shares information with other registries, registrars, ccTLDs, law enforcement, security professionals, etc. not only on abusive domain name registrations within its own TLDs, but also provides information uncovered with respect to domain names in other registries’ TLDs. Neustar has often found that rarely are abuses found only in the TLDs for which it manages, but also within other TLDs, such as .com and .info. Neustar routinely provides this information to the other registries so that it can take the appropriate action.
With the assistance of Neustar as its back-end registry services provider, Richemont DNS can meet its obligations under Section 2.8 of the Registry Agreement where it is required to take reasonable steps to investigate and respond to reports from law enforcement and governmental and quasi-governmental agencies of illegal conduct in connection with the use of its TLD. Richemont DNS and⁄or Neustar will respond to legitimate law enforcement inquiries within one business day from receiving the request. Such response shall include, at a minimum, an acknowledgement of receipt of the request, Questions or comments concerning the request, and an outline of the next steps to be taken by Richemont DNS and⁄or Neustar for rapid resolution of the request. 
In the event such request involves any of the activities which can be validated by Richemont DNS and⁄or Neustar and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), Neustar places the domain on “serverHold”. 
28.3 Measures for Removal of Orphan Glue Records
As the Security and Stability Advisory Committee of ICANN (SSAC) rightly acknowledges, although orphaned glue records may be used for abusive or malicious purposes, the “dominant use of orphaned glue supports the correct and ordinary operation of the DNS.” See http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf. 
While orphan glue often support correct and ordinary operation of the DNS, we understand that such glue records can be used maliciously to point to name servers that host domains used in illegal phishing, bot-nets, malware, and other abusive behaviors. Problems occur when the parent domain of the glue record is deleted but its children glue records still remain in DNS. Therefore, when the Registry has written evidence of actual abuse of orphaned glue, the Registry will take action to remove those records from the zone to mitigate such malicious conduct. 

Neustar run a daily audit of entries in its DNS systems and compares those with its provisioning system. This serves as an umbrella protection to make sure that items in the DNS zone are valid. Any DNS record that shows up in the DNS zone but not in the provisioning system will be flagged for investigation and removed if necessary. This daily DNS audit serves to not only prevent orphaned hosts but also other records that should not be in the zone. 
In addition, if either Richemont DNS or Neustar become aware of actual abuse on orphaned glue after receiving written notification by a third party through its Abuse Contact or through its customer support, such glue records will be removed from the zone. 
28.4 Measures to Promote WHOIS Accuracy 
The Richemont DNS registry will implement several measures to promote Whois accuracy. 

Whois service for Richemont DNS will operate as follows: all basic contact details for each domain name are kept in a unique internal system by the registry, which facilitates the access to the domain information. In addition, Richemont DNS will perform internal monitoring checks and procedures which will only allow accurate Whois information and remove outdated data.


28.4.1. Authentication of Registrant Information
As a single entity registry, the only registrant in .Jewelry will be Richemont DNS. However, Richemont DNS will guarantee the adequate authentication of registrant data, ensuring the highest levels of accuracy and diligence when dealing with Whois data. In doing so, Richemont DNS’s solid internal system will undertake the following, but not limited to, authentication measures: running checks against Whois internal records, regular verification of all contact details and other relevant registrant information. The Richemont DNS’s registrar will also be charged with regularly checking whois accuracy.
28.4.2. Regular Monitoring of Registration Data
Richemont DNS is strongly committed to implement specific policies and procedures to guarantee the adequate compliance with ICANN’s Whois requirements. Among other measures, Richemont DNS will regularly remind its internal personnel to meet the standards of ICANN’s Whois information Policy, including regular checks of Whois data against internal records, offering Whois accuracy services, evaluating claims of fraudulent Whois data and the cancellation of domain name registrations with outdated Whois details.

28.4.3. Policies and Procedures ensuring compliance 
Only Richemont DNS and its Affiliates will be permitted to register and use Richemont DNS domain names. Accordingly, the duties of the Richemont DNS registrar will be very limited and closely defined. However, as part of the RRA (Registry Registrar Agreement), Richemont DNS will require the Richemont DNS registrar to take steps necessary to ensure Whois data is complete and accurate and to implement the Richemont DNS registration policies.

