Application number: 1-1296-16820 for NU DOT CO LLC

NU DOT CO LLC

701 Brickell Avenue
Suite 860
Miami FL 33131
US

01 305 372 0075

01 305 372 0079

Jose Ignacio Rasco

Manager

01 305 372 0075

r@straat.co

Mr. Nicolai Bezsonoff

Manager

01 305 372 0075

nicolai@cointernet.co

Limited liability company

NU DOTCO LLC is a UNITED STATES entity, registered in the STATE of DELAWARE as a limited liability company.

Not Available

Jose Ignacio Rasco III
Manager
Juan Diego Calle
Manager
Nicolai Bezsonoff
Manager

Jose Ignacio Rasco III
CFO
Juan Diego Calle
CEO
Nicolai Bezsonoff
COO

Domain Marketing Holdings, LLC
Not Applicable
NUCO LP, LLC
Not Applicable

LTD

Not Available

NU DOTCO, LLC (“NU.CO”) foresees no known rendering issues in connection with the proposed .LTD TLD which it is seeking to apply for as a gTLD. This answer is based upon consultation with NU.CO’s backend provider, Neustar, which has successfully launched a number of new gTLDs over the last decade. In reaching this determination, the following data points were analyzed:
• 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;

The mission of .LTD is to provide businesses and organizations that are structured as a private limited company with an alternative “home domain” for their online presence. We envision that through strategic marketing campaigns designed to brand the domain, it will become a premium online namespace for a variety of companies structured as an LTD. Given the prevalence of this corporate structure in the United Kingdom and other Commonwealth nations (e.g., India, Canada, etc.), the addressable need is significant. While difficult to pinpoint, estimates indicate that over 750,000 businesses are registered using this structure in the United Kingdom alone. Private limited companies generally have to provide public notice of their legal structure (i.e. displaying “Ltd.” or “Limited” in their name) in order to avail its owners of the associated benefits. The .LTD TLD can aid registrants in complying with this requirement. This general domain will also provide new registrants with better, more relevant alternatives to the limited options remaining for current commercial TLD names. In addition, recognizing that “LTD” is commonly referenced under law as a means of identifying a specific type of business entity in the UK and other countries, we would like to provide an opportunity during the Sunrise Period to registered companies and businesses, in all major jurisdictions around the world, to participate under their trade names in order to protect legitimate businesses and consumers from confusion or fraud. For example, in the UK, we will engage relevant company incorporation agencies to ensure that legally and appropriately registered trade names, have an adequate period of time to purchase a new domain name matching their trade name. More details on this can be found on the reply to question 29 and in section 18-C below. 

18.2 How will .LTD benefit registrants, Internet users, and others? 
.LTD seeks to offer registrants and the broader internet community, with a reliable, trusted, and secure top level domain (TLD). This more relevant TLD option helps identify, and categorize the content of a site, ultimately aiding registrants with their marketing efforts. The descriptive identifier also provides a meaningful opportunity to structure and distinguish corporate content from the proliferation of other internet sites. Congestion in the current availability of commercial TLD names fundamentally advantages older incumbent players. Providing access to additional high-value second level domain names (i.e. shorter and more memorable) will provide an opportunity for new entrants to compete effectively for internet users’ finite attention. The domain’s coherent and consistent branding will assist registrants in developing meaningful emotional connection with users, allowing them to further differentiate themselves as premium destinations. These marketing efforts along with the initial adoption of key industry players, should reinforce the implicit attribution of “cutting-edge” and “innovativeness” upon its registrants. Prospective users benefit from the long-term commitment of a proven executive team that has a track-record of building and successfully marketing affinity TLD’s (e.g., .CO targeting innovative businesses and entrepreneurs). 

The demand for having an online presence continues to grow worldwide, especially as more people and businesses become active internet users, enjoying the increases in productivity and promotional effectiveness that the internet offers. A clear example of this is the number of worldwide internet users, which has grown at an average18% annual rate over the past decade, and domain registrations which have experienced similar adoption rates having grown from approximately 25mm in 2000 to over 225mm today. 

In particular for small businesses and entrepreneurs, the Internet offers an incredibly useful way to promote themselves to a wider audience, both locally and globally. Moreover, it allows them to cost-effective offer their products and services directly to consumers, leveling the playing field with larger and more established competitors. A number of new and innovative business models have been established that were not possible prior to the Internet, creating substantial value for society. 

However, until a few years ago it was difficult and costly for individuals and small businesses to establish an internet presence. This has changed as prices decreased dramatically and offerings became more accessible and intuitive. This is the result of having many retailers (i.e. registrars or resellers) that compete amongst each other on price, along with product and service differentiation. Differentiation has mainly centered around higher value-add services ancillary to the domain registration itself, such as hosting, web-site builders, SSL, e-mail, etc. The basic product (a domain) has not changed much, and until now, there have been few feasible alternatives to the commercial TLDs. The proposed new TLDs will provide users with more relevant and customized options. Just as ICANN opened up the market for the distribution and registration of domains and created the Registrar industry, which ultimately benefitted hundreds of millions of people and businesses worldwide, we expect that the introduction of new TLDs will yield similar benefits. 

The experienced team behind this application initially launched and currently operates the .CO ccTLD. The intention is for .LTD to be added to .CO’s product portfolio, where it can benefit from economies of scale along with the firm’s experience and expertise in marketing and branding TLD properties. Their successful track record proves that properly branded affinity domains can help sites form deeper emotional connections with their users, providing significant value-add. The .CO re-launch is a great illustration of how a new option in TLDs can address the unmet needs an affinity group (e.g., small businesses and start-ups), and we continue to firmly believe that the new .LTD domain will provide better, more relevant solutions for limited companies across a variety of industries. 

Since its launch, .CO’s marketing has primarily focused on developing a worldwide ecosystem of innovative small businesses and entrepreneurs. To date, the .CO registry, .CO Internet S.A.S, has reached close to 1.3 million domains under management, with more than one million individual new Registrations in the first year alone and a renewal rate for domains purchased during launch of nearly 70% and a current average renewal rate of 65%. The renewal rate is one of the highest amongst the industry and especially high considering it has not yet reached the multiple year expiration dates, where it’s expected to climb even higher. In addition, .CO has become the standard secondary option to .COM for the leading global registrars, having the most conversions when presented with a non-.COM option. Further, .CO has secured a strong position with the tech startup community by securing such high profile users as Twitter (t.co), Google (g.co), tech influencers like Angel list (angel.co) and 500 Startups (500.co), and entrepreneurship organizations like Startup America (s.co). 

.CO has differentiated itself from other existing TLDs by combining innovative branding with the highest standards in trademark protection, unprecedented marketing campaigns, and pro-active security monitoring. We plan to implement a very similar strategy for .LTD in its launch, operation, promotion and growth. 

We plan to target a similar community of entrepreneurs, startups, and progressive entities that are looking for an online presence with a suitable domain name. We anticipate the addressable community will continue to grow as traditional businesses choose to launch an online presence for their pre-existing operations and as entrepreneurs launch new start-ups. The domain’s marketing strategy will utilize a 3 pillar framework, similar to that used with .CO: 

- Awareness: We plan to launch marketing campaigns to both the small businesses and entrepreneurs promoting .LTD via a combination of:
o Media placements online and offline
o Social media campaigns
o Events
o Sponsorships
o Endorsements
o PR efforts
o Direct marketing 
o Channel marketing 

- Usage: We plan to foster the community of users of .LTD via a combination community engagement and outreach, use-case development and direct marketing to base. 

- Distribution: The distribution will be done through the existing ICANN accredited registrar channel and will include marketing at the point of sale, packages and bundles, campaigns, etc. 

The marketing plans will evolve depending on market conditions, but using .CO as an example, we implemented an awareness and branding strategy that included the creation of a brand identity and logo; mass media placements including 2 super-bowl commercials with one of our partners plus many TV placements; billboards and other outdoors campaigns; several online media campaigns including networks, re-targeting and videos; ongoing Twitter, Facebook engagements; sponsorship and presence in a variety of events for TMs (INTA), Tech startups (SxSW, Web 2.0, Internetweek, etc.), Startups (Task Rabbit TR.co), Community (ICANN, LACTLD, etc.), etc. We also implemented for .CO a strong usage promotion of the domain by creating and fostering a community of .CO users and case studies. We achieved this through a combination of events, sponsorships, and partnerships with different entities like Angel.co, 500.co, Startup America (s.co), founders institute (fi.co), etc. We also cultivated many case studies of successful .CO users, remaining in close contact with them. Finally, we implemented a rigorous channel marketing and sales plan that included marketing placements at the point of purchase plus co-marketing and community outreach. 

While we do plan to follow a similar strategy to achieve widespread awareness, usage and distribution, the budget and actual placements for promoting .LTD will be scaled down accordingly, as neither its volume of registrations or revenues is expected to be in line with that of .CO. 

By launching the .LTD domain we expect to provide more descriptive⁄ relevant options for end-users, including access to desirable second level domain names which are unavailable or occupied by current general TLD’s. As illustrated with .CO, the rapid growth to 1.3 million domains is evidence of pent up demand in the marketplace for good, descriptive domain names. We expect that our marketing strategies will result in a new branded and available option that will emotionally connect with potential users and allow them to differentiate themselves through the use of a branded premium domain. 

We will also follow the same ICANN rules and distribution methods of major gTLDs thereby ensuring Registrars and Resellers do not have to change their systems to distribute the .LTD domain. As our systems are already integrated with largest registrars in the world and we have implemented industry best practices, the transition to delegation and launch should be seamless to the registrar channel as well as consumers. 

We will also implement a thick whois and adopt any ICANN recommendations or requirements in the future. In order to protect the privacy of our users, we will allow the use of Privacy or Proxy registrations by reputable registrars that comply with applicable policies specified by ICANN. We find this service is highly valuable for registrants that want to ensure their information is not available online and would like to maintain a higher level privacy. 

18.3 .LTD operating rules to benefit consumers 

NU DOTCO LLC is formed by the experienced team that initially launched and currently operates the .CO ccTLD. It has relevant, first-hand experience with the launch and operation of a domain including a strong focus on rights protection mechanisms and adoption of the latest policies and best practices for the benefit of consumers, businesses, and brands alike. The .CO registry has been praised in the trademark and IP community for its comprehensive implementation of rights-protection mechanisms. During itʹs launch in 2010, .CO implemented processes that went far beyond what had been considered best practices until that point in time. Two examples are the Globally Protected Marks List (GPML), which protect the rights of the top 100 brands in the world, and the Rapid Domain Compliance Process (RDCP), which enables the registry to quickly suspend any .CO domain name if it’s being used in a manner that appears to threaten the stability, integrity or security of the .CO registry, or any of its registrar partners. These initiatives, among others, earned .CO a nomination by the World Trademark Review during its annual 2011 IP awards ceremony. 
In addition, .CO implemented a thorough Sunrise phase that allowed Trademark owners globally to apply and secure the domain prior to anybody else. The Sunrise was very successful handling over 10,000 applications and resulting in a very smooth allocation process with minimal if any issues or complaints during and after the process was carried out. We at .CO ensured there was enough awareness of the Sunrise process through a series of campaigns that included an IP community outreach at events like INTA in Boston May 2010, where we had a significant presence, articles with several IP publications and outreach with the largest Corporate Registrars. 

Since then, the .CO domain has grown to over 1.3 million domains under management, and the number of trademark complaints through the UDRP remains relatively low (less than 100 so far), a testament of the robustness of the rights protection mechanisms implemented. 