28.5 Resourcing Plans 
Responsibility for abuse mitigation rests with a variety of functional groups. The Abuse Monitoring team is primarily responsible for providing analysis and conducting investigations of reports of abuse. The customer service team also plays an important role in assisting with the investigations, responded to customers, and notifying registrars of abusive domains. Finally, the Policy⁄Legal team is responsible for developing the relevant policies and procedures. 
The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:
Customer Support – 12 employees
Policy⁄Legal – 2 employees
The resources are more than adequate to support the abuse mitigation procedures of the .Jewelry registry. 
Furthermore, Richemont DNS dedicates significant financial and personnel resources to combating malicious and abusive behavior in the DNS. Richemont DNS will extend these resources to encompass the designation and maintenance of the unique abuse point of contact, regular monitoring of potential abusive and malicious activities with support from dedicated technical staff, analysis of reported abuse and malicious activity, and action to address such reported activity. 

The designated abuse prevention staff will be subject to regular evaluations, receive adequate training and work under expert supervision. The abuse prevention resources will comprise both internal staff and external abuse prevention experts who would give extra advice and support when necessary. These external staff include experts in Richemont DNS’s registrar.
 

29.1 Introduction

Richemont DNS is applying for this registry to provide a dedicated platform for stable and secure online communication and interaction and in order to protect Richemont’s intellectual property rights. Around the world the Richemont group companies (“Richemont”) have over 30,000 registered intellectual property assets including trademarks, patents and designs. We place the highest priority upon the protection of our intellectual property and it is our intention to extend this prioritisation to the protection of the rights of others in our gTLDs.

29.1.1 Rights protection in gTLD registry operation is a core objective of Richemont.

Richemont DNS will achieve this by maintaining tight control over our registries. Richemont is planning to register domains in its own right in its TLDs through a single registrar. Although Richemont and Richemont DNS will be the only eligible registrants, we will nonetheless require our registrar to work with us on a four step registration process featuring (i) Eligibility Confirmation, (ii) Naming Convention Check, (iii) Acceptable Use Review, and (iv) Registration. As stated in our answer to Question 18, all domains in our registry will remain the property of Richemont and will be provisioned to support the business goals of Richemont. Domains in our registries will not be registered or delegated to third party organizations, institutions or individuals. All domains in our registries will carry accurate and up-to-date registration records.

We will be seeking an exemption from clause 1b of the Code of Conduct for a registry operator because all domains will be registered and maintained by Richemont for our exclusive use. 

Domains in our registries will not be sold or assigned to any third party beyond Richemont.

We believe that these policies which will be reinforced by procedures which we constantly monitor and update in line with ICANN policy developments and dot Brand registry best practice will ensure that abusive registrations are prevented.

29.2 Core measures to prevent abusive registrations

To prevent abusive registration or cybersquatting we will adopt the following Rights Protection Mechanisms (RPMs) which have been mandated by ICANN:
• A 30 day Sunrise process
• A 60 day Trademark Claims process

Generally the RPMs listed above are targeted at abusive registrations undertaken by third parties. However, domains in our registry will be registered only to Richemont or its affiliates through a single registrar which will be required through contract to ensure that the rules covering eligibility and use of a domain are adhered to – for example all registration requests will be validated so that registered domains are used only to support the business goals of Richemont. This means that abusive registrations should be completely prevented. In the very unlikely circumstances that they occur, we acknowledge that we will be the respondent in any proceedings that are brought and we undertake to co-operate fully with ICANN and other appropriate agencies.

29.2.1 Sunrise Eligibility

Our Sunrise Eligibility Requirements will clearly state that eligible applicants must be members of the Richemont group of companies and our subsidiaries. Furthermore, all domain names must be used to support the business goals of Richemont. Nonetheless, notice of our Sunrise will be provided to third party holders of validated trademarks in the Trademark Clearinghouse as required by ICANN. Our Sunrise Eligibility Requirements will be published on the website of our registry

29.2.2 Sunrise

Our Sunrise will last for 30 days. Applications received from an ICANN-accredited registrar supported by an entry in the Trademark Clearinghouse within this period that satisfy our Sunrise Eligibility Requirements will be accepted for participation and if registered will have a one year term of registration. 