We plan to continue to build on the strong right protection mechanisms we have implemented in the past. Therefore, recognizing that “LTD” is commonly referenced under law as a means of identifying a specific type of business entity in the UK and other countries, we would like to provide an opportunity during the Sunrise Period to registered companies and businesses, in all major jurisdictions around the world, to participate under their trade names in order to protect legitimate businesses and consumers from confusion or fraud. For example, in the UK, we will engage the appropiate company incorporation agency to ensure that legally and appropriately registered trade names, have an adequate period of time to purchase a new domain name matching their trade name. Specifically, this phase would allow a company such as ʺMycompany, LTD.ʺ to register the equivalent ʺMyCompany.LTDʺ before the registry opens for General Availability to the public.

We plan to follow all ICANN policies, including the best practices and recommendations for gTLDs. This will allow us to ensure end-users, have an easy way to register⁄purchase, administer, and use their domains. Adopting these policies will also prevent malicious behavior by third parties and ensure a smooth operation of the domain. The plans for the launch will be similar to the launch process used in .CO, which included: 

- Gradual Offering Plan: The .CO launch included a very comprehensive gradual opening plan that both protected trademarks and provided transparency to end users. The launch was lauded by ICANN for its comprehensiveness and management. For the launch of .LTD we will follow ICANN’s policies especially as it relates to the Trademark Clearinghouse which was similar to the process we used for .CO: 
- 
o Sunrise: Provide a period of a few weeks to allow the TM and IP community to register their .LTD domains prior to the opening to the public. Trademark validations will be done by the Trademark Clearinghouse or as specified by ICANN in their policies. If there are multiple validated applications, these would go to auction and allocated based on these results. Additionally, as mentioned above allow registered companies and businesses, in all major jurisdictions around the world, to participate in the Sunrise under their trade names in order to protect legitimate businesses and consumers from confusion or fraud. For example, in the UK, we will engage the appropiate company incorporation agency to ensure that legally and appropriately registered trade names, have an adequate period of time to purchase a new domain name matching their trade name. Specifically, this phase would allow a company such as ʺMycompany, LTD.ʺ to register the equivalent ʺMycompany.LTDʺ before the registry opens for General Availability to the public. 

o Landrush: Provide a period of a few weeks to allow domain investors and others that are interested in premium domains to apply for these domains. Once the period of the Landrush phase is over, a process to check the applications will determine if these were unique or if there were multiple applicants. If single applicants, then the domain is awarded at that time. If multiple applicants then the domain would go to an auction in which all applicants would be able to participate. For .CO this process included close to 30,000 applications and the resulting auctions were managed by Pool.com. The process was very successful managing to allocate very efficiently domains according to their perceived value by applicants and bidders at the resulting auctions. 

- General Availability: For .CO we had 100k registrations in the first 10 minutes and we didn’t have a single issue nor service degradation through the launch or afterwards. We achieved this through a combination of strong planning between our partners, especially Neustar our back-end provider; communication with our Registrars prior and during the launch in a very structured way; strong infrastructure planning and provisioning; and effective load, contingency, and disaster recovery planning. We plan to use similar methods for the launch of .LTD.
o First come first serve during GA and afterwards, which we believe is the best mechanism to ensure a fair allocation of domains once the domain has been launched. 
o Use of UDRP and any other best-practices in rights protection mechanisms
o Highly managed General Availability launch 
o Additionally, we intend to develop other protection mechanisms in consultation with the global community of entities that offer company incorporations or trade names. For example, we could incorporate a feature that will allow names registered with each incorporation agency (e.g. Incorporation Agencies in the UK) to be denoted in the public Whois with additional fields that identify that domain as having been validated or sourced from a valid Incorporation Agency. This could be implemented relatively easily using existing EPP functionality based on name-value pairs as .CO used during its Sunrise’s phase.
- Premium Domains: We will keep some domains for premium sales and these will be restricted prior to the Gradual Offering Plan begins, but can be applied for during the Sunrise phase. These premium domains will be brokered or sold via auction directly or through an accredited 3rd party. With .CO we used this mechanism as a way to allocate high value domains and also to promote the usage of the domain by high profile companies including Twitter with t.co, Google with g.co, Startup America with s.co, as well as a myriad of smaller startups and other endorsements. 

No

Not Available

No

In preparation for answering this question, NU DOTCO, LLC (NU.CO) reviewed the following relevant background material regarding the protection of geographic names in the DNS, including: 

- ICANN Board Resolution 01-92 regarding the methodology developed for the reservation and release of country names in the .INFO top-level domain (see http:⁄⁄www.icann.org⁄en⁄minutes⁄minutes-10sep01.htm); 

- ICANN’s Proposed Action Plan on .INFO Country Names (see http:⁄⁄www.icann.org⁄en⁄meetings⁄montevideo⁄action-plan-country-names-09oct01.htm); 

- “Report of the Second WIPO Internet Domain Name Process: The Recognition and Rights and the Use of Names in the Internet Domain Name System,ʺ Section 6, Geographical Identifiers (see http:⁄⁄www.wipo.int⁄amc⁄en⁄processes⁄process2⁄report⁄html⁄report.html); 

- ICANN’s Governmental Advisory Committee (GAC) Principles Regarding New gTLDs, (see https:⁄⁄gacweb.icann.org⁄download⁄attachments⁄1540128⁄gTLD_principles_0.pdf?version=1&modificationDate=1312358178000); and 

- ICANN’s Generic Names Supporting Organization (GNSO) Reserved Names Working Group – Final Report (see http:⁄⁄gnso.icann.org⁄issues⁄new-gtlds⁄final-report-rn-wg-23may07.htm).

Initial Reservation of Country and Territory Names

NU.CO is committed to initially reserving the country and territory names contained in the internationally recognized lists described in Article 5 of Specification 5 attached to the New gTLD Applicant Guidebook at the second level and at all other levels within the .LTD gTLD at which domain name registrations will be provided. Specifically, NU.CO will reserve:

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

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

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

Potential Future Release of Two Character Names

While NU.CO foresees no immediate need for plans to make use of these initially reserved country names at the second level within the .LTD namespace, NU.CO recognizes that there has been several successful and non-misleading use of country names by new gTLD operators as evidenced below:

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

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

NZ.COOP – Is operated by the New Zealand Cooperatives Association which brings together the country’s cooperative mutual business in a not-for-profit incorporated society.

USA.JOBS - Is operated by DirectEmployers Association (DE). While Employ Media the registry operator of the .JOBS gTLD is currently in a dispute with ICANN regarding the allocation of this and other domain names. Direct Employers has a series of partnerships and programs with the United States Department of Labor, the National Association of State Workforce Agencies and Facebook to help unemployed workers find jobs. 

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

The more likely request by NU.CO will come in connection with the un-reservation and allocation of two-letter .LTD domain names, e.g. US.LTD, UK.LTD, etc. If NU.CO should decide in the future to attempt and allocate these domain names, it would submit the proper Registry Service Evaluation Processes (RSEP) with ICANN. In evaluating similar RSEP requests that have been submitted to ICANN by other gTLD registry operators, NU.CO believes that its request would be favorably granted.

Creation and Updating the Policies

NU.CO is committed to continually reviewing and updating when necessary its policies in this area. Consistent with this commitment, NU.CO intends to remain an active participant in any ongoing ICANN policy discussion regarding the protection of geographic names within the DNS.

23.1 Introduction 

NU DOTCO LLC has elected to partner with NeuStar, Inc (“Neustar”) to provide back-end services for the .LTD registry. In making this decision, NU DOTCO LLC 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 .LTD 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. NU DOTCO LLC will use Neustar’s Registry Services platform to deploy the .LTD registry, by providing the following Registry Services (none of these services are offered in a manner that is unique to .LTD): 

-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. 

23.2.1 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. 

23.2.2 EPP

The .LTD 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.

23.2.3 DNS

NU DOTCO LLC 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.

23.2.4 WHOIS

Neustar’s existing standard WHOIS solution will be used for the .LTD. 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)

23.2.5 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.

23.2.6 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.

23.2.7 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.

23.2.8 Access to Bulk Zone Files

NU DOTCO LLC 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.

23.2.9 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.

23.2.10 IPv6 Support

The .LTD 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.

23.2.11 Required Rights Protection Mechanisms

NU DOTCO LLC, 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.

23.2.12 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 

NU DOTCO LLC will not be offering services that are unique to .LTD.

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

NU DOTCO LLC has partnered with NeuStar, Inc (ʺNeustarʺ), an experienced TLD registry operator, for the operation of the .LTD Registry. The applicant 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

24.2.1 High-level SRS System Description

The SRS to be used for .LTD 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, NU DOTCO LLC 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).

24.2.2 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 the applicant, to produce a complete history of changes for any domain name.

24.2.3 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. 

24.2.4 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.

24.2.5 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. 

24.2.6 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 attached depicts the overall SRS architecture including network components.

24.2.7 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 .LTD 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. 

24.2.8 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 .LTD.

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: 

24.2.9 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.

24.2.10 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.

24.2.11 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.

24.2.12 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. 

24.2.13 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.

24.2.14 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. 

24.2.15 Compliance with Specification 6 Section 1.2

The SRS implementation for .LTD 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 attached. 

Additional information on the EPP implementation and compliance with RFCs can be found in the response to Question 25.

24.2.16 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 .LTD 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 .LTD 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 .LTD registry. 

25.1 Introduction

NU DOTCO LLC’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 NU DOTCO LLC is provided with an unparalleled EPP based registry. The following discussion explains the EPP interface which will be used for the .LTD registry. This interface exists within the protocol farm layer as described in Question 24 and is depicted in Figure 25-1 attached.

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 attached, 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 attached. Evidence of Neustar’s ability to perform at these levels can be found in the .biz monthly progress reports found on the ICANN website.

25.3.1 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 .LTD 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 attached provides a list of extensions developed for other TLDs. Should the .LTD 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 .LTD registry is attached in the document titled “EPP Schema Files.”

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 .LTD registry.

26.1 Introduction

.LTD 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. .LTD’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 .LTD’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, .LTD’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 attached 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..LTD). 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 attached 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%, less than or equal to 60 minutes. Please note that Neustar’s current architecture is built towards the stricter SLAs (95%, less than or equal to 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 attached shows an architectural depiction of the new 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 .LTD 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 .LTD registry. The resources are more than adequate to support the WHOIS needs of all the TLDs operated by Neustar, including the .LTD registry.  

27.1 Registration Life Cycle

27.1.1 Introduction

.LTD will follow the lifecycle and business rules found in the majority of gTLDs today. Our back-end operator, Neustar, has over ten years of experience managing numerous TLDs that utilize standard and unique business rules and lifecycles. This section describes the business rules, registration states, and the overall domain lifecycle that will be use for .LTD.

27.1.2 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 .LTD registry per the defined .LTD 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 .LTD 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 .LTD 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 .LTD registry.
-Hold – Removes the domain from the DNS zone.
-UpdateProhibted – Prevents the object from being modified by an Update command.
-TransferProhibted – Prevents the object from being transferred to another Registrar by the Transfer command.
-RenewProhibted – Prevents a domain from being renewed by a Renew command.
-DeleteProhibted – 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. 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.

27.2 Registration States

27.2.1 Domain Lifecycle – Registration States

As described above the .LTD 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. 

27.2.2 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.

27.2.3 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.

27.2.4 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.

27.2.5 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.

27.2.6 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.

27.3 Typical Registration Lifecycle Activities

27.3.1 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. 

27.3.2 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. 

27.3.4 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 .LTD will follow that term restriction. 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.

27.3.5 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:

1. The gaining (new) Registrar submits a Transfer command, which includes the AuthInfo code of the domain name.

2. 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

3. A poll message notifying the losing Registrar of the pending transfer is sent to the Registrar’s message queue

4. 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

5. If the losing Registrar has not Acked or Nacked the transfer request within the 120 hour timeframe, the Registry auto-approves the transfer

6. 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.