The processing of registration requests made in our Sunrise will be undertaken by our registrar. 

As required in the Applicant Guidebook in section 7.1, we will recognise in our Sunrise “all word marks: (i) nationally or regionally registered and for which proof of use – which can be a declaration and a single specimen of current use – was submitted to, and validated by, the Trademark Clearinghouse; or (ii) that have been court-validated; or (iii) that are specifically protected by a statute or treaty currently in effect and that was in effect on or before 26 June 2008.”

29.2.3 Sunrise Dispute Resolution Policy

We will devise and publish the rules for a Sunrise Dispute Resolution Policy (SDRP) on our registry website. The Richemont SDRP will apply to all our registries. It will allow any party to raise a challenge on the following four grounds as required in the Applicant Guidebook (6.2.4):

(i) At the time the challenged domain name was registered, the registrant did not hold a trademark registration of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty;

(ii) The domain name is not identical to the mark on which the registrant based its Sunrise registration; 

(iii) The trademark registration on which the registrant based its Sunrise registration is not of national effect (or regional effect) or the trademark had not been court-validated or protected by statute or treaty; or 

(iv) The trademark registration on which the domain name registrant based its Sunrise registration did not issue on or before the effective date of the Registry Agreement and was not
applied for on or before ICANN announced the applications received.

Complaints will be initially processed by our registrar who will provide a report to us identifying the challenger, the challenged domain name, the grounds upon which the complaint is based and why the challenger believes the grounds are satisfied.

Complaints can be submitted through our registry website and must be made within 30 days following the closure of the Sunrise.

29.2.4 Trademark Claims Service

The Richemont Trademark Claims Service (TMCS) will run for a 60 day period following the closure of our 30 day Sunrise. Our TMCS will be supported by the Trademark Clearinghouse and will provide a notice to third parties interested in filing a character string in our registry of a registered trademark right that matches the character string in the TMCH. 

We will honour and recognise in our TMCS the following types of mark as defined in the Applicant Guidebook s7.1: (i) nationally or regionally registered; (ii) court-validated; or (iii) specifically protected by a statute or treaty in effect at the time the mark is submitted to the Clearinghouse for inclusion. 

Once received from the TMCH, with which our registry provider NeuStar will interface, a claim will be initially processed by our registrar who will provide a report to us on the eligibility of the applicant.

29.2.5 Implementation and Resourcing Plans of core services to prevent abusive registration

Our Sunrise and IP Claims service will be introduced to the following timetable:
Day One: Announcement of Registry Launch and publication of registry website with details of the Sunrise and TMCS
Day 30: Sunrise opens for 30 days
Day 60: Sunrise closes
Day 61: Publication of all domains applied for in our Thick Whois
Day 62: Registry Open, domains applied for in the Sunrise registered and TMCS (Trademark Claim Service) begins for 60 days
Day 122: TMCS ends; normal operations continue

Our Implementation Team will comprise the following:

From Richemont: The Richemont DNS team of up to four experts with experience of domain name management will work closely with the Richemont Intellectual Property Department under the leadership of Richemont International’s Senior Digital and IP Counsel. This features three people with experience of on-line legal dispute resolution. She will also have access to the Richemont Corporate Legal Team.

From NeuStar, registry service provider to Richemont: A Customer Support team of 12, a Product Management Team of four and a Development ⁄ Engineering Team of 19 will be available as required to support the legal team, led by Jeff Neuman. This team has over 10 years experience of implementing registry launches including rights protection schemes including the .biz Sunrise and IP Claims.

In addition, Richemont will be supported by its Registrar which will provide a legal specialist and six operational staff. The operational staff will undertake the validation checks on registration requests.