27.3.6 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.

27.4 Applicable Time Elements

The following section explains the time elements that are involved. 

27.4.1 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.

27.4.2 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. 

27.4.3 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). 

27.4.4 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.

27.4.5 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. 

27.4.6 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.

27.4.7 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.

27.5 State Diagram

Figure 27-1 attached 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 27.2 for detailed descriptions 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.

27.5.1 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. 

27.6 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 NU DOTCO LLC 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 .LTD 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 .LTD registry. 

28.1 Abuse Prevention and Mitigation

Strong abuse prevention of a new gTLD is an important benefit to the internet community. .LTD and its registry operator and 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 .LTD 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, NU DOTCO LLC’s partner, Neustar has developed the ability to efficiently work with various law enforcement and security communities to begin a new phase of mitigation of these types of threats.

28.1.1 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 .LTD’s registry provider, Neustar is at the forefront of the prevention of such abusive practices and is one of the few registry operators to have actually developed and implemented an active “domain takedown” policy. We also believe that a strong program is essential given that registrants have a reasonable expectation that they are in control of the data associated with their domains, especially its presence in the DNS zone. Because domain names are sometimes used as a mechanism to enable various illegitimate activities on the Internet often the best preventative measure to thwart these attacks is to remove the names completely from the DNS before they can impart harm, not only to the domain name registrant, but also to millions of unsuspecting Internet users.

Removing the domain name from the zone has the effect of shutting down all activity associated with the domain name, including the use of all websites and e-mail. The use of this technique should not be entered into lightly. .LTD 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. 

28.1.2 Abuse Point of Contact 

As required by the Registry Agreement, .LTD 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. .LTD will also provide such information to ICANN prior to the delegation of any domain names in the TLD. This information shall consist of, at a minimum, a valid e-mail address dedicated solely to the handling of malicious conduct complaints, and a telephone number and mailing address for the primary contact. We will ensure that this information will be kept accurate and up to date and will be provided to ICANN if and when changes are made. In addition, with respect to inquiries from ICANN-Accredited registrars, our registry services provider, Neustar shall have an additional point of contact, as it does today, handling requests by registrars related to abusive domain name practices. 

28.2 Policies Regarding Abuse Complaints

One of the key policies each new gTLD registry will need to have is an Acceptable Use Policy that clearly delineates the types of activities that constitute “abuse” and the repercussions associated with an abusive domain name registration. In addition, the policy will be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This will include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. 

.LTD 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 NU DOTCO LLC to lock, cancel, transfer or otherwise suspend or take down domain names violating the Acceptable Use Policy and allow the Registry where and when appropriate to share information with law enforcement. Each ICANN-Accredited Registrar must agree to pass through the Acceptable Use Policy to its Resellers (if applicable) and ultimately to the TLD registrants. Below is the Registry’s initial Acceptable Use Policy that we will use in connection with .LTD.

28.2.1 .LTD Acceptable Use Policy

This Acceptable Use Policy gives the Registry the ability to quickly lock, cancel, transfer or take ownership of any .LTD 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 .LTD’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. \

28.2.2 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”. 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.

28.2.2.1 Coordination with Law Enforcement

With the assistance of Neustar as its back-end registry services provider, .LTD 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 .LTD for rapid resolution of the request. 

In the event such request involves any of the activities which can be validated by the Registry and involves the type of activity set forth in the Acceptable Use Policy, the sponsoring registrar is then given 12 hours to investigate the activity further and either take down the domain name by placing the domain name on hold or by deleting the domain name in its entirety or providing a compelling argument to the registry to keep the name in the zone. If the registrar has not taken the requested action after the 12-hour period (i.e., is unresponsive to the request or refuses to take action), the Registry will place the domain on “serverHold”. 

28.2.3 Monitoring for Malicious Activity

.LTD’s partner, Neustar is at the forefront of the prevention of abusive DNS practices. Neustar is one of only a few registry operators to have actually developed and implemented an active “domain takedown” policy in which the registry itself takes down abusive domain names. 

Neustar’s approach is quite different from a number of other gTLD Registries and the results have been unmatched. 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. 

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.

28.2.3.1 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:

28.2.3.2 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.

28.2.3.3 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 contacts the responsible 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. 

28.2.3.3.1 Coordination with Law Enforcement & Industry Groups

One of the reasons for which Neustar was selected to serve as the back-end registry services provider by .LTD is Neustar’s extensive experience with its industry-leading abusive domain name and malicious monitoring program and its 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, .LTD 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. .LTD 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 .LTD and⁄or Neustar for rapid resolution of the request. 

In the event such request involves any of the activities which can be validated by .LTD 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 .LTD 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 

.LTD acknowledges that ICANN has developed a number of mechanisms over the past decade that are intended to address the issue of inaccurate WHOIS information. Such measures alone have not proven to be sufficient and therefore .LTDwill put forth additional efforts to address this by undertaking the following measures:
 1) A mechanism a procedures to address domain names with inaccurate or incomplete WHOIS data
 2) Policies and Procedures to ensure compliance including include audits

- Mechanism to address with inaccurate WHOIS data: a procedure whereby third parties can submit complaints directly to the Applicant (as opposed to ICANN or the sponsoring Registrar) about inaccurate or incomplete WHOIS data. Such information shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, .LTD will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, Applicant reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.

- Policies and Procedures to ensure compliance: .LTD shall on its own initiative, no less than twice per year, perform a manual review of a random sampling of .LTD domain names to test the accuracy of the WHOIS information. Although this will not include verifying the actual information in the WHOIS record, .LTD will be examining the WHOIS data for prima facie evidence of inaccuracies. In the event that such evidence exists, it shall be forwarded to the sponsoring Registrar, who shall be required to address those complaints with their registrants. Thirty days after forwarding the complaint to the registrar, the Applicant will examine the current WHOIS data for names that were alleged to be inaccurate to determine if the information was corrected, the domain name was deleted, or there was some other disposition. If the Registrar has failed to take any action, or it is clear that the Registrant was either unwilling or unable to correct the inaccuracies, .LTD reserves the right to suspend the applicable domain name(s) until such time as the Registrant is able to cure the deficiencies.


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 .LTD registry. 

29.1 Rights Protection Mechanisms

NU DOTCO LLC is formed by the experienced team that initially launched and currently operates the .CO ccTLD. It has relevant, first-hand experience with the launch and operation of a domain including a strong focus on rights protection mechanisms and adoption of the latest policies and best practices. The .CO registry has been praised in the trademark and IP community for its comprehensive implementation of rights-protection mechanisms. During itʹs launch in 2010, .CO implemented processes that went far beyond what had been considered best practices until that point in time. Two examples are the Globally Protected Marks List (GPML), which protect the rights of the top 100 brands in the world, and the Rapid Domain Compliance Process (RDCP), which enables the registry to quickly suspend any .CO domain name if it’s being used in a manner that appears to threaten the stability, integrity or security of the .CO registry, or any of its registrar partners. These initiatives, among others, earned .CO a nomination by the World Trademark Review during its annual 2010 IP awards ceremony. 

In addition, .CO implemented a thorough Sunrise phase that allowed Trademark owners globally to apply and secure the domain prior to anybody else. The Sunrise was very successful handling over 10,000 applications and resulting in a very smooth allocation process with minimal if any issues or complaints during and after the process was carried out. We at .CO ensured there was enough awareness of the Sunrise process through a series of campaigns that included an IP community outreach at events like INTA in Boston May 2010, where we had a significant presence, articles with several IP publications and outreach with the largest Corporate Registrars. 

Since then, the .CO domain has grown to over 1.3 million domains under management, and the number of trademark complaints through the UDRP remains relatively low (less than 133 so far), a testament of the robustness of the rights protection mechanisms implemented. 
We plan to continue to build on the strong right protection mechanisms we have implemented in the past. Therefore, recognizing that the string “.LTDʺ is commonly referenced under law as a means of identifying a specific type of business entity in the UK and other countries, we would like to provide an opportunity during the Sunrise Period to registered companies and businesses, in the UK and other major jurisdictions around the world, to participate under their trade names in order to protect legitimate businesses and consumers from confusion or fraud. For example, in the UK, we will engage with the appropriate state agencies to ensure that legally and appropriately registered trade names, have an adequate period of time to purchase a new domain name matching their trade name. Specifically, this phase would allow a company such as ʺMycompany LTDʺ to register the equivalent ʺMycompany.LTDʺ before the registry opens for General Availability to the public. 

Additionally, we intend to develop other protection mechanisms in consultation with the global community of entities that offer company incorporations or trade names. For example, we could incorporate a feature that will allow names registered with each incorporation agency to be denoted in the public Whois with additional fields that identify that domain as having been validated or sourced from a valid agency. This could be implemented relatively easily using existing EPP functionality based on name-value pairs as .CO used during its Sunrise’s phase. 

This of course will require the collaboration of the participating organizations in the UK, and the equivalent organizations in other major countries where that same identifier is used, in order to maximize the effectiveness of the process. 

NU DOTCO LLC is firmly committed to the protection of Intellectual Property rights and to implementing the mandatory rights protection mechanisms contained in the Applicant Guidebook and detailed in Specification 7 of the Registry Agreement. .LTD recognizes that although the New gTLD program includes significant protections beyond those that were mandatory for a number of the current TLDs, a key motivator for .LTD’s selection of Neustar as its registry services provider is Neustar’s experience in successfully launching a number of TLDs with diverse rights protection mechanisms, including many the ones required in the Applicant Guidebook. More specifically, .LTD will implement the following rights protection mechanisms in accordance with the Applicant Guidebook as further described below:

-Trademark Clearinghouse: a one-stop shop so that trademark holders can protect their trademarks with a single registration.
-Sunrise and Trademark Claims processes for the TLD.
-Implementation of the Uniform Dispute Resolution Policy to address domain names that have been registered and used in bad faith in the TLD.
-Uniform Rapid Suspension: A quicker, more efficient and cheaper alternative to the Uniform Dispute Resolution Policy to deal with clear cut cases of cybersquatting.
-Implementation of a Thick WHOIS making it easier for rights holders to identify and locate infringing parties

29.1.1 Trademark Clearinghouse Including Sunrise and Trademark Claims

The first mandatory rights protection mechanism (“RPM”) required to be implemented by each new gTLD Registry is support for, and interaction with, the trademark clearinghouse. The trademark clearinghouse is intended to serve as a central repository for information to be authenticated, stored and disseminated pertaining to the rights of trademark holders. The data maintained in the clearinghouse will support and facilitate other RPMs, including the mandatory Sunrise Period and Trademark Claims service. Although many of the details of how the trademark clearinghouse will interact with each registry operator and registrars, .LTD is actively monitoring the developments of the Implementation Assistance Group (“IAG”) designed to assist ICANN staff in firming up the rules and procedures associated with the policies and technical requirements for the trademark clearinghouse. In addition, .LTD’s back-end registry services provider is actively participating in the IAG to ensure that the protections afforded by the clearinghouse and associated RPMs are feasible and implementable.

Utilizing the trademark clearinghouse, all operators of new gTLDs must offer: (i) a sunrise registration service for at least 30 days during the pre-launch phase giving eligible trademark owners an early opportunity to register second-level domains in new gTLDs; and (ii) a trademark claims service for at least the first 60 days that second-level registrations are open. The trademark claim service is intended to provide clear noticeʺ to a potential registrant of the rights of a trademark owner whose trademark is registered in the clearinghouse.