The Implementation Team will create a formal Registry Launch plan by 1 October 2012. This will set out the exact process for the launch of each Richemont registry and will define responsibilities and budgets. The Richemont Registry website, which is budgeted for in the three year plans provided in our answers to question 46 will be built by 1 December 2012. It will feature Rules of Registration, Rules of Eligibility, Terms & Conditions of Registration, Acceptable Use Policies as well as the Rules of the Sunrise, the Rules of the Sunrise Dispute Resolution Policy and the Rules of the Trademark Claims Service.

Technical implementation between the registry and the Trademark Clearinghouse will be undertaken by the registry service provider as soon as practical after the Trademark Clearinghouse is operational and announces its integration process. 

As demonstrated in our financial answers, a budget has been set aside to pay fees charged by the Trademark Clearinghouse Operator for this integration.

The contract we have with our registrar (the RAA) will require that the registrar uses the TMCH, adheres to the Terms & Conditions of the TMCH and will prohibit the registrar from filing domains in our registries on its own behalf or utilising any data from the TMCH except in the provision of its duties as our registrar. 

When processing TMCS claims, our registrar will be required to use the specific form of notice provided by ICANN in the Applicant Guidebook.

We will also require our registrar to implement appropriate privacy policies reflecting the location of our registries and the high standards that we set. 

29.3 Mechanisms to identify and address the abusive use of registered domain names on an ongoing basis

To prevent the abusive use of registered domain names on an ongoing basis we will adopt the following Rights Protection Mechanisms (RPMs) which have been mandated by ICANN:
• The Uniform Dispute Resolution Policy (UDRP) to address domain names that have been registered and used in bad faith in the TLD.
• The Uniform Rapid Suspension (URS) scheme which is a faster, more efficient alternative to the Uniform Dispute Resolution Policy to deal with clear-cut cases of cybersquatting.
• The Post Delegation Dispute Resolution Procedure (PDDRP)
• Implementation of a Thick WHOIS making it easier for rights holders to identify and locate infringing parties

The UDRP and the URS are targeted at abusive registrations undertaken by third parties and the PDDRP at so called “Bad Actor” registries. As domains in our registry will be registered not to third parties but only to Richemont or its affiliates through a single registrar which will be required through contract to ensure that the rules covering eligibility and use of a domain are adhered to, we believe that abusive registrations by third parties should be completely prevented. 

Abusive behaviour by representatives of Richemont or our subsidiaries will be prevented by our internal processes, for example the pre-registration validation checks and monitoring of use which our registrar will assist us with.

Despite this, we acknowledge that we are subject to the UDRP, the URS and the PDDRP and we will co-operate fully with ICANN and appropriate registries in the unlikely circumstances that complaints against us, as the registrant, are made.

29.3.1 The Uniform Dispute Resolution Policy (UDRP)

The UDRP is an out-of-court dispute resolution mechanism for trademark owners to resolve clear cases of bad-faith, abusive registration and use of domain names. The UDRP applies by contract to all domain name registrations in gTLDs. Standing to file a UDRP complaint is limited to trademark owners who must demonstrate their rights. To prevail in a UDRP complaint, the complainant must further demonstrate that the domain name registrant has no rights or legitimate interests in the disputed domain name, and that the disputed domain name has been registered and is being used in bad faith. In the event of a successful claim, the infringing domain name registration is transferred to the complainant’s control.

Richemont or its subsidiaries will be the respondent in all UDRP complaints because we will be the only eligible registrants. Therefore we do not anticipate that there are any circumstances in which complainants can argue that we have “no rights or legitimate interests” in a domain in our registry so the possibility of good faith UDRP complaints should be minimised. In the unlikely circumstances that a complaint is made, we will respond in a timely fashion, reflecting our contractual responsibility to ICANN as a registry operator.

We will be applying for an exemption to Clause 1b of the Registry Operators Code of Conduct. This means that we will not be allowed to transfer domains to third parties as the only registrant will be Richemont or our affiliates. Therefore if a complaint against us is filed, the only possible remedy will be the cancellation of the domain instead of the transfer to the complainant. 

Should a successful complaint be made we will therefore place the cancelled domain that is the subject of the complaint on a list that prevents it from being registered again, unless legitimate rights in and to the domain name can be established by an eligible successor registrant.

29.3.2 The URS

The URS is intended to be a lighter, quicker complement to the UDRP. Like the UDRP, it is intended for clear-cut cases of trademark abuse. Under the URS, the only remedy which a panel may grant is the temporary suspension of a domain name for the duration of the registration period (which may be extended by the prevailing complainant for one year, at commercial rates). URS substantive criteria mirror those of the UDRP but with a higher burden of proof for complainants, and additional registrant defences. Once a determination is rendered, a losing registrant has several appeal possibilities from 30 days up to one year. Either party may file a de novo appeal within 14 days of a decision. There are penalties for filing “abusive complaints” which may result in a ban on future URS filings.

As with the description of our UDRP process above, Richemont or its affiliates will be the respondent in all URS complaints because we will be the only eligible registrants. Therefore we do not anticipate that there are any circumstances in which complainants can argue that we have “no legitimate right or interest to the domain name’ and ‘that the domain name was registered and is being used in bad faith’. Notwithstanding this, should a complaint be made, we will respond in a timely fashion, reflecting our contractual responsibility to ICANN as a registry operator.

Should a successful complaint be made, Richemont DNS will suspend the domain name for the duration of the registration period.

We will co-operate with the URS panel providers and panelists as we will co-operate with UDRP panel providers and panellists.

Being the only eligible registrant, we will not make changes to a domain in Locked Status or alter a registration record associated with a URS complaint as required in the Applicant Guidebook. 

29.3.3 The Post Delegation Dispute Resolution Procedure (PDDRP)

The PDDRP is an administrative (court alternative) option for trademark owners to file an objection against a registry whose “affirmative conduct” in its operation or use of its gTLD is alleged to cause or materially contribute to trademark abuse. In this way, the PDDRP is intended to act as a higher-level enforcement tool to assist ICANN compliance activities, where rights holders may not be able to continue to turn solely to lower-level multijurisdictional enforcement options in a vastly expanded DNS.

The PDDRP involves a number of procedural layers, such as an administrative compliance review, appointment of a “threshold review panel,” an expert determination as to liability under the procedure (with implementation of any remedies at ICANN’s discretion), a possible de novo appeal and further appeal to arbitration under ICANN’s registry terms. The PDDRP requires specific bad-faith conduct including profit from encouraging infringement in addition to “the typical registration fee.” 

As set out in the Applicant Guidebook in the appendix summarising the PDDRP, the grounds for a complaint on a second level registration are that , “(a) 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 (b) 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: (i) takes unfair advantage of the distinctive character or the reputation of the complainantʹs mark; or (ii) impairs the distinctive character or the reputation of the complainantʹs mark, or(iii) creates a likelihood of confusion with the complainantʹs mark.”. 

Whilst we will co-operate with any complaints made under the PDDRP and it is our intention to abide by any determinations, we think it is impossible that any PDDRP complaints will succeed because the grounds set out above cannot be satisfied as domains in the registry will not be for sale and cannot be transferred to third parties.

29.3.4 Thick Whois

As required in Specification 4 of the Registry agreement, all Richemont registries will provide Thick Whois. A Thick WHOIS provides a centralized location of registrant information within the control of the registry (as opposed to thin Whois where the data is dispersed across registrars). 

Thick Whois will provide rights owners and law enforcement with the ability to review the registration record easily. 

We will place a requirement on our registrar to ensure that all registrations are filed with accurate Whois details and we will undertake reviews of Whois accuracy every three months to ensure that the integrity of data under our control is maintained. 

We will create and publish a Whois Query email address so that third parties can submit queries about any domains in our registry.

29.3.5 Implementation and Resourcing Plans for mechanisms to identify and address the abusive use of registered domain names on an ongoing basis

Our post-launch rights protection mechanisms will be in place from Day One of the launch of the registry.

To ensure that we are compliant with our obligations as a registry operator, we will develop a section of our registry website to assist third parties involved in a UDRP, URS and PDDRP complaints including third parties wishing to make a complaint, ICANN compliance staff and the providers of UDRP and URS panels. This will feature an email address for enquiries relating to disputes or seeking further information on specific domains. We will monitor this address for all of the following: Notice of Complaint, Notice of Default, URS Determination, UDRP Determination, Notice of Appeal and Appeal Panel Findings where appropriate.

As stated in our answer to Question 18, Richemont DNS together with Richemont’s Intellectual Property group will be responsible for the development, maintenance and enforcement of Domain Management Policy. This will include ensuring that the following implementation targets are met:
• Locking domains the subject of UDRP or URS complaints within 24 hours of receipt of a URDP or a URS complaint
• Confirming the implementation of the lock to the relevant UDRP or URS provider
• Cancel domain names that are the subject of a successful UDRP complaint within 24 hours
• Redirect servers to a website with the ICANN mandated information following a successful URS within 24 hours

The human resources dedicated to managing post-launch RPM include:

From Richemont: The Richemont DNS team of up to four experts with experience of domain name management will work closely with the Richemont Intellectual Property Department under the leadership of Richemont International’s Senior Digital and IP Counsel. This features three people with experience of on-line legal dispute resolution. She will also have access to the Richemont Corporate Legal Team.

From NeuStar, registry service provider to Richemont: A Customer Support team of 12, a Product Management Team of four and a Development ⁄ Engineering Team of 19 will be available as required to support the legal team, led by Jeff Neuman. This team has over 10 years experience of implementing registry launches including rights protection schemes including the .biz Sunrise and IP Claims.

In addition, Richemont will be supported by its Registrar which will provide a legal specialist and six operational staff. The operational staff will undertake the validation checks on registration requests.

29.4 Additional Mechanism that exceed requirements 

Rights protection is at the core of Richemont’s objective in applying for this registry. Therefore we are committed to providing the following additional mechanisms:

29.4.1 Registry Legal Manager

We will appoint a Legal Manager to ensure that we are compliant with ICANN policies. The Legal Manager will also handle all disputes relating to RPMs. This will involve evaluating complaints, working with external legal counsel and law enforcement, resolving disputes. The Legal Manager will also liaise with external stakeholders including URS and UDRP panel provides, the TMCH operator, trademark holders as needed. 

29.4.2 Rights Protection Help Line

We will maintain a Rights Protection Help Line. Calls to this line will be allocated a Case Number and the following details will be recorded:
• The contact details of the complainant
• The domain name that is the subject of the complaint or query
• The registered right, if any, that is associated with the request
• An explanation of the issues such as why the complainant believes that its mark has been infringed

An initial response to a query or complaint will be made within 24 hours. The Rights Protection Help Line will be in place on Day One of the registry. The cost of the Rights Help Line is reflected in the Projections Templates provided at Q46 as part of on-going registry maintenance costs.

The aim of the Rights Protection Help Line is to assist third parties in understanding the mission and purpose of our registry and to see if a resolution can be found that is quicker and easier than the filing of a UDRP or URS complaint.

The Legal Manager will oversee the Rights Protection Help Line.

29.4.3 Registrar Accreditation

We will audit the performance of our registrar every six months and re-validate our Registry-registrar Agreements annually. Our audits will include site visits to ensure the security of data etc.

29.4.4 Annual Report

We will publish an Annual Report on Rights Protection in our registries on our Registry Website. This will include relevant statistics and it will outline all cases and how they were resolved.

29.4.5 Contacts with WIPO and other DRS providers

We will invite representatives of WIPO and other DRS providers to review our RPM and to make suggestions on any improvements that we might make after the first full year of operation.

29.4.6 Registrant Pre-Verification

All requests for registration will be verified by our registrar to ensure that they come from a legitimate representative of Richemont or our subsidiaries. A record of the request will be kept in our on-line domain management console including the requestor’s email address and other contact information.

29.4. 7 Speed of Response

Wherever possible, as outlined above, we are committed to a response within 24 hours of a complaint being made. This exceeds the guidelines for the UDRP and the URS.

Richemont DNS and our back-end operator, Neustar, recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .Jewelry registry solution will leverage industry-best security practices including the consideration of physical, network, server, and application elements. 
Neustar’s approach to information security starts with comprehensive information security policies. These are based on the industry best practices for security including SANS (SysAdmin, Audit, Network, Security) Institute, NIST (National Institute of Standards and Technology), and Center for Internet Security (CIS). Policies are reviewed annually by Neustar’s information security team.
The following is a summary of the security policies that will be used in the .Jewelry registry, including:
1. Summary of the security policies used in the registry operations
2. Description of independent security assessments
3. Description of security features that are appropriate for .Jewelry
4. List of commitments made to registrants regarding security levels

All of the security policies and levels described in this section are appropriate for the .Jewelry registry.
30.(a).1 Summary of Security Policies 

Neustar, Inc. has developed a comprehensive Information Security Program in order to create effective administrative, technical, and physical safeguards for the protection of its information assets, and to comply with Neustarʹs obligations under applicable law, regulations, and contracts. This Program establishes Neustarʹs policies for accessing, collecting, storing, using, transmitting, and protecting electronic, paper, and other records containing sensitive information.
The Program defines:
 The policies for internal users and our clients to ensure the safe, organized and fair use of information resources.
 The rights that can be expected with that use. 
 The standards that must be met to effectively comply with policy.
 The responsibilities of the owners, maintainers, and users of Neustar’s information resources.
 Rules and principles used at Neustar to approach information security issues

The following policies are included in the Program:
1. Acceptable Use Policy
The Acceptable Use Policy provides the “rules of behavior” covering all Neustar Associates for using Neustar resources or accessing sensitive information.
2. Information Risk Management Policy
The Information Risk Management Policy describes the requirements for the on-going information security risk management program, including defining roles and responsibilities for conducting and evaluating risk assessments, assessments of technologies used to provide information security and monitoring procedures used to measure policy compliance.
3. Data Protection Policy 
The Data Protection Policy provides the requirements for creating, storing, transmitting, disclosing, and disposing of sensitive information, including data classification and labeling requirements, the requirements for data retention. Encryption and related technologies such as digital certificates are also covered under this policy.
4. Third Party Policy
The Third Party Policy provides the requirements for handling service provider contracts, including specifically the vetting process, required contract reviews, and on-going monitoring of service providers for policy compliance.
5. Security Awareness and Training Policy
The Security Awareness and Training Policy provide the requirements for managing the on-going awareness and training program at Neustar. This includes awareness and training activities provided to all Neustar Associates. 
6. Incident Response Policy
The Incident Response Policy provides the requirements for reacting to reports of potential security policy violations. This policy defines the necessary steps for identifying and reporting security incidents, remediation of problems, and conducting “lessons learned” post-mortem reviews in order to provide feedback on the effectiveness of this Program. Additionally, this policy contains the requirement for reporting data security breaches to the appropriate authorities and to the public, as required by law, contractual requirements, or regulatory bodies.
7. Physical and Environmental Controls Policy
The Physical and Environment Controls Policy provides the requirements for securely storing sensitive information and the supporting information technology equipment and infrastructure. This policy includes details on the storage of paper records as well as access to computer systems and equipment locations by authorized personnel and visitors.
8. Privacy Policy
Neustar supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them, their personal choices, or life experiences. Neustar supports domestic and international laws and regulations that seek to protect the privacy rights of such individuals.
9. Identity and Access Management Policy
The Identity and Access Management Policy covers user accounts (login ID naming convention, assignment, authoritative source) as well as ID lifecycle (request, approval, creation, use, suspension, deletion, review), including provisions for system⁄application accounts, shared⁄group accounts, guest⁄public accounts, temporary⁄emergency accounts, administrative access, and remote access. This policy also includes the user password policy requirements. 
10. Network Security Policy
The Network Security Policy covers aspects of Neustar network infrastructure and the technical controls in place to prevent and detect security policy violations. 
11. Platform Security Policy
The Platform Security Policy covers the requirements for configuration management of servers, shared systems, applications, databases, middle-ware, and desktops and laptops owned or operated by Neustar Associates.
12. Mobile Device Security Policy
The Mobile Device Policy covers the requirements specific to mobile devices with information storage or processing capabilities. This policy includes laptop standards, as well as requirements for PDAs, mobile phones, digital cameras and music players, and any other removable device capable of transmitting, processing or storing information.
13. Vulnerability and Threat Management Policy
The Vulnerability and Threat Management Policy provides the requirements for patch management, vulnerability scanning, penetration testing, threat management (modeling and monitoring) and the appropriate ties to the Risk Management Policy.
14. Monitoring and Audit Policy
The Monitoring and Audit Policy covers the details regarding which types of computer events to record, how to maintain the logs, and the roles and responsibilities for how to review, monitor, and respond to log information. This policy also includes the requirements for backup, archival, reporting, forensics use, and retention of audit logs.
15. Project and System Development and Maintenance Policy
The System Development and Maintenance Policy covers the minimum security requirements for all software, application, and system development performed by or on behalf of Neustar and the minimum security requirements for maintaining information systems.

30. (a).2 Independent Assessment Reports
Neustar IT Operations is subject to yearly Sarbanes-Oxley (SOX), Statement on Auditing Standards #70 (SAS70) and ISO audits. Testing of controls implemented by Neustar management in the areas of access to programs and data, change management and IT Operations are subject to testing by both internal and external SOX and SAS70 audit groups. Audit Findings are communicated to process owners, Quality Management Group and Executive Management. Actions are taken to make process adjustments where required and remediation of issues is monitored by internal audit and QM groups.
External Penetration Test is conducted by a third party on a yearly basis. As authorized by Neustar, the third party performs an external Penetration Test to review potential security weaknesses of network devices and hosts and demonstrate the impact to the environment. The assessment is conducted remotely from the Internet with testing divided into four phases:
 A network survey is performed in order to gain a better knowledge of the network that was being tested
 Vulnerability scanning is initiated with all the hosts that are discovered in the previous phase
 Identification of key systems for further exploitation is conducted
 Exploitation of the identified systems is attempted.
Each phase of the audit is supported by detailed documentation of audit procedures and results. Identified vulnerabilities are classified as high, medium and low risk to facilitate management’s prioritization of remediation efforts. Tactical and strategic recommendations are provided to management supported by reference to industry best practices.
30.(a).3 Augmented Security Levels and Capabilities
There are no increased security levels specific for .Jewelry. However, Neustar will provide the same high level of security provided across all of the registries it manages. 
A key to Neustar’s Operational success is Neustar’s highly structured operations practices. The standards and governance of these processes: 
 Include annual independent review of information security practices 
 Include annual external penetration tests by a third party 
 Conform to the ISO 9001 standard (Part of Neustar’s ISO-based Quality Management System)
 Are aligned to Information Technology Infrastructure Library (ITIL) and CoBIT best practices 
 Are aligned with all aspects of ISO IEC 17799
 Are in compliance with Sarbanes-Oxley (SOX) requirements (audited annually)
 Are focused on continuous process improvement (metrics driven with product scorecards reviewed monthly).
A summary view to Neustar’s security policy in alignment with ISO 17799 can be found in section 30.(a).4 below.
30.(a).4 Commitments and Security Levels 
The .Jewelry registry commits to high security levels that are consistent with the needs of the TLD. These commitments include:

Compliance with High Security Standards
 Security procedures and practices that are in alignment with ISO 17799
 Annual SOC 2 Audits on all critical registry systems
 Annual 3rd Party Penetration Tests 
 Annual Sarbanes Oxley Audits

Highly Developed and Document Security Policies
 Compliance with all provisions described in section 30.(a).4 below and in the attached security policy document.
 Resources necessary for providing information security
 Fully documented security policies
 Annual security training for all operations personnel

High Levels of Registry Security
 Multiple redundant data centers
 High Availability Design
 Architecture that includes multiple layers of security
 Diversified firewall and networking hardware vendors
 Multi-factor authentication for accessing registry systems
 Physical security access controls
 A 24x7 manned Network Operations Center that monitors all systems and applications
 A 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks
 DDoS mitigation using traffic scrubbing technologies