.LTD’s registry service provider, Neustar, has already implemented Sunrise and⁄or Trademark Claims programs for numerous TLDs including .biz, .us, .travel, .tel and .co and will implement the both of these services on behalf of .LTD. 

29.1.1.1 Neustar’s Experience in Implementing Sunrise and Trademark Claims Processes

In early 2002, Neustar became the first registry operator to launch a successful authenticated Sunrise process. This process permitted qualified trademark owners to pre-register their trademarks as domain names in the .us TLD space prior to the opening of the space to the general public. Unlike any other “Sunrise” plans implemented (or proposed before that time), Neustar validated the authenticity of Trademark applications and registrations with the United States Patent and Trademark Office (USPTO). 

Subsequently, as the back-end registry operator for the .tel gTLD and the .co ccTLD, Neustar launched validated Sunrise programs employing processes. These programs are very similar to those that are to be employed by the Trademark Clearinghouse for new gTLDs. 

Below is a high level overview of the implementation of the .co Sunrise period that demonstrates Neustar’s experience and ability to provide a Sunrise service and an overview of Neustar’s experience in implementing a Trademark Claims program to trademark owners for the launch of .BIZ. Neustar’s experience in each of these rights protection mechanisms will enable it to seamlessly provide these services on behalf of .LTD as required by ICANN. 

a) Sunrise and .co

The Sunrise process for .co was divided into two sub-phases: 

-Local Sunrise giving holders of eligible trademarks that have obtained registered status from the Colombian trademark office the opportunity apply for the .CO domain names corresponding with their marks 
-Global Sunrise program giving holders of eligible registered trademarks of national effect, that have obtained a registered status in any country of the world the opportunity apply for the .CO domain names corresponding with their marks for a period of time before registration is open to the public at large. 

Like the new gTLD process set forth in the Applicant Guidebook, trademark owners had to have their rights validated by a Clearinghouse provider prior to the registration being accepted by the Registry. The Clearinghouse used a defined process for checking the eligibility of the legal rights claimed as the basis of each Sunrise application using official national trademark databases and submitted documentary evidence. 

Applicants and⁄or their designated agents had the option of interacting directly with the Clearinghouse to ensure their applications were accurate and complete prior to submitting them to the Registry pursuant to an optional “Pre-validation Process”. Whether or not an applicant was “pre-validated”, the applicant had to submit its corresponding domain name application through an accredited registrar. When the Applicant was pre-validated through the Clearinghouse, each was given an associated approval number that it had to supply the registry. If they were not pre-validated, applicants were required to submit the required trademark information through their registrar to the Registry.
As the registry level, Neustar, subsequently either delivered the: 

-Approval number and domain name registration information to the Clearinghouse
-When there was no approval number, trademark information and the domain name registration information was provided to the 
Clearinghouse through EPP (as is currently required under the Applicant Guidebook). 

Information was then used by the Clearinghouse as either further validation of those pre-validated applications, or initial validation of those that did not go through pre-validation. If the applicant was validated and their trademark matched the domain name applied-for, the Clearinghouse communicated that fact to the Registry via EPP.
 
When there was only one validated sunrise application, the application proceeded to registration when the .co launched. If there were multiple validated applications (recognizing that there could be multiple trademark owners sharing the same trademark), those were included in the .co Sunrise auction process. Neustar tracked all of the information it received and the status of each application and posted that status on a secure Website to enable trademark owners to view the status of its Sunrise application. 

Although the exact process for the Sunrise program and its interaction between the trademark owner, Registry, Registrar, and IP Clearinghouse is not completely defined in the Applicant Guidebook and is dependent on the current RFI issued by ICANN in its selection of a Trademark Clearinghouse provider, Neustar’s expertise in launching multiple Sunrise processes and its established software will implement a smooth and compliant Sunrise process for the new gTLDs.

b) Trademark Claims Service Experience

With Neustar’s biz TLD launched in 2001, Neustar became the first TLD with a Trademark Claims service. Neustar developed the Trademark Claim Service by enabling companies to stake claims to domain names prior to the commencement of live .biz domain registrations. 

During the Trademark Claim process, Neustar received over 80,000 Trademark Claims from entities around the world. Recognizing that multiple intellectual property owners could have trademark rights in a particular mark, multiple Trademark Claims for the same string were accepted. All applications were logged into a Trademark Claims database managed by Neustar. 
The Trademark Claimant was required to provide various information about their trademark rights, including the:

-Particular trademark or service mark relied on for the trademark Claim
-Date a trademark application on the mark was filed, if any, on the string of the domain name
-Country where the mark was filed, if applicable
-Registration date, if applicable
-Class or classes of goods and services for which the trademark or service mark was registered
-Name of a contact person with whom to discuss the claimed trademark rights. 

Once all Trademark Claims and domain name applications were collected, Neustar then compared the claims contained within the Trademark Claims database with its database of collected domain name applications (DNAs). In the event of a match between a Trademark Claim and a domain name application, an e-mail message was sent to the domain name applicant notifying the applicant of the existing Trademark Claim. The e-mail also stressed that if the applicant chose to continue the application process and was ultimately selected as the registrant, the applicant would be subject to Neustar’s dispute proceedings if challenged by the Trademark Claimant for that particular domain name. 

The domain name applicant had the option to proceed with the application or cancel the application. Proceeding on an application meant that the applicant wanted to go forward and have the application proceed to registration despite having been notified of an existing Trademark Claim. By choosing to “cancel,” the applicant made a decision in light of an existing Trademark Claim notification to not proceed. 

If the applicant did not respond to the e-mail notification from Neustar, or elected to cancel the application, the application was not processed. This resulted in making the applicant ineligible to register the actual domain name. If the applicant affirmatively elected to continue the application process after being notified of the claimant’s (or claimants’) alleged trademark rights to the desired domain name, Neustar processed the application. 

This process is very similar to the one ultimately adopted by ICANN and incorporated in the latest version of the Applicant Guidebook. Although the collection of Trademark Claims for new gTLDs will be by the Trademark Clearinghouse, many of the aspects of Neustar’s Trademark Claims process in 2001 are similar to those in the Applicant Guidebook. This makes Neustar uniquely qualified to implement the new gTLD Trademark Claims process.

29.1.2 Uniform Dispute Resolution Policy (UDRP) and Uniform Rapid Suspension (URS)

29.1.2.1 UDRP

Prior to joining Neustar, Mr. Neuman was a key contributor to the development of the Uniform Dispute Resolution Policy (“UDRP”) in 1998. This became the first “Consensus Policy” of ICANN and has been required to be implemented by all domain name registries since that time. The UDRP is intended as an alternative dispute resolution process to transfer domain names from those that have registered and used domain names in bad faith. Although there is not much of an active role that the domain name registry plays in the implementation of the UDRP, Neustar has closely monitored UDRP decisions that have involved the TLDs for which it supports and ensures that the decisions are implemented by the registrars supporting its TLDs. When alerted by trademark owners of failures to implement UDRP decisions by its registrars, Neustar either proactively implements the decisions itself or reminds the offending registrar of its obligations to implement the decision. 

29.1.2.2 URS

In response to complaints by trademark owners that the UDRP was too cost prohibitive and slow, and the fact that more than 70 percent of UDRP cases were “clear cut” cases of cybersquatting, ICANN adopted the IRT’s recommendation that all new gTLD registries be required, pursuant to their contracts with ICANN, to take part in a Uniform Rapid Suspension System (“URS”). The purpose of the URS is to provide a more cost effective and timely mechanism for brand owners than the UDRP to protect their trademarks and to promote consumer protection on the Internet. 

The URS is not meant to address Questionable cases of alleged infringement (e.g., use of terms in a generic sense) or for anti-competitive purposes or denial of free speech, but rather for those cases in which there is no genuine contestable issue as to the infringement and abuse that is taking place. 

Unlike the UDRP which requires little involvement of gTLD registries, the URS envisages much more of an active role at the registry-level. For example, rather than requiring the registrar to lock down a domain name subject to a UDRP dispute, it is the registry under the URS that must lock the domain within 24hours of receipt of the complaint from the URS Provider to restrict all changes to the registration data, including transfer and deletion of the domain names. 

In addition, in the event of a determination in favor of the complainant, the registry is required to suspend the domain name. This suspension remains for the balance of the registration period and would not resolve the original website. Rather, the nameservers would be redirected to an informational web page provided by the URS Provider about the URS. 
Additionally, the WHOIS reflects that the domain name will not be able to be transferred, deleted, or modified for the life of the registration. Finally, there is an option for a successful complainant to extend the registration period for one additional year at commercial rates. 

.LTD is fully aware of each of these requirements and will have the capability to implement these requirements for new gTLDs. In fact, during the IRT’s development of f the URS, Neustar began examining the implications of the URS on its registry operations and provided the IRT with feedback on whether the recommendations from the IRT would be feasible for registries to implement. 

Although there have been a few changes to the URS since the IRT recommendations, Neustar continued to participate in the development of the URS by providing comments to ICANN, many of which were adopted. As a result, Neustar is committed to supporting the URS for all of the registries that it provides back-end registry services.

29.1.3 Implementation of Thick WHOIS

The .LTD registry will include a thick WHOIS database as required in Specification 4 of the Registry agreement. A thick WHOIS provides numerous advantages including a centralized location of registrant information, the ability to more easily manage and control the accuracy of data, and a consistent user experience. 

29.1.4 Policies Handling Complaints Regarding Abuse

In addition the Rights Protection mechanisms addressed above, NU DOTCO LLC will implement a number of measures to handle complaints regarding the abusive registration of domain names in its TLD as described in .LTD’s response to Question 28.

29.1.4.1 Registry Acceptable Use Policy

One of the key policies each new gTLD registry is the 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. The policy must be incorporated into the applicable Registry-Registrar Agreement and reserve the right for the registry to take the appropriate actions based on the type of abuse. This may include locking down the domain name preventing any changes to the contact and nameserver information associated with the domain name, placing the domain name “on hold” rendering the domain name non-resolvable, transferring to the domain name to another registrar, and⁄or in cases in which the domain name is associated with an existing law enforcement investigation, substituting name servers to collect information about the DNS queries to assist the investigation. .LTD’s Acceptable Use Policy, set forth in our response to Question 28, will include prohibitions on phishing, pharming, dissemination of malware, fast flux hosting, hacking, and child pornography. In addition, the policy will include the right of the registry to take action necessary to deny, cancel, suspend, lock, or transfer any registration in violation of the policy.

29.1.4.2 Monitoring for Malicious Activity 

.LTD 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”. 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.

29.3 Resourcing Plans

The rights protection mechanisms described in the response above involve a wide range of tasks, procedures, and systems. The responsibility for each mechanism varies based on the specific requirements. In general the development of applications such as sunrise and IP claims is the responsibility of the Engineering team, with guidance from the Product Management team. Customer Support and Legal play a critical role in enforcing certain policies such as the rapid suspension process. These teams have years of experience implementing these or similar processes. 

The necessary resources will be pulled from the pool of available resources described in detail in the response to Question 31. The following resources are available from those teams:

-Development⁄Engineering – 19 employees
-Product Management- 4 employees
-Customer Support – 12 employees

The resources are more than adequate to support the rights protection mechanisms of the .LTD registry. 

30.(a).1 Security Policies

NU DOTCO LLC and our back-end operator, Neustar recognize the vital need to secure the systems and the integrity of the data in commercial solutions. The .LTD 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 CIS (Center for Internet Security). 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 .LTD 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 .LTD
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 .LTD registry.

30.(a).2 Summary of Security Policies 

Neustar 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 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).3 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).4 Augmented Security Levels and Capabilities

There are no increased security levels specific for .LTD. 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).5 below.

30.(a).5 Commitments and Security Levels 

The .LTD 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.(b) 